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Privacy Policy

Last updated: December 29, 2025

 

This Privacy Policy explains how De Civitate, UAB (“we”, “us”, “our”, or the “Company”) collects, uses, discloses, and protects personal data when you visit or use https://lithuaniandualcitizenship.com/ (the “Website”) and when you contact us or request an eligibility assessment (together, the “Services”).

We process personal data in accordance with the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and applicable Lithuanian and EU laws.

If you do not agree with this Privacy Policy, please do not use the Website.

1. Data Controller (Who is responsible for your data)

Controller: De Civitate, UAB
Address: Žalgirio g. 122, 09300 Vilnius, Lithuania
Email: info@lithuaniancitizenship.com
Phone: +370 521 40 187

2. Definitions

  • Personal Data means any information relating to an identified or identifiable natural person.

  • Processing means any operation performed on Personal Data (collection, storage, use, disclosure, deletion, etc.).

  • Controller means the entity that determines the purposes and means of Processing (De Civitate, UAB).

  • Processor means a third party that processes Personal Data on behalf of the Controller.

  • Cookies are small files stored on your device to enable or improve Website functionality, analytics, and advertising measurement.

3. What data we collect

3.1 Data you provide directly

When you fill in forms, request an assessment, or contact us, we may collect:

  • Contact details: full name, email address, phone number.

  • Inquiry content: message, information you choose to provide about your situation, timelines, and questions.

  • Eligibility/assessment details (if provided): information about ancestry/family history, relevant dates/places, and other details needed to evaluate eligibility.

Important: Please avoid sending highly sensitive information through general website forms unless it is necessary. If you decide to include sensitive information, we will handle it with increased care and only process it where lawful (see Section 5).

3.2 Data collected automatically (Usage Data)

When you use the Website, we may automatically collect technical and usage information such as:

  • IP address (and approximate location derived from IP, such as country/city)

  • browser type/version, device type, operating system

  • pages visited, time and date of visit, time spent on pages, clickstream data

  • referring page and diagnostic/security information

4. Cookies, analytics, and advertising (GA4, GTM, Google)

We use cookies and similar technologies. Some cookies are strictly necessary; others are optional and used only with your consent where required.

4.1 Tools we use

Based on current configuration, we use:

  • Google Analytics 4 (GA4) via Google Tag Manager (GTM) to understand Website usage and improve performance.

  • Google advertising/measurement tools (e.g., conversion measurement) to evaluate marketing effectiveness.

These tools may set cookies or use similar identifiers and may process data such as device information, usage events, and IP-derived location.

4.2 Managing cookies

You can manage cookies by:

  • using any cookie banner/consent settings displayed on the Website (if enabled), and/or

  • adjusting your browser settings to block or delete cookies.

If you block cookies, some features of the Website may not function properly.

5. Why we use your data (Purposes)

We use Personal Data to:

  1. Provide and operate the Website and ensure it functions properly.

  2. Respond to inquiries and communicate with you.

  3. Perform eligibility assessments or pre-engagement evaluation at your request.

  4. Improve the Website through analytics and performance measurement.

  5. Measure marketing performance (e.g., conversions and campaign effectiveness).

  6. Protect the Website and users (security, fraud prevention, troubleshooting).

  7. Comply with legal obligations and enforce our rights where necessary.

6. Legal bases for processing (GDPR)

We process your Personal Data under one or more of the following legal bases:

  • Consent (Art. 6(1)(a)): for optional cookies/advertising where required; and in limited cases for certain data you voluntarily provide.

  • Contract / pre-contract steps (Art. 6(1)(b)): to take steps at your request (e.g., assessment) and, if applicable, to provide services.

  • Legitimate interests (Art. 6(1)(f)): to operate, improve, and secure the Website; to measure performance; to prevent misuse—balanced against your rights.

  • Legal obligation (Art. 6(1)(c)): where we must comply with applicable laws.

Sensitive (special-category) data

If you provide information that may qualify as special categories of data under GDPR (Art. 9)—for example, information that reveals ethnicity or religious affiliation—we will process it only when permitted by law and when necessary for the relevant purpose, potentially relying on explicit consent (Art. 9(2)(a)) or another applicable Art. 9 condition.

7. Who we share data with

We may share Personal Data only as needed, including with:

  • Google (GA4/GTM and advertising measurement) for analytics and marketing measurement.

  • IT/hosting and technical service providers that help us operate the Website and communications (acting as processors where applicable).

  • Professional advisers (lawyers, accountants, auditors) where necessary and subject to confidentiality.

  • Authorities or courts if required by law, or to protect rights, safety, and security.

We do not sell your Personal Data.

8. International transfers

Some providers we use (including Google) may process data outside the European Economic Area (EEA), including in the United States.

Where international transfers occur, we implement appropriate safeguards as required by GDPR, such as Standard Contractual Clauses (SCCs) and additional measures where appropriate.

You may request more information about safeguards by contacting us at info@lithuaniancitizenship.com.

9. Data retention (How long we keep data)

We retain Personal Data only as long as necessary for the purposes described in this Policy, and to meet legal and operational requirements.

Typical retention periods (may vary by context):

  • Inquiry / assessment requests: up to 24 months after the last interaction.

  • Client-related records (if you become a client): typically up to 10 years after the end of the relationship (to meet legal, accounting, and limitation-period requirements).

  • Analytics data (GA4): generally up to 14 months (subject to configuration).

  • Security logs: typically up to 180 days, unless needed longer for investigation or legal claims.

We may anonymize data instead of deleting it where feasible.

10. Your rights under GDPR

Subject to applicable law, you have the right to:

  • Access your Personal Data and obtain a copy.

  • Rectify inaccurate or incomplete data.

  • Erase your data in certain cases.

  • Restrict processing in certain cases.

  • Data portability for certain data processed by automated means.

  • Object to processing based on legitimate interests (including analytics, where applicable).

  • Withdraw consent at any time (this does not affect processing already carried out).

To exercise your rights, contact us at info@lithuaniancitizenship.com. We may request verification to protect your data.

Complaints

You also have the right to lodge a complaint with a supervisory authority in the EU/EEA.

11. Security

We use reasonable technical and organizational measures to protect Personal Data (e.g., access controls, encryption in transit via HTTPS, and security monitoring). However, no online transmission or storage can be guaranteed as 100% secure.

12. Children’s privacy

The Website is not intended for children under 16. We do not knowingly collect Personal Data from children. If you believe a child has provided us Personal Data, please contact us so we can delete it.

13. Links to third-party websites

The Website may include links to third-party sites. We are not responsible for their privacy practices. Please review their privacy policies.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and revise the “Last updated” date above. Material changes may be communicated via a prominent notice on the Website.

15. Contact

If you have questions about this Privacy Policy or your Personal Data, contact us:

De Civitate, UAB
Žalgirio g. 122, 09300 Vilnius, Lithuania
Email: info@lithuaniancitizenship.com
Phone: +370 521 40 187