Terms and Conditions

GENERAL TERMS AND CONDITIONS FOR THE PROVISION OF ELECTRONIC SERVICES

1. Parties’ Data in the Data Processing Agreement (hereinafter – the Agreement): 1.1. Service Provider (hereinafter – the Service Provider):
Ethos Solutions, MB
Company Code: 306689726
VAT Code: LT100016734817
Address: Gėlių g. 4, Didžiulių k., LT-60295 Raseinių r.
Director: Andrius Šarkus
1.2. PARTNER (name and surname / legal form and name) (hereinafter – the Partner):
PERSONAL / COMPANY CODE:
ADDRESS:
PHONE, EMAIL:
DOCUMENT NUMBER AUTHORIZING ACTIVITY (IF REQUIRED):
2. The Data Processing Agreement (hereinafter – the Agreement or the Data Processing Agreement) is an annex to the General Terms and Conditions and constitutes an integral part thereof. In this annex, Ethos Solutions, MB (hereinafter – the Data Controller) and the Partner (hereinafter – the Data Processor) acknowledge that the Data Controller provides services to the Data Processor, which are accessible to the Data Processor through the Ethos Solutions, MB platform (hereinafter – the Services) under the General Terms and Conditions for the Provision of Electronic Services between the Parties. During the provision of these services, the Data Processor is provided with personal data processed by the Data Controller and processes personal data on behalf of the Data Controller.

1. GENERAL PROVISIONS

1.1. This Agreement establishes the conditions applicable to the processing of personal data managed by the Data Processor for a defined purpose. This Agreement supersedes and replaces any previous conditions regarding personal data processing that the Parties may have agreed upon (if any).
1.2. The Parties agree that the Data Processor carries out data processing concerning the Data Controller’s data obtained during the provision of services. The purpose of data processing is the execution of the Service Agreement, meaning that the Data Processor processes the data of clients receiving services on behalf of the Data Controller.
1.3. The data processing carried out under this Agreement is subject to the Standard Contractual Clauses for personal data processing agreements, approved by the Director of the State Data Protection Inspectorate by Order No. 1T-117 (1.12.E) of December 27, 2021, with the modifications and additions specified in this Agreement based on the Parties’ choices.
1.4. The Data Processor undertakes to process personal data only in accordance with documented instructions provided by the Data Controller, except where such processing is required under European Union law or the laws of an EU Member State applicable to the Data Processor. The Data Controller shall be liable to the Data Processor for any consequences resulting from unlawful instructions and shall compensate the Data Processor for any direct damages incurred due to such unlawful instructions.

2. DEFINITIONS

2.1. The terms used in this Agreement shall have the same meaning as those defined in the Regulation and the Law on Legal Protection of Personal Data of the Republic of Lithuania (hereinafter – the Law), as well as in other applicable legal acts.

3. RIGHTS AND OBLIGATIONS OF THE PARTIES

3.1. The Data Controller:
3.1.1. Undertakes to provide the Data Processor with binding instructions on how to process personal data, to always maintain authority and control over personal data, and to ensure that the applicable technical and organizational measures used by the Data Processor protect personal data against accidental or unlawful destruction, alteration, disclosure, or any other unauthorized processing.
3.1.2. Undertakes to ensure that personal data is processed in compliance with Article 24 of the Regulation, the Law, other applicable European Union or EU Member State legal acts regulating personal data protection and/or processing, and the terms of this Agreement.
3.1.3. Has the right and obligation to make decisions regarding the purposes and means of personal data processing.
3.1.4. Is responsible, including but not limited to, ensuring that the personal data processing assigned to the Data Processor has a legal basis.
3.1.5. Confirms that it has provided and will provide, during the execution of this Agreement, the necessary instructions to the Data Processor regarding the processing of personal data carried out on behalf of the Data Controller.
3.1.6. Undertakes, upon request from the Data Processor, to provide the necessary information required for the Data Processor to fulfill its obligations under personal data protection laws in relation to the processing of personal data assigned by the Data Controller.
3.1.7. Cooperates with the Data Processor and data subjects, applying appropriate technical and organizational measures to fulfill the obligation to respond to data subjects' requests to exercise their rights as established by applicable legal acts.
3.2. The Data Processor:
3.2.1. Must comply with the legal acts regulating data processing applicable in the Republic of Lithuania as well as the provisions of the Regulation.
3.2.2. Considering the nature of data processing and the information available to the Data Processor, assists the Data Controller in ensuring compliance with data processing security obligations in accordance with Article 32 of the Regulation. Taking into account the state of technological development, implementation costs, the nature, scope, context, and purposes of data processing, as well as the varying likelihood and severity of risks to the rights and freedoms of natural persons, the Data Processor shall take feasible measures to implement technical and organizational measures to ensure a level of security appropriate to the identified risks.
3.2.3. Takes measures to ensure that personal data is processed only by those natural persons who require access for the execution of functions assigned to the Data Processor. The Data Processor ensures that individuals entrusted with processing personal data have committed to maintaining confidentiality.
3.2.4. Processes personal data in accordance with the requirements and scope established in this Agreement or in other agreements concluded between the Data Controller and the Data Processor.
3.2.5. Has the right to engage sub-processors located and operating within EU or EEA countries. If the Data Processor intends to engage a sub-processor located outside the EU and/or EEA, prior specific approval from the Data Controller must be obtained.
3.2.6. Undertakes to have written agreements signed with all engaged sub-processors, ensuring that they impose data protection obligations identical to those established in this Agreement. The Data Processor further commits to regularly monitor the actions of its engaged sub-processors and assumes full responsibility for their actions as if they had been carried out by the Data Processor itself.
3.2.7. Considering the nature of the data processing, assists the Data Controller by implementing appropriate technical and organizational measures, to the extent possible, to fulfill the Data Controller’s obligation to respond to data subject requests in accordance with Chapter III of the Regulation. The Data Controller shall respond to such data subject requests, unless the Data Processor wishes to provide a response itself regarding the data processing activities it perform
s. 3.2.8. Undertakes to provide the Data Controller with all necessary information and assistance to demonstrate compliance with the obligations set forth in this Agreement. The Data Controller may conduct an audit to verify compliance with this Agreement by providing a written notice at least 14 days in advance.
3.2.9. Any inspection at the Data Processor’s premises shall be conducted only during working hours and with minimal disruption to regular operations. Individuals conducting the inspection must sign a confidentiality agreement before accessing the Data Processor’s premises. Upon request, the Data Controller shall provide the Data Processor with a copy of the inspection report.
3.2.10. Considering the nature of data processing and the information available to the Data Processor, upon a written request from the Data Controller, the Data Processor shall assist the Data Controller in complying with obligations related to:
• Notification to the supervisory authority and data subjects regarding a personal data breach,
• Data protection impact assessments (including prior consultations),
as required under Articles 33-36 of the Regulation.
If the Data Processor becomes aware of a personal data breach related to data processing carried out under this Agreement, it shall promptly notify the Data Controller without undue delay.
3.2.11. Upon completion of the services related to data processing, the Data Processor shall delete all personal data, except in cases where European Union law or the laws of a Member State require the retention of personal data, or if the Data Processor assumes the role of the Data Controller for such data.

4. TECHNICAL AND ORGANIZATIONAL MEASURES FOR DATA PROTECTION AND DOCUMENTATION MANAGEMENT

4.1. The Parties shall ensure the protection of processed personal data by implementing appropriate technical and organizational measures designed to safeguard personal data against accidental or unlawful destruction, damage, alteration, loss, disclosure, as well as any other unauthorized processing. These measures must ensure an adequate level of protection that corresponds to: The nature of the processed personal data, The risks arising from the processing of such data, and The appropriateness of the security measures, taking into account:
a) The state of technological development;
b) The costs of implementation;
c) The nature, scope, context, and purposes of data processing;
d) The risks posed by processing to the rights and freedoms of the natural persons whose personal data is being processed.
4.2. The security measures that the Data Processor undertakes to implement are specified in the General Security Requirements (Annex No. 1 to the Data Processing Agreement), in other instructions issued by the Data Controller (if any), and in applicable legal acts.
4.3. The Data Processor undertakes to ensure the confidentiality of personal data at all times and guarantees that access to personal data will be granted only to those employees or authorized persons of the Data Processor who require such access to perform their assigned functions. Personal data shall only be processed to the extent permitted by the Data Processor’s granted rights. The Data Processor further commits to ensuring that individuals authorized to process personal data are: Properly informed about the confidentiality of personal data, Adequately trained on how to fulfill their duties and comply with the data processing requirements established in this Agreement, the instructions of the Data Controller, and applicable legal acts, Bound by confidentiality obligations regarding personal data. The Data Processor confirms its clear understanding that the confidentiality obligations related to personal data shall remain in effect even after the termination of this Agreement and/or the Service Agreement.
4.4. At the request of the Data Controller, the Data Processor undertakes to cooperate and assist the Data Controller by providing information regarding the necessary technical and organizational measures aimed at protecting the rights of data subjects as provided by applicable legal acts, including but not limited to:
a) Providing the Data Controller with a copy of the personal data of data subjects in a secure format agreed upon by the Parties;
b) Correcting, restricting, or irreversibly deleting personal data as required.
4.5. At the request of the Data Controller and within the timeframe specified by the Data Controller, the Data Processor shall provide all necessary information, documents, and assistance required for the Data Controller to properly comply with all applicable data protection laws and to demonstrate such compliance.
4.6. If an authorized supervisory authority or any other party, including a data subject, requests the Data Processor to provide personal data processed under this Agreement and the Service Agreement, the Data Processor must immediately forward such a request to the Data Controller.
4.7. The Data Processor is not permitted to disclose personal data or any other information related to personal data processing without the prior written consent of the Data Controller, except in cases where the Data Processor is legally required to disclose such information under applicable laws or regulations. In such cases, the Data Processor must immediately notify the Data Controller, unless such notification would violate applicable legal provisions.

5. PERSONAL DATA SECURITY BREACHES

5.1. The Data Processor undertakes, upon the Data Controller’s request and within the timeframe specified by the Data Controller, to assist in fulfilling its obligations to ensure proper data processing and security. This includes, but is not limited to: Notifying of personal data security breaches, Conducting risk and impact assessments, Consulting with the supervisory authority, as required by applicable data protection laws. The Data Processor agrees that notifications of personal data security breaches shall be made through the Data Controller. Separate notifications by the Data Processor shall only be provided if required by law. All notifications must comply with the requirements of Articles 33 and 34 of the Regulation.

5.2. In the event of a personal data security breach occurring at the Data Processor, the Data Controller must immediately and, if possible, no later than 72 hours after becoming aware of the breach, notify the competent supervisory authority, unless the personal data breach does not pose a risk to the rights and freedoms of data subjects.
5.3. If a personal data security breach poses a significant risk to data subjects, the Data Controller must immediately notify both the competent supervisory authority and the affected data subjects about the breach. In the event of an actual or suspected personal data security breach, or if the Data Processor is subject to any supervisory authority proceedings related to the processing of personal data under the Data Processing Agreement and/or the Service Agreement, the Data Processor must immediately, and in any case no later than 24 hours after becoming aware of the incident, provide a written notification to the Data Controller, free of charge.
5.5. Upon receiving the Data Controller’s authorization, the Data Processor must immediately take action to eliminate the issue, prevent further damage, and mitigate the consequences of such an incident.
In its notification, the Data Processor shall provide the Data Controller with all necessary information required under data protection laws, enabling the Data Controller to properly fulfill its obligation to notify the supervisory authority and affected data subjects, as well as to remediate and minimize the impact of the data security breach. The notification shall include, but is not limited to, the following information:
a) A description of the nature of the personal data security breach, specifying the affected categories of data subjects, the number of data subjects impacted, and the categories and volume of processed data records involved.
b) The identity and contact details of the data protection officer or another designated contact person from whom further information about the incident can be obtained.
c) Recommended measures to mitigate potential negative consequences resulting from the personal data security breach.
d) A description of the likely consequences of the personal data security breach and the potential risks to data subjects.
e) A description of the measures proposed or implemented by the Data Processor and/or any sub-processor (if applicable) in response to the personal data security breach.
f) Any other relevant information reasonably necessary for the Data Controller to comply with data protection laws, including fulfilling its obligation to notify the supervisory authority.
5.6. If necessary and feasible, upon receiving instructions from the Data Controller, the Data Processor must, at its own expense, take the required corrective actions in relation to the affected data subjects.
5.7. The Data Processor is required to properly document all personal data security breaches occurring under this Agreement, including: The facts related to the breach, The consequences of the breach, and The corrective actions taken. Such documentation must enable the supervisory authority to verify compliance with data protection laws. Only the necessary information required for this purpose may be recorded.

6. LIABILITY

6.1. Each Party acting as a Data Controller is individually financially responsible for the processing of personal data. A Party shall not be liable for the data processing activities carried out by other Data Controllers.
6.2. The Data Controller shall be jointly liable for the Data Processor’s data processing only if the Data Processor acted (or failed to act) in accordance with the Data Controller’s instructions.
6.3. If the Data Processor acts contrary to the Data Controller’s instructions, the Data Processor shall be solely liable for any negative consequences arising from such personal data processing, including any sanctions imposed by supervisory authorities. Other liability rules shall apply only if they are explicitly mandated by law.
6.4. The Data Processor is liable for any damage caused to the Data Controller, the Data Controller’s clients, business partners, or third parties due to improper performance or violation of: The Data Processing Agreement, The Data Controller’s instructions, and/or applicable data protection laws. This liability extends to acts or omissions committed by the Data Processor, its employees, or any sub-processors engaged.
6.5. If a third party submits any claim or lawsuit against the Data Processor regarding the Data Processing Agreement, the provided services, or a violation of data protection laws, the Data Controller has the right to participate in negotiations and legal proceedings, either as an independent party or as a third party, to ensure the proper protection of its rights and legitimate interests.
6.6. The Data Processor must coordinate all legal actions with the Data Controller in every case.

7. DATA PROCESSING DURATION

7.1. This Agreement shall remain in effect as long as the Data Processor processes personal data on behalf of the Data Controller.
Upon termination or expiration of this Agreement, the Data Processor must cease all data processing activities. If requested by the Data Controller, and unless otherwise required by applicable data protection laws, the Data Processor must delete or return all personal data to the Data Controller, including the deletion of all copies of such data.
7.2. Upon termination or expiration of the Agreement, the Data Processor must cease all data processing activities. If requested by the Data Controller, and unless otherwise required by data protection laws, the Data Processor must delete or return all personal data to the Data Controller, along with deleting or returning all copies of such data.
7.3. Without the prior written consent of the Data Controller, the Data Processor undertakes not to disclose any personal data processed under this Agreement or otherwise allow access to it by any third party, except for persons authorized by law and sub-processors engaged in accordance with this Agreement.

8. OTHER TERMS

8.1. Any disputes arising from this Agreement shall be resolved through mutual negotiations between the Parties. If the Parties fail to reach an agreement, any disputes, disagreements, or claims arising from or related to this Agreement, including its breach, termination, or validity, that remain unresolved through negotiation shall be settled in a court of the Republic of Lithuania, based on the registered office of the Data Controller, unless otherwise required by applicable legal provisions.
8.2. In the event of any conflict between the terms of this Agreement and any other agreements concluded between the Parties, the provisions of this Agreement shall prevail.
8.3. This Agreement shall enter into force on the date of its signing and shall remain in effect until the earliest occurrence of one of the following: 1. The Service Agreement remains in force, or 2. The termination date specified in a separate notice from the Data Controller to the Data Processor regarding the termination of the Data Processing Agreement, which shall be no earlier than 30 (thirty) days from the date of the notice, or 3. The termination date specified in a separate notice from the Data Processor to the Data Controller regarding the termination of the Data Processing Agreement, which shall be no earlier than 30 (thirty) days from the date of the notice.
8.4. The Data Processing Agreement may also terminate with respect to specific personal data from the moment the Data Processor becomes an independent data controller for such personal data and notifies the Data Controller in writing.
8.5. The Data Processor’s confidentiality obligations shall remain in effect even after the termination of the Data Processing Agreement and/or the Service Agreement.
8.6. Any amendments or additions to the Data Processing Agreement shall only be valid if made in writing and signed by authorized representatives of both Parties.
8.7. The Parties confirm and guarantee that they have all necessary authorizations to enter into and execute the Data Processing Agreement.
8.8. This Agreement is executed in three copies, each having equal legal force, with one copy provided to each Party.

ELECTRONIC SERVICES PROVISION AGREEMENT No.

SPECIAL PART

1. PARTIES' DETAILS OF THE ELECTRONIC SERVICES AGREEMENT (hereinafter – the Agreement):
1.1. Service Provider (hereinafter – the Service Provider):
Ethos solutions, MB
Company Code: 306689726
VAT Code: LT100016734817
Address: Gėlių g. 4, Didžiulių k., LT-60295 Raseinių r.
Director: Andrius Šarkus
1.2. PARTNER (Name and Surname / Legal Form and Name) (hereinafter – the Partner):
PERSONAL / COMPANY CODE:
ADDRESS:
TELEPHONE, EMAIL:
DOCUMENT NUMBER AUTHORIZING ACTIVITY (IF REQUIRED):
1.3. USER (Name and Surname / Legal Form and Name) (hereinafter – the User):
PERSONAL / COMPANY CODE:
ADDRESS:
TELEPHONE, EMAIL:
1.4. The Service Provider, Partner, and User are collectively referred to as the "Parties to the Agreement."
2. PARTNER'S LOGIN DETAILS:
2.1. SYSTEM CODE:
2.2. PASSWORD:
The Parties to the Agreement confirm that they have familiarized themselves with the terms of the Agreement, as well as all other accompanying documents, and had the opportunity, by mutual agreement of the Parties, to influence the terms of the Agreement. The Client fully understands all the terms of the Agreement, agrees with them, and acknowledges that they reflect the
Client’s true intent.
3. SIGNATURES OF THE PARTIES TO THE AGREEMENT
Service Provider:
Ethos solutions, MB
Company Code: 306689726
Address: Gėlių g. 4, Didžiulių k., LT-60295 Raseinių r.
Phone No.:
Email:
PARTNER (NAME, SURNAME / LEGAL FORM AND NAME):
USER:

ELECTRONIC SERVICES PROVISION AGREEMENT No.

GENERAL PART

4. DEFINITIONS USED IN THE AGREEMENT
4.1. Platform – the website managed by the Service Provider under its own name, accessible at ethostherapy.co.uk, and intended for the provision of the Service Provider’s services.
4.2. User – refers to a client who has ordered a service through the Platform. In the Agreement, the term "User" may also be referred to as "Client."
4.3. Partner – a natural person engaged in individual activities, a legal entity, or another person without legal entity status who can acquire rights and obligations in their own name and conduct business using the Platform for professional or commercial activities.
4.4. Account – an individual section of the Platform assigned to a specific registered user, identified by an email address or phone number. The Account allows the user to edit personal and contact information and access the Platform’s features.
4.5. Profile – information about the Partner available to Platform Users, including descriptions of the work performed or services offered by the Partner.
4.6. Partner's Services – the range of work offered or services provided by the Partner, along with other relevant information.
4.7. Request – information uploaded by the User to the Platform, potentially using an automated chat modeling program, as well as information entered directly through the Platform, mobile application, integrated system (API), sent via email, and/or provided by phone when searching for a Partner to perform a Task.
4.8. Task – a specific job or service described in the User's Request and the Partner's Offer, which the User wishes to order.
4.9. Price – The Partner’s remuneration for the completion of the Work, which is visible to the User upon receiving the Offer. The price is determined in accordance with the applicable legal regulations in the country, market conditions, and the rates provided by the Partners.
4.10. Transaction Fee – The Service Provider’s remuneration for the provided services, which is paid by the Partner.
4.11. GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC.
4.12. Session – Defined as the relationship between the User and the Partner during which the Partner provides services to the User.
4.13. Completed Session – A session that was initiated with the participation of both the User and the Partner, or a session that the User canceled less than 24 hours before the scheduled session date, or one in which the User did not attend.
4.14. Subscription – The ordering of continuous services through the Platform. The subscription is valid for 1 (one) calendar month from the date of subscription order/purchase. The subscription is considered ordered from the moment of payment.
4.15. Other Terms – The terms used in the Agreement correspond to those used in the laws of the Republic of Lithuania and the Terms of Payment Services.
5. Subject and Purpose of the Agreement
5.1. The Agreement regulates the relationships between the Parties arising from the provision of services under the Agreement. The General Terms define the content of services provided by electronic means and regulate the rights and obligations of the Parties arising from the provision and use of the Platform's services.
5.2. Platform Operator – Ethos Solutions, MB, legal entity code: 306689726.
5.3. The Platform can be accessed at ethostherapy.co.uk. To use the Platform, a device connected to the internet with a compatible web browser is required.
5.4. The Service Provider, through the Platform operated under its name, provides intermediary services between the User and the Partner, who, using the Platform, enters into transactions with the User.
5.5. The Platform enables Users to enter into transactions with the Partner to purchase the Partner’s services and make payments by transferring funds to the Partner through the Service Provider’s account.
5.6. By this Agreement, the Partner authorizes the Service Provider, acting as an intermediary in the conclusion of contracts between the Partner and the User, to represent the Partner, i.e., to issue invoices (including credit invoices) on behalf of the Partner for the services provided to the User and to receive monetary payments from Users for these services.
6. Conditions for Using the Platform
6.1. The Service Provider provides services to Users and Partners based on these Platform Terms. The User and the Partner confirm that they agree with the Platform Terms and that they are clear and understandable.
6.2. Before using the services, the Partner must register on the Platform, provide the necessary information in the registration form, and upload the required documentation as specified on the Platform.
6.3. A request to provide Partner Services must be completed through the Platform. The Partner is required to fill in the profile registration information.
6.4. Upon completing the registration, an Account is created, which can be accessed using the User’s username and password.
6.5. Clicking the "Register" button signifies that the User agrees that:
6.5.1. He/she has the legal right, in accordance with legal provisions, to enter into an Agreement for the use of the Platform.
6.5.2. He/she has read and agrees that the services will be provided under the terms of the Agreement and its annexes.
6.5.3. Before entering into the Agreement, the Partner has provided the Service Provider with all the necessary documents specified in the information published on the Platform, required for the Service Provider to verify the Partner and confirm that they meet the requirements for providing the service, as established by law or the Service Provider itself. The Partner declares that all provided information is accurate and is responsible for fulfilling all conditions related to the provision of Consultations that will be offered during Sessions.
6.5.4. The Partner will use the Platform to offer consultations and their services to Users, manage their Profile, specify session dates, and, if applicable, other content.
6.5.5. The service provision agreement is concluded between the User and the Partner. Ordering services and entering into a Service Agreement does not create any contractual relationship between the Users and the Service Provider.
6.5.6. The Partner's account will be protected by a username and password. The Partner undertakes to maintain the confidentiality of the information required to access the account and agrees not to allow third parties to use the account. If it is determined that third parties are using the account, the Partner shall compensate the Service Provider and the Client for all direct and indirect damages and shall pay the Service Provider a penalty of €2,000.00 (two thousand euros).
6.5.7. The Profile shall contain the following information about the Partner (not limited to the listed items, but considering them as the basis):
6.5.7.1. Personal data (name, surname, education, and contact email);
6.5.7.2. Photograph that complies with standard ethical considerations;
6.5.7.3. Professional information (education, specialization, certifications, courses, diplomas, experience, and other information proving their competence).
6.5.7. The following information about the Partner is provided in the Profile (not limited to the listed items, but considering them as the basis):
6.5.7.1. Personal data (name, surname, education, and contact email);
6.5.7.2. A photo that meets standard ethical considerations;
6.5.7.3. Professional information (education, specialization, certifications, courses, diplomas, experience, and other information proving their competence).
6.6. Registration on the Platform is free; however, a Partner may have only one account.
6.7. By registering on the Platform, the Partner guarantees that they have the necessary experience and knowledge in their specified field of activity and will provide services according to the highest professional standards. Competence is verified by the Service Provider.
6.8. An account may be created by a legal entity, but only a person authorized to act on behalf of the legal entity may operate under its name.
6.9. The Partner is obligated to fulfill tax obligations arising from applicable laws due to the provision of Partner Services through the Platform. Upon request from tax authorities, the Service Provider must provide information about the Partner in accordance with the procedures established by law.
6.10. The Partner ensures that an account created on behalf of a legal entity is registered by an authorized representative with the right to act on behalf of the legal entity.
6.11. The Partner agrees and does not object that if it is suspected or proven that any of their behavior related to the Platform contradicts or does not comply with principles of good morality, applicable laws, or the rights and/or interests of the Service Provider, the Service Provider may, at any time and without providing any reason or justification, reject or block the account. The duration of the block may be indefinite and is determined at the discretion of the Service Provider, depending on the circumstances of the specific case. Upon request from the police or other competent authorities, the Service Provider has the right to disclose the Partner's data and any related information.
6.12. The Partner is aware that the Service Provider allows Users to submit reviews about the Partner on the Platform, which become available on the Partner’s Profile after being submitted by the User. Users can rate the Partner after the Partner has completed the Work. The available rating options include a star rating from 1 to 5 or "like" and "don't like" symbols. The review should reflect the quality of the work, the attractiveness of the offer, and the characteristics of the collaboration with the Partner. The Service Provider has the right to fully or partially remove a review if it violates the terms of the Agreement or applicable legal regulations.
6.13. All reviews that unjustifiably threaten the reputation of Partners/Clients or harm the Service Provider will be removed from the Platform.
6.14. The Client has the right to submit a complaint to the Service Provider regarding the Service no later than 7 days after the Completed Session.
6.15. Complaints are reviewed within 30 days from the date of receipt. During the complaint review process, no payments to the Partner will be made.
6.16. The Parties to the Agreement understand that the Service Provider only grants permission to use the Platform. This permission does not include the right to transfer the authorization to use the Platform to third parties or to transfer the rights and obligations of the User and Partner to other persons.
6.17. Copyrights and trademarks, including source code, databases, logos, and images, belong to the Service Provider. The User and the Partner do not acquire any intellectual property rights when using the Platform. Any copying or making the content available to others is prohibited unless otherwise specified in separate agreements. Violation of this clause results in a penalty of €2,000.00 payable to the Service Provider, along with compensation for all direct and indirect damages incurred by the Service Provider.
6.18. The following activities are prohibited when using the Platform:
6.18.1. Attempting to extract the software’s source code by decompiling, reverse engineering, or any other means;
6.18.2. Modifying the Platform in any way or form;
6.18.3. Using modified versions of the Platform;
6.18.4. Uploading files that are corrupted or infected with viruses or programs that may damage or negatively affect the operation of the Platform.
6.18.5. Concluding transactions while bypassing the Platform;
6.18.6. Unauthorized access to the Platform.
6.19. Violation of clause 6.18 by the User or Partner results in a penalty ranging from €2,000.00 to €5,000.00, depending on the nature and consequences of the violation, along with compensation for all direct and indirect damages incurred by the Service Provider.
7. Rights and Obligations of the Parties to the Agreement
7.1. The Service Provider:
7.1.1. Oversees the technical operation of the Platform, ensuring its accuracy and compliance with legal regulations.
7.1.2. Is not a party to the contracts concluded by Users and is not responsible for improper performance or non-performance of contracts when the contracting parties violate the terms of the Agreement.
7.1.3. Is not responsible for the accuracy and reliability of the data provided by the User and/or Partner, nor for the parties' ability to fulfill their contractual obligations.
7.1.4. Informs the User and the Partner about known technical failures of the Platform’s systems or devices that may affect service provision. In the event of technical failures of the Platform’s systems or devices, the Service Provider has no financial obligations, including compensation for losses, penalties, or any other contractual or statutory payments to the other Parties to the Agreement.
7.1.5. Has the right to remove or block content, communications, Profiles, and Accounts if they violate the terms of the Agreement, its annexes, or legal regulations.
7.1.6. Has the right to verify Account and Profile data when there are reasonable doubts regarding the security of the Account or the accuracy of the information provided by the User or Partner. If there are justified concerns about the security of the Profile or the authenticity of the User’s or Partner’s data, the Service Provider may suspend the account until the User or Partner provides reliable and unquestionable information regarding their identity or other relevant details.
7.1.7. Has the right to issue invoices (including credit invoices) to Users on behalf of the Partner for the services provided by the Partner.
7.1.8. Has the right to receive payments from Users for the services provided by the Partner.
7.1.9. Undertakes to transfer the funds received from Users to the Partner, deducting the Transaction Fee (12%) and any other amounts payable under the Agreement, no later than 8 days after the provided service/session.
7.1.10. Apply appropriate organizational and technical measures to protect the personal data provided by other parties to the Agreement from accidental or unlawful destruction, alteration, disclosure, or any other unlawful processing.
7.1.11. The Service Provider shall not be liable under any circumstances for:
• The quality of the Partners' work and the content of consultations;
• The information provided by the Partners about themselves;
• The improper selection of technical tools used during remotely provided sessions and the quality of the internet connection;
• Sessions that did not take place due to the User's fault if the User did not cancel the session at least 24 hours in advance;
• Sessions that did not take place due to the Partner's fault if the session was not canceled.
7.2. The Partner, in addition to all other rights and obligations set forth in the Agreement:
7.2.1. Shall promptly provide the Service Provider with accurate and correct information about the services provided, which is necessary for issuing invoices (including credit invoices) to Users on behalf of the Partner.
7.2.2. Shall pay the Service Provider the commission fee specified in the Agreement in accordance with the terms set forth therein.
7.2.3. Compensate for any damages incurred due to the Partner's fault or negligence.
7.2.4. The Partner confirms and undertakes to comply with all tax obligations specified in the applicable laws governing the provision of the Partner's services, including the obligation to pay corporate tax, income tax, social security contributions, mandatory health insurance contributions, reverse VAT taxation, and other taxes applicable to such activities, including corporate income and profit taxes.
Additionally, the Partner agrees to fulfill all registration obligations required by law for the entity providing the Partner’s services, including obtaining a VAT payer code if applicable.
If the tax authorities request information regarding the Partner’s activities, the Service Provider may provide such information to the tax authorities to the extent and in accordance with the applicable laws.
Additionally, the Partner is responsible for ensuring compliance with all applicable tax requirements related to the provision of the Partner’s services. The Partner agrees to compensate the Service Provider for any taxes, claims, payments, fines, or other tax obligations that the Service Provider may incur due to the Partner’s failure to comply with applicable tax obligations (including failure to pay income tax and social security contributions).
7.2.5. May cancel a service/session at any time before the start of the service/session.
7.2.6. A session is considered not held/completed due to the Partner's fault if the Partner joins it more than 20 minutes after the session's scheduled start time.
7.2.7. The Partner decides how many services/sessions to provide within a calendar month and sets their own service rates.
7.2.8. The Partner undertakes to notify about vacations or any other reasons that prevent them from fulfilling their obligations to Users and/or providing services on the Platform. The notification must be provided no later than 30 days before such an event and must also be reflected in the Platform’s calendar.
7.2.9. In cases of ongoing service/session demand (subscription-based services under the Agreement), the Partner undertakes to allocate a sufficient number of slots (available session time slots) per month for all existing subscribers. If there are no available slots, the Partner undertakes to freeze the subscription function (this can be done in the profile settings) and refrain from accepting new Users.
7.2.10. In cases of ongoing service/session demand (subscription-based services under the Agreement), the Partner undertakes to offer a lower service/session price than the standard rate.
7.2.11. The Partner shall provide sessions and consultation services personally, at an appropriate expert and professional level, and in compliance with all applicable laws, regulations, the Code of Conduct, as well as moral and ethical standards.
7.2.12. The Partner shall ensure, at their own expense, that all necessary technical equipment required for the proper and uninterrupted provision of services/sessions, including internet access, is available.
7.2.13. The Partner shall regularly update and verify their data (including billing details) and promptly notify the Service Provider of any changes or update the changed data in their Account. If the Partner fails to comply with this obligation, they shall be liable for all direct and indirect losses incurred by the Service Provider.
7.2.14. The Partner undertakes not to encourage the User in any way to enter into a service provision agreement or a similar agreement for consultation services directly with the Partner. If it is determined that such an agreement was made and/or the service was provided during the validity of this Agreement or within one year after its termination, the Partner agrees to pay the Service Provider a penalty of €5,000.00 (five thousand euros), which shall be considered a fair and undisputed loss of the Service Provider. The penalty shall be paid upon the Service Provider’s demand.
The payment of the contractual penalty does not eliminate the Service Provider’s right to claim full compensation for all incurred losses.
7.2.15. The Partner shall not offer their services on competing platforms under more favorable conditions (i.e., at a lower price or with other more favorable terms) than those offered on the Platform. If such a case is identified, the Partner agrees to pay the Service Provider a penalty of €2,000.00 (two thousand euros), which shall be considered a fair and undisputed loss of the Service Provider. The penalty shall be paid upon the Service Provider’s demand.
In such a case, the Agreement with the Partner shall be terminated. The payment of the contractual penalty does not eliminate the Service Provider’s right to claim full compensation for all incurred losses.
7.2.16. Information disclosed to the Partner during the service/session is considered confidential, and the Partner undertakes to ensure its confidentiality in accordance with applicable legal regulations. The Partner's obligation of confidentiality is particularly restricted in cases where, under the Criminal Code, they have a legal duty to report that a criminal offense has been or may have been committed.
7.2.17. The Partner agrees to be identified as a client by the Service Provider and consents to the Service Provider referencing the Partner in its marketing materials, including using the Partner’s name, trademark (if applicable), and providing a brief description of the Partner’s business.
7.3. The User, in addition to all other rights and obligations set forth in the Agreement:
7.3.1. Shall use the Platform in accordance with applicable legal regulations.
7.3.2. Shall ensure the security of the mobile devices used to access the Platform, preventing third parties from knowing the login credentials, passwords, or other identification data, except for individuals authorized by the User to act on their behalf.
7.3.3. Shall report any legal violations related to the use of the Platform.
7.3.4. Shall not use the Platform’s services for illegal purposes, including obtaining funds through criminal activities or other unlawful means, or violating the rights and legitimate interests of third parties.
7.3.5. The User may cancel a service/session up to 24 hours before the scheduled start time without providing a reason. In this case, the full payment for the service/session shall be refunded no later than 14 days after cancellation. If the service/session is not canceled but is marked as Completed, the User is not entitled to a refund.
7.3.6. The User may reschedule a session no later than 24 hours before the scheduled start time. The User is allowed one opportunity to change the time of a purchased service/session.
7.3.7. If a service/session is canceled by the Partner, the User shall receive a refund within 14 days.
7.3.8. The User acknowledges that sessions may be provided as part of a monthly subscription (Subscription). As part of the subscription, the User can set a schedule in their account based on the number of selected sessions with their assigned therapist. The subscription is always paid in advance for each subsequent calendar month.
7.3.9. The User understands that the Subscription may be canceled at any time in the Account Settings, effective from the next calendar month for which the Subscription has not yet been paid.
7.3.10. By ordering a service/session—i.e., submitting an order and making payment for the service/session—the User enters into a contract with the Partner. The terms of this contract are specified in the service/session order and in the Agreement.
7.4. The User and the Partner understand and explicitly agree that:
7.4.1. They use the Platform at their own risk. The Platform is available to the Subscriber “as is” and “as available.”
7.4.2. The Service Provider's company, its parent company, subsidiaries, branches, officers, directors, shareholders, employees, agents, attorneys, partners, licensors, and other representatives (collectively referred to as Related Parties) do not provide any guarantees that: The quality of the Platform and any services, information, or other data accessible through it will meet the expectations and requirements of the User or Partner; Access to the Platform will be uninterrupted, timely, secure, or free from errors, critical or non-critical incidents; The results obtained from using the Platform will be accurate and reliable; The Platform and any content accessible through it will be free of viruses or other malicious components.

7.5. To the maximum extent permitted by applicable law, the Service Provider shall not be liable for: Any direct or indirect losses/damages of the User or Partner related to data loss; The use of or inability to use the Platform; The cost of acquiring substitute services, data, or other information that should be, but is not, available through the Platform; Any actions or behavior of third parties on the Platform; Improper storage, transfer, synchronization, or configuration of Subscriber Account settings; Any data lost or rendered unrecoverable due to mismanagement by the Subscriber and/or Users; Unauthorized access, modification, corruption, deletion, or improper storage of data; Any changes to the Platform's usage terms, including but not limited to: Changes in the Subscription plan (e.g., upgrading or downgrading the plan); Changes in payment amounts, and other modifications.

7.6. Notwithstanding the provisions of Section 7.5, the maximum liability of the Service Provider towards the User and Partner (if applicable), regardless of the form of liability, shall in all cases be limited to an amount equal to the total fees actually paid by the User and/or Partner to the Service Provider in the six (6) months preceding the actions giving rise to the Service Provider's liability.
If, after the termination of this Agreement, a claim is made against the Service Provider for any compensation due to the termination of the Agreement, the compensation amount shall be determined in accordance with the applicable laws. The compensation shall be payable only if it is established that the individual benefited from business relationships with Clients through the Platform or that the Partner’s business significantly expanded due to the use of the Platform.
7.7. If either Party fails to exercise any of its rights or exercises such a right only partially, this shall not be construed as a waiver of that right.
If any provision of this Agreement is deemed invalid by a court decision, this shall not affect the validity of the remaining provisions, which shall remain in full force and effect.
7.8. The Account is non-transferable, and all rights to the Account and Data terminate upon the death of the User or Partner. Upon receipt of a copy of the death certificate, the Account shall be deleted, and all Data shall be erased.
7.9. Neither Party has the right to assign or otherwise transfer this Agreement, or any rights and/or obligations arising from it, to third parties without the prior consent of the other Party.
8. Price, Payment Procedure, and Terms
8.1. The price of the services provided by the selected Partner is specified on the Portal.
8.2. By registering for an appointment with a Partner in the electronic calendar available on the Portal, the User agrees to the price of the services provided by the selected Partner.
8.3. The User undertakes to pay for the selected Partner's services directly to the designated Service Provider’s account linked to the Portal or to the Service Provider’s account using other electronic payment methods immediately after registration in the electronic calendar available on the Portal.
The Partner authorizes the Service Provider to act as an agent in receiving payments from Clients, including any amounts or fees payable by the Client to the Partner.
8.4. The payment is considered completed when the payment amount is credited to the Service Provider's account.
8.5. An invoice is automatically generated and sent to the User's specified email address immediately after the payment is received.
8.6. If the User cancels an appointment with the Partner no later than 24 hours before the scheduled time, the amount paid by the User will be refunded to their account within 14 days.
8.7. The transaction fee is 12% of the service price.
8.8. The service price, after deducting the transaction fee, is paid to the Partner once the User's complaint submission period has expired, which is 7 days after the Completed Session, but no later than 14 days.
If the User has submitted a complaint regarding the Partner’s service, the service price will not be paid until the dispute is fully resolved.
8.9. The service price is not paid to the Partner in other cases specified in the Agreement (such as contractual violations).
8.10. In the case of a Subscription, the User’s subscription fee depends on the chosen subscription plan. The Partner acknowledges that in the case of a Subscription, the service price must be lower than in a one-time purchase.
8.11. If during the Subscription period the User upgrades their Subscription plan to a higher-tier plan, the increased (new/additional) Subscription fee takes effect immediately, and the price difference is allocated on a pro-rata basis for the remainder of the current Subscription period. If the Subscription plan is downgraded to a lower-tier plan, the Subscription fee adjustment will take effect only after the current Subscription period ends. A confirmation of the Subscription payment will be sent to the email address specified in the User's account.

8.12. The Service Provider reserves the right to modify payment terms, including the right to: Change all fees applicable to the User and Partner; Introduce new charges; Impose fees on previously free Platform features. Such changes shall take effect 14 days after notifying the parties to the Agreement, provided that such notification is required by the laws of the country where the Platform operates.
9. Personal Data and Processing
9.1. The User and Partner confirm that they have been informed that:
9.1.1. The Service Provider is the data controller for personal data processed on the Platform.
9.1.2. Based on the conclusion and execution of the electronic service agreement, as well as for the purposes of contract enforcement, protection and defense of the Service Provider’s rights and legitimate interests, identity verification, accuracy verification of personal data, compliance with regulatory risk management requirements, daily operations, debt management, and ensuring remote service provision, the Service Provider will collect and process the following personal data: Name; Surname; Possibly, but not necessarily, personal identification number; Possibly, but not necessarily, data from an identity verification document; Residential address; Phone number; IP address; Employer, engagement in business or individual economic activity; Bank account and/or payment card numbers; Any other information related to the listed data.
9.2. Upon verifying their identity with the Service Provider and submitting an appropriate request, the User and/or Partner have the following rights:
9.2.1. The right to obtain information on: The sources from which their personal data was collected; What personal data has been collected; The purpose of data processing; The recipients to whom the data has been disclosed in the past one (1) year; The right to data portability.
9.2.2. The right to request the correction of incorrect, incomplete, or inaccurate personal data and/or to suspend the processing of such data (except for storage) if, after reviewing their personal data, the User or Partner determines that their data is incorrect, incomplete, or inaccurate.
If, after reviewing their personal data, the User or Partner determines that their data is being processed illegally or unfairly, they have the right to submit a written request to the Service Provider to immediately delete the unlawfully or unfairly collected personal data or to suspend its processing (except for storage).
9.2.3. The right to object to the processing of their data for direct marketing purposes.
9.2.4. The right to object, by submitting legally justified objections, to the processing of their data based on the legitimate interest pursued by the Service Provider or a third party to whom the personal data is provided.
9.2.5. The right to request human intervention in the review of a contract decision if the contract was concluded automatically.
9.2.6. If their rights are violated, the Client may contact the responsible person designated by the Service Provider, whose contact details are provided on the Service Provider’s website, or submit a complaint to the State Data Protection Inspectorate or a court.
9.3. The Service Provider confirms that any information about the User and Partner related to this Agreement is considered confidential.
9.4. The User's and Partner's personal data will be stored until the end of the contractual relationship and for a longer period if required by applicable laws. If the Agreement is terminated earlier than the scheduled term, personal data will be retained in compliance with legal requirements, but for no longer than 10 years.
9.5. INTELLECTUAL PROPERTY: All rights (including copyrights, intellectual property rights, and industrial property rights) to the intellectual property accessible on the Website, Platform, and Content belong to the Service Provider.
9.6. During the term of the Agreement, the Service Provider grants the Partner and/or User the right to use the Platform.
9.5. INTELLECTUAL PROPERTY: All rights (including copyrights, intellectual property rights, and industrial property rights) to the intellectual property accessible on the Website, Platform, and Content belong to the Service Provider.
9.6. During the term of the Agreement, the Service Provider grants the Partner and/or User the right to use the Platform.
10. Termination of the Agreement
10.1. The Agreement comes into effect once the User and Partner have read and agreed to the terms by registering on the Platform and successfully completing the registration process. The Agreement is valid for one (1) year. If the Agreement is not terminated after one year, it is automatically extended for an additional one (1) year.
10.2. The User and Partner may terminate the Agreement by notifying the Service Provider at least 30 calendar days in advance.
10.3. The Service Provider has the right to terminate the Agreement by notifying the User or Partner via email and/or through their Account at least 30 calendar days in advance.
Account suspension may be implemented immediately if the Service Provider suspects any violation of the Agreement and/or applicable laws. Account suspension for up to 30 calendar days is not considered termination of the Agreement.
10.4. The Service Provider has the right to terminate the Agreement without prior notice if:
10.4.1. The User or Partner has provided false or incomplete information, refused to provide or update information necessary for the proper use of the Platform and/or Account.
10.4.2. The Service Provider has reasonable information raising doubts about the User’s and/or Partner’s reliability, or if the User’s and/or Partner’s activities can be classified as fraud, abuse, or causing harm to third parties.
10.4.3. The User’s and/or Partner’s activity on the Platform violates the Agreement terms or in any way harms or may harm the Service Provider’s legal, business, financial interests, or reputation.
10.4.4. The User and Partner must settle all payments for the Service Provider’s services before the termination of the Agreement. The User’s or Partner’s notice of termination shall be considered invalid until all outstanding debts to the Service Provider have been fully paid.
10.4.5. A User who has entered into an Agreement for the provision of services by electronic means may, without providing a reason, submit a request (electronically or in writing) to terminate the Agreement within 14 days from the date of its conclusion.
10.4.6. If it is determined that the User and/or Partner is engaged in activities prohibited by law or the Agreement, harms the legitimate interests of the Service Provider, or damages the reputation of the Service Provider, the Service Provider may take all legally permissible actions and restrict access to the Platform and website.
10.5. The User and Partner shall be informed of any changes to the Agreement terms via email no later than 15 days before they take effect.
It is considered that the User and/or Partner agrees to the changes if they continue using the Platform after the changes take effect.
10.6. The Service Provider may amend the Agreement terms without adhering to the 15-day notice period specified in Section 10.5 in the following cases: If subject to a mandatory legal requirement that necessitates partial modification of the Agreement terms; If minor changes are made, such as stylistic or grammatical corrections, sentence rewording, section restructuring for clarity, or the inclusion of examples, provided that such changes do not reduce or restrict the User’s and/or Partner’s rights, do not increase their liabilities, or do not worsen their position; In exceptional cases where changes to the Agreement terms are necessary to ensure User and/or Partner protection from fraud, malware, spam, data breaches, or other security threats.
11. Final Provisions
11.1. If the address or any other details of the parties to the Agreement specified in the Agreement change, the party must immediately notify the Service Provider.
Failure to comply with this requirement means that the User and/or Partner cannot raise claims or objections that the Service Provider's actions, carried out based on the last known details, do not comply with the Agreement or that they did not receive notifications sent to those details.
11.2. All notifications and any other information exchanged between the parties must be in simple written form, except in cases where Lithuanian law, this Agreement, or other documents submitted to the Service Provider (such as applications, forms, etc.) specify that notifications may be delivered orally or must be in notarized form.
Documents transmitted via telecommunication or electronic communication means (such as fax, internet, etc.) are considered equivalent to written documents.
11.3. Disputes arising from the implementation of the Agreement shall be resolved through negotiations. If the dispute cannot be resolved amicably, it shall be settled by the Kaunas District Court, Kaunas Division, in the Republic of Lithuania.
11.4. In matters not specified in the General Terms, the legal norms established in the Civil Code of the Republic of Lithuania and other applicable laws shall apply.

Partner and Client Service Agreement

ANNEX NO. 2 TO THE GENERAL TERMS AND CONDITIONS FOR THE PROVISION OF ELECTRONIC SERVICES

1. Details of the Parties to the Data Processing Agreement (hereinafter – the Agreement):
1.1. USER (name and surname / legal form and name) (hereinafter – the User):
PERSONAL / COMPANY CODE:
ADDRESS:
TELEPHONE, EMAIL:
1.2. PARTNER (name and surname / legal form and name) (hereinafter – the Partner):
PERSONAL / COMPANY CODE:
ADDRESS:
TELEPHONE, EMAIL:
LICENSE / PERMIT NUMBER (IF REQUIRED):
I. SUBJECT OF THE AGREEMENT
1. This agreement is considered concluded when the Client completes the registration process, which includes a reference to this agreement. By performing the actions specified in the registration center, the Client enters into this agreement by clicking the appropriate link, such as “Register,” etc. When registering online, all information provided must be complete and accurate. Ethos Solutions (the Platform Operator) may require the authorized representative signing the agreement on behalf of the Client to present appropriate evidence confirming their authority to represent the Client. The Service Provider reserves the right to refuse registration, cancel, or delete a registration if it is misused or if false information is provided.
2. The definitions specified in the General Terms of the Platform Agreement apply to this agreement.
3. The Partner undertakes to perform the Work according to the accepted Request received through the Platform.
4. The Client and the Partner are connected through the Platform.
II. WORK EXECUTION DEADLINES
1. The Partner undertakes to complete the Work no later than the deadline specified on the Platform.
2. The work completion deadline may be extended if both parties agree and confirm the agreement in writing or by electronic means, including through the Platform.
III. AGREEMENTS
1. The Partner's remuneration for the completion of the Work is specified through the Platform.
2. Upon completion of the Work, payment documents with the final Price are provided to the Client.
3. The Client shall pay for the completed Work within the payment deadline specified in the invoice.
4. The Client agrees to receive invoices, invoice duplicates, and/or their corrections through the Platform or at the email address specified in the Account.
5. The Client agrees to receive invoices in paper form if technical or other obstacles prevent their electronic delivery.
6. If the Partner fails to provide a payment document through the Platform for the completed Work, the Client has the right to withhold payment to the Partner until a proper VAT invoice or invoice is submitted. The parties agree that this shall not be considered a payment delay.
7. The Client shall make payments for the Work directly to Ethos Solutions through the payment application on the Platform or via bank transfer to Ethos Solutions’ designated bank account. The Partner authorizes Ethos Solutions, as an agent, to receive amounts payable by the Client or any other fees paid by the Client to the Partner. Any payment obligations shall be considered fulfilled at the moment the payment is credited to the Ethos Solutions account.
8. It is clear to both the Partner and the Client that all intellectual property belonging to the Service Provider (the Platform Operator) prior to the conclusion of this agreement remains the exclusive property of the Service Provider (the Platform Operator). Any intellectual property that arises, is acquired, or is created as a result of this agreement and the provision of services after the agreement is concluded shall belong to the Service Provider (the Platform Operator).

Obligations Under the Data Protection Law:

9. Provision of Personal Data
(a) The Client provides personal and non-personal data necessary for the provision of services. Such data primarily includes personal data specified in the privacy notice.
(b) Data may be provided directly by the Client or by data subjects at the Client’s initiative.
(c) The Client ensures that no more personal data than absolutely necessary is provided (principle of data minimization).
10. Informing Data Subjects
(a) The Client shall provide all data subjects whose personal data is transferred to the service provider with comprehensive and accurate information regarding the processing of their personal data for the purposes of this agreement, in accordance with Articles 13 and 14 of the GDPR. This information must be provided in a concise, clear, understandable, and easily accessible format, using plain and simple language.
(b) The Client is informed of their rights under Chapter III of the GDPR. These rights primarily include the right to access data, the right to rectification, the right to restrict processing, and the right to object.
11. Lawful Processing
(a) The Partner shall ensure that the use of any personal data related to, contained in, or obtained from the services complies with all applicable data protection laws. This primarily includes compliance with any legal requirements related to the control of the activities and/or behavior of individuals using the services on behalf of the Client, including, but not limited to, any specific rules regarding the processing of employees' personal data in the context of employment.
(b) The Platform Operator shall ensure that any of its entities located outside the European Economic Area enter into standard contractual clauses with the Client and the Partner or confirm compliance with other appropriate safeguards permitted under applicable data protection laws, except in cases where the entity is located in a country that, according to a decision by the European Commission, ensures an adequate level of personal data protection.
(c) If the Client becomes aware of any data security breach related to the services, the Client shall promptly and appropriately inform the Service Provider (Platform Operator) about such a breach. If applicable laws require notification of any personal data security breach to data subjects or supervisory authorities and it concerns the Client’s data, the parties shall coordinate this notification together.
(d) If the Client uses their own servers for data export through the interfaces provided by the Service Provider (Platform Operator), the Client is responsible for ensuring the security of the server. This includes all measures necessary to maintain the integrity, confidentiality, and availability of information and information systems, which are standard for such services. Examples of such measures include access control, patch management, system hardening, and data transmission encryption.
(e) The Client guarantees that the Service Provider, local subsidiaries, and service partners may lawfully process any personal data provided directly by the Client or by data subjects at the Client’s initiative for the purposes of this agreement.
(f) The Client is familiar with the laws and regulations of the relevant jurisdiction concerning data protection and the use or processing of personal data related to the services provided under this agreement.

IV. PARTNER'S OBLIGATIONS

The Partner undertakes to:
(a) Perform the work diligently, considering business professionalism and in compliance with applicable legal regulations.
(b) Comply with regulations governing occupational safety, fire protection, workplace hygiene, environmental protection, and the protection of employees from occupational hazards, as well as the provisions of the main Agreement.
(c) Compensate for any damages and/or losses incurred by the Client, provided that such damages are proven in accordance with the terms of the main Agreement and applicable legal regulations.
(d) Perform the Work according to the scope approved by the Client. The Client may modify the scope of Work if both parties agree.
(e) Notify the Client of any circumstances that may jeopardize the quality of the completed Work or other circumstances beyond the Partner's control.
(f) Hold valid certificates, permits, and qualification documents that grant the right to perform the Work. The Partner must have these documents at the Work site. If property owners, their representatives, or competent authorities request these documents, the Partner must provide them.
(g) It is recommended that the Partner have liability insurance for the services provided through the Platform. All other obligations of the Partner are outlined in the main electronic service provision Agreement.

V. CLIENT'S OBLIGATIONS

1. The Client is granted access to the Platform using their access credentials. The Client agrees to ensure the confidentiality of access credentials and prevent any unauthorized access to the account. The Client undertakes to regularly change the password if such a requirement is specified by the Platform Operator.
2. The Client understands that if the Platform usage guidelines are violated, the Platform Operator reserves the right to block the Client's access to the Platform and remove or block the Client's data that violates the terms of this agreement, without any control from the Partner. In such cases, the Service Provider (Platform Operator) will inform the Client in writing or via email about the access blockage and the blocking or removal of their data.
3. The Service Provider (Platform Operator) grants the Client the right to access and use the Platform strictly for the purposes of this agreement and for its duration. The Service Provider may periodically implement new versions, updates, and improvements to the Platform. In such cases, the previous sentence applies accordingly.
4. The Client is not entitled to grant third parties access to the Platform, either for a fee or free of charge.
5. The Service Provider (Platform Operator) and the Partner do not grant the Client any licenses and/or intellectual property rights (existing and/or future).
6. For any data protection breach caused by the Client’s failure to comply with their obligations under this agreement, the Client shall compensate the Service Provider (Platform Operator) for any resulting damages.
The Client undertakes to:
(a) Cooperate with the Partner as necessary for the completion of the Work;
(b) Settle payment with the Partner for the Work.
(c) Inform the Partner, within the legally prescribed period, about any identified deficiencies or circumstances affecting the implementation of the Agreement. In such cases, the Client must send a notification to the Partner’s email address provided through the Platform or use the designated functionality of the Platform.
All other Client obligations are outlined in the main electronic service provision Agreement.
VI. Liability
1. The Partner is liable for damages—regardless of the legal basis—in cases of intent and gross negligence. In cases of slight negligence, the Partner is only liable for damages resulting from a material contractual obligation breach (i.e., obligations that must be fulfilled to properly execute the contract and on which the Client is entitled to rely consistently). In such cases, the Service Provider's liability is limited to compensation for reasonably foreseeable and typically occurring damages.
This limitation of liability does not apply to damages resulting from loss of life, bodily injury, or harm to health.
2. The Client understands that the Service Provider (Platform Operator) has neither created nor verified the data transmitted through the Platform. For this reason, the Service Provider is not responsible for such data, its legality, completeness, accuracy, or relevance. Additionally, the Service Provider (Data Controller) is not liable for ensuring that such data is free from third-party intellectual property rights.
The Service Provider (Platform Operator) is not liable for any damage resulting from the download or use of unverified harmful data through the Platform.
3. To the extent that the Service Provider’s (Platform Operator’s) liability for damages is excluded or limited, the same exclusion or limitation applies to the personal liability of its representatives, employees, and other indirect agents.
4. Both parties, the Client and the Partner, are responsible for ensuring that they, as well as their representatives, employees, or agents who fulfill obligations under this agreement or use the Platform and services, comply with all applicable laws, regulations, ordinances, rules, and standards.

VII. TERM, AMENDMENTS, AND TERMINATION OF THE AGREEMENT

The agreement may be amended, supplemented, or terminated in written form unless a specific form is required by law.

VIII. OTHER CONDITIONS

1. All disputes and disagreements shall be resolved through negotiations. If disputes and disagreements cannot be resolved through negotiations, they shall be settled in accordance with the procedure established by law.
2. The parties to the agreement shall not be held liable for failure to fulfill or improper fulfillment of contractual obligations if such failure or improper fulfillment occurred due to force majeure circumstances.
3. Each party has the right to terminate this agreement if force majeure circumstances persist for more than one month from the date of receipt of the notification regarding their occurrence.

PRIVACY POLICY
1. What does Privacy Policy mean?
This Privacy Policy (hereinafter referred to as the "Privacy Policy") provides you with information on how MB Ethos Solutions (hereinafter referred to as the "Company") processes your personal data obtained through the following means:
(i) in the course of executing the Company's contracts;
(ii) when you engage in active interactions on the Company's social media accounts;
(iii) in the context of the Company's direct marketing activities;
(iv) when participating in the Company's recruitment processes;
(v) to ensure the protection of confidential information and business continuity;
(vi) from shareholders (natural persons) and members of management bodies;
(vii) to fulfill contracts concluded between the Company and counterparties – legal entities;
(viii) to ensure the protection of property and individuals.
All the aforementioned individuals whose data is processed by the Company are hereinafter referred to as "Data Subjects."
The Privacy Policy also establishes certain obligations for Data Subjects that must be adhered to when visiting the website Ethostherapy.co.uk (hereinafter referred to as the "Website").
2. About the Company
MB Ethos Solutions, legal entity code 306689726, with its registered office at Gėlių g. 4, Didžiulių k., LT-60295 Raseinių r., is a company whose data is collected and stored in the Register of Legal Entities of the Republic of Lithuania.
The contact email of the Data Protection Officer is info@teisesprincipas.lt.
The entity responsible for information protection is MB Ethos Solutions, legal entity code 306689726, with its registered office at Gėlių g. 4, Didžiulių k., LT-60295 Raseinių r.
3. What is Personal Data?
3.1. Personal data refers to any information collected by the Company about a Data Subject that can be used to identify the Data Subject and is stored electronically or by other means.
3.2. Personal data includes any information, such as the Data Subject's name, surname, address, and other details collected by the Company for the purposes specified in this Privacy Policy or in a separate Data Subject’s consent or agreement with the Company.
4. Execution of Contracts
Purpose of Data Processing
Processed Personal Data
Legal Basis for Data Processing
Data Retention Period
Contract conclusion
Name, surname, phone number, date of birth, personal identification number, address, gender, email, health information, identity-confirming document.
Performance of a contract
5 years. If services are purchased – 10 years. Identity-confirming data is stored until the purchased gym membership expires, after which it is immediately destroyed.
Contract execution
Name, surname, phone number, date of birth, personal identification number, address, gender, email, information about physical fitness, health, identity-confirming document.
Performance of a contract
5 years. If services are purchased – 10 years. Identity-confirming data is stored until the purchased gym membership expires, after which it is immediately destroyed.
4.1.
The above-mentioned data is necessary for the proper execution of the contract. If such data is not provided, the Company will not be able to fulfill the contract properly, except for the fingerprint model and photograph.
Therefore, the Company collects sensitive information: with your consent (pursuant to Article 9(2)(a) of the GDPR), we may process your health data.
Please note that all your personal and health data is deleted after the date of subscription suspension/termination is recorded in the system.
4.2.
The Company collects information lawfully, as it is necessary for the following purposes:
• To conclude and execute service contracts, including registration and account administration (Article 6(1)(b) of the GDPR);
• For the processing of health data, based on consent (Article 9(2)(a) of the GDPR);
• For identification purposes, in order to fulfill the concluded service contract (Article 6(1)(b) of the GDPR);
• For sending informational notifications, based on the performance of the concluded service contract (Article 6(1)(b) of the GDPR);
• For contract suspension due to unpaid services, in accordance with the concluded service contract (Article 6(1)(b) of the GDPR);
• For sending direct marketing messages, based on consent (Article 6(1)(a) of the GDPR);
• For compliance with legal obligations in the areas of accounting, taxation, and document archiving (Article 6(1)(c) of the GDPR);
• To protect the Company’s legitimate interests in defending its rights in courts, pre-litigation dispute resolution institutions, and similar bodies, as well as providing information to insurance companies in cases of damage (Article 6(1)(f) of the GDPR).
4.3. Your information may be shared with:
• State and local government institutions (e.g., the State Tax Inspectorate and similar bodies) in cases and to the extent prescribed by law;
• The Company’s service providers, including debt collection agencies, IT system providers, IT service providers, communication service providers (e.g., email services), and data storage service providers, who assume confidentiality and security obligations in accordance with personal data protection laws;
• Insurance companies;
• Legal service providers and law firms, to the extent necessary for obtaining legal assistance or defending legitimate interests;
• Courts, pre-litigation dispute resolution institutions, and other competent authorities, to the extent necessary for the defense of our legitimate interests;
• Bailiffs, to the extent necessary for the enforcement of court and pre-litigation dispute resolution decisions.
4.4.
To ensure the legitimate interest of executing contracts concluded between the Company and its corporate counterparties, the Company processes the personal data of these counterparties' employees, including name, surname, email address, phone number, and correspondence content. These data are retained for four (4) years.
4.5.
If you are a service provider and will be providing services to the Company, we will process contractual data.
4.6.
When processing the personal data of the Company’s service provider or supplier employees, the legal basis for such data processing is the Company’s legitimate interest.
4.7.
If you provide services as a natural person, the Company will process your data on the basis of contract performance. The personal data specified in this section will be processed for the duration of the contract. If personal data is included in contracts, it will be retained for 10 years from the date of contract termination.
5. Participation in Recruitment Processes
5.1. We collect and process your curriculum vitae (CV), cover letter, and/or other information you provide, including:
• Name, surname, date of birth, address, email, phone number;
• Information about salary (monthly salary/hourly wage);
• Information about payment terms and schedules;
• Work hours, other conditions, and commitments.
This data is processed based on your consent, which you express by sending your CV either directly to us or through an employment service provider.
5.2. We collect information about you lawfully because:
• The information is necessary to evaluate your candidacy for a position in our company (Article 6(1)(b) of the GDPR);
• We have a legitimate interest in contacting your previous employers to obtain more information about your professional and work-related qualities (Article 6(1)(f) of the GDPR);
• We rely on your consent to obtain information about your professional and work-related qualities from your current employer (Article 6(1)(a) of the GDPR);
• We have a legal obligation to retain received inquiries, requests, and complaints (Article 6(1)(c) of the GDPR).
5.3.
If you do not submit your curriculum vitae (CV) and/or cover letter, we will not be able to assess your suitability for the offered position.
5.4.
If you do not provide separate consent for the processing of your personal data after the conclusion of this recruitment process, we commit to deleting and/or destroying your personal data within five (5) business days after an employment contract is signed with the selected candidate.
5.5.
The Company states that it does not collect sensitive information about you. However, if you voluntarily provide us with sensitive information during the recruitment process, we will consider this as your consent to process such personal data (Article 9(2)(a) of the GDPR).
6. Protection of the Company’s Confidential Information and Business Continuity
6.1.
To ensure its legitimate interest in protecting the Company's confidential information and ensuring business continuity, the Company may review its employees' correspondence with counterparties.
For these purposes, the Company processes the following data:
• Email address
• Name and surname
• Content of information stored in electronic work tools
• Content of email correspondence
• Employee's online activity records
Such data is retained for four (4) years.
7. Protection of Property and Individuals
7.1.
To ensure the safety of Data Subjects, visitors, and employees, as well as to protect the property of Data Subjects, visitors, employees, and the Company, video surveillance is conducted. The following data is processed:
• General visual recordings within the surveillance area
• Location and movement of individuals within camera surveillance zones
• Possessed property
• Behavioral patterns and other relevant information (date, time)
These data are processed for 14 (fourteen) days from the date of collection, based on the Company’s legitimate interest.
7.2.
To protect the safety of Clients, visitors, and employees, as well as to safeguard the property of Clients, visitors, employees, and the Company, and to record and preserve evidence of incidents (such as property damage, theft, unlawful actions, injuries, accidents, etc.), the Company processes video recordings and their recording date.
These data are processed for 14 (fourteen) days from the date of collection, based on the Company’s legitimate interest.
8. Processing of Shareholders' (Natural Persons) and Management Body Members' Data
8.1.
In compliance with legal obligations, the Company processes the following data of shareholders (natural persons) and members of management bodies:
• Names and surnames
• Personal identification numbers
• Residential addresses
• Appointment dates
The Company's operational data is retained for 10 years.
9. Direct Marketing
9.1.
For individuals who have provided their contact details and expressed a desire to receive information about the Company's offered goods and/or services, we will send marketing communications via electronic means (email, phone, SMS messages), including:
• Offers regarding the sale of the Company's goods or provision of services,
• Newsletters and other promotional materials,
• Requests for feedback on provided services,
• Notifications about Company updates.
9.2.
For the purpose of direct marketing, the Company will process the following personal data:
• Phone number,
• Email address (mandatory data, without which we will be unable to send direct marketing messages).
9.3.
Your data will be used for direct marketing purposes for three (3) years after consent is obtained.
9.4.
If you are our Client and have not objected to receiving direct marketing messages from the Company by notifying us at the email provided below, we will send marketing messages via email about goods or services similar to those you have purchased or used, based on our legitimate interest.
9.5.
For Clients who have provided consent, we may offer personalized offers based on an analysis of their data, including:
• Name, surname, phone number, email address, residential address,
• Frequency of visits,
• Selected membership type.
Personal data for this purpose will be processed for one (1) year after obtaining consent.
9.6.
You have the right to opt out of receiving direct marketing messages at any time by contacting us via email.
10. Social Media and Website
10.1.
You may register and create an account on the Website only if you are 18 years old or older. All information you provide to the Company when becoming a registered Client will be collected and stored based on your consent, in accordance with the terms of this Privacy Policy.
If, in our reasonable opinion, you violate any provision of our Privacy Policy, we reserve the right to block your account at any time.
If you know or suspect that a third party has gained access to your username or password, you must notify us as soon as possible via email.
10.2.
All information you provide to us via social media platforms (including messages, the use of "Like" and "Follow" buttons, and other communications) is controlled by the social network operator.
10.3.
Our Website contains links to our social media accounts.
10.4.
We recommend reading the privacy notices of third parties and directly contacting service providers if you have any questions about how they process your personal data.
10.5. Cookies
The Company provides public access to the Website, maintains it, and continuously improves it. For these reasons, the Company uses cookies.
A cookie is a small file consisting of letters and numbers that, with your consent, we store in your browser or on your computer’s hard drive.
We use different types of cookies for various purposes. On the Website, we collect only anonymous data obtained from cookies, including your browsing trends on our Website and demographic data.
10.6. We collect information about you lawfully because:
• We have a legitimate interest in using cookies necessary for the proper functioning of the Website and its features (Article 6(1)(f) of the GDPR);
• For the use of analytical and advertising cookies, we rely on your consent (Article 6(1)(a) of the GDPR).
10.7. Types of Cookies
• Strictly Necessary Cookies – These cookies are essential for the proper functioning of the Website. The legal basis for processing data through these cookies is the proper performance of the contract when the Client visits the Website, ensuring quality and security. These cookies may, for example, enable the Client to log in, access secure areas of the Website, use the shopping cart function, or access other essential services.
• Analytical and Performance Cookies – These cookies allow the Company to identify and count Website visitors and monitor how visitors navigate the Website while using it. This helps the Company improve Website performance and ensure that users can easily find the information they need. The legal basis for processing data collected through these cookies is Client consent.
• Functional Cookies – These cookies are used to recognize Clients when they return to the Website, allowing the Company to customize content according to Client preferences and remember relevant information. The legal basis for processing data collected through these cookies is Client consent.
10.8.
Cookies also help us distinguish you from other Website users, ensuring a more pleasant browsing experience and allowing us to improve the Website.
Most browsers allow you to reject all cookies, and some browsers provide an option to reject only third-party cookies. You may choose to use these options.
However, please note that blocking all cookies may negatively impact your experience on the Website, and without cookies, you may not be able to use all the services provided on the Website.
We use the cookies described below, and a detailed list of these cookies can be found here:
• stripe_mid – Ensures payment security and functionality; prevents fraud.
• m – Also used by Stripe to identify the device and prevent fraud.
• cids – Used for session management.
• csrftoken – Verifies that the login attempt is legitimate and not an attack.
• frontend_lang – Stores the selected language.
• messages – Displays notifications or errors to the user when they occur.
• sessionId – Stores user information to ensure a stable session.
• jsessionid – Manages video call session settings.
• config.js – Stores user settings related to camera, microphone, and similar features.
• jwt – Ensures that only authenticated users can access their assigned session.
• G_AUTHUSER_H – Google authentication cookie that stores information about a user logged in via Google authentication.
Non-functional Cookies:
• _fbp – Facebook Pixel Cookie – Helps improve user acquisition from ads by tracking user activity on the Website.
• fr – Facebook Cookie – Assists with advertising and user profiling, can track users across different websites.
• _fbc – Facebook Click ID Cookie – Tracks the success of advertisements.
• datr – Facebook Security Cookie – Ensures security and prevents fraud from Facebook’s side.
• _ga – Google Analytics Cookie – Tracks user actions across different web pages, generating analytics on advertising success and efficiency.
• _gac – Google Ads Campaign Cookie – Tracks advertising campaign success, monitoring user activity after logging in, and whether the ad was effective (e.g., whether the user engaged or made a purchase).
• _gads – Google Ad Manager Cookie – Stores user information related to advertising performance, helping evaluate ad effectiveness.
10.9.
We may share your cookie information with our service providers that provide us with IT and website hosting services.
10.10.
You can control the use of cookies by changing your browser settings. For more information, please visit the website of your browser developer.
10.11.
Please note that deleting cookies or disabling their use in the future may prevent you from accessing certain parts or features of our Website. Changing your cookie settings may also affect other websites you visit.
11. Video Surveillance
11.1.
Video surveillance is conducted (if applicable) because the Company aims to protect its property and, in the event of an incident, ensure that evidence related to the incident is preserved.
For this purpose, we have installed video surveillance cameras in our Company premises.
Additionally, for the protection of our legitimate interests, if necessary, we may use your personal data to defend our legal interests in courts, pre-litigation dispute resolution institutions, and other competent authorities.
In the event of damage to our property, we may also share your data with insurance companies.
11.2.
The Company has a legitimate interest in ensuring the security of its assets and preserving evidence of incidents; therefore, we may conduct video surveillance (Article 6(1)(f) of the GDPR).
Additionally, we have a legitimate interest in defending our rights in courts, pre-litigation dispute resolution institutions, and similar bodies.
Furthermore, if you cause damage to us (our property), which we have insured, we may share your information with insurance companies (Article 6(1)(f) of the GDPR).
12. Disclosure of Data
12.1.
We may disclose information about you to our employees, managers, agents, service providers, such as debt administration or collection companies, marketing service providers, IT service providers, or subcontractors, if it is reasonably necessary for the purposes specified in this Privacy Policy.
12.2.
Additionally, we may disclose information about you:
• If required by law;
• To defend our rights or interests (including providing your data to third parties for the purpose of debt collection);
• In the event of an intended sale of the Company’s business or part of its assets, by disclosing your personal data to a potential buyer;
• If the Company’s business or a substantial part of its assets is sold to third parties.
12.3.
Your personal data will not be transferred to a third country or an international organization.
12.4.
Except as specified in this Privacy Policy, we do not provide your personal data to any third parties.
12.5.
The list of data recipients or categories of recipients mentioned in this Privacy Policy may change. If you wish to be notified about any changes regarding the recipients of your personal data, please inform us via the email address provided in this Privacy Policy by including the following text in your email:
"I wish to receive information about changes to the recipients of my personal data. Name, Surname."
13. Security of Your Personal Data
13.1.
Your personal data will be processed in compliance with the General Data Protection Regulation (GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other applicable legal requirements.
When processing your personal data, we implement organizational and technical measures to ensure protection against accidental or unlawful destruction, alteration, disclosure, or any other unauthorized processing.
14. Your Rights
14.1.
This section provides information about your rights regarding the processing of your personal data by us and the circumstances under which you may exercise these rights.
If you would like more information about your rights or wish to exercise them, please contact us via the email address provided in this Privacy Policy.
14.2.
The Company will provide you with information about the actions taken regarding your request to exercise your rights without undue delay, but no later than within one (1) month from the date of receiving your request.
Considering the complexity of the request and the number of requests received, this period may be extended by an additional two (2) months.
In such a case, we will inform you within one (1) month from the date of receiving your request about the extension and the reasons for it.
The Company will only refuse to fulfill your request in cases provided for by law.
14.3. Requests, Complaints, Inquiries:
When submitting an inquiry via the contact email addresses provided on the Company’s website or by mail, you should provide:
• Your name and surname
• Email address or another contact detail
• Inquiry subject and content
• Any other relevant information related to the inquiry
Upon submitting an inquiry, you may be asked to provide additional information about yourself to enable us to respond appropriately.
14.4. We collect and store information about you lawfully because:
• If you submit an inquiry, request, or complaint regarding a contract concluded between us or for the purpose of concluding a contract, these data are collected for contract performance or conclusion purposes (Article 6(1)(b) of the GDPR);
• If you submit an inquiry, request, or complaint for any reason other than contract conclusion or execution, we have a legitimate interest in handling received inquiries (Article 6(1)(f) of the GDPR);
• We have a legal obligation to retain received inquiries, requests, and complaints (Article 6(1)(c) of the GDPR);
• We have a legitimate interest in defending our rights in courts or other institutions (Article 6(1)(f) of the GDPR).
14.5.
The Company states that it does not collect sensitive information about you, including: Racial or ethnic origin, Political opinions, Religious or philosophical beliefs, Trade union membership, Genetic data, Biometric data, Health data, Data concerning an individual's sex life or sexual orientation. If this information is not relevant to your submitted or intended complaint, request, or inquiry, please do not provide it.
However, if such information is provided, we will consider that you have given consent for its processing (Article 9(2)(a) of the GDPR).
14.6.
The Company informs you that, in the case of a request, complaint, or inquiry, your information may be shared with:
• Legal service providers and law firms, to the extent necessary for the protection of our legitimate interests;
• Bailiffs, to the extent necessary for the enforcement of awarded claims;
• Our service providers, including communication (email), IT, and business management platform service providers, if the inquiry, request, or complaint is submitted via email.
14.7.
Your information will be retained as follows:
• If your inquiry is related to a contract that we have concluded or plan to conclude, we will retain it for 10 years after the contract ends.
• If you submit a complaint, request, or other inquiry that is not related to contract conclusion or performance, we will retain it for 1 year after a decision has been made by our Company.
• Documents submitted to courts, dispute resolution bodies, or law enforcement institutions will be retained for 1 year after the final decision is issued.
• Court enforcement orders and bailiff rulings will be retained for 10 years after payment completion.
15. Right to Withdraw Consent
15.1.
If you have provided us with explicit consent for the processing of your personal data, you may withdraw it at any time.
16. Right to Access Your Personal Data
16.1.
We strive to ensure that you fully understand how we use your personal data so that you do not experience any inconvenience.
You may contact us at any time to inquire whether we process any of your personal data.
If we store or use your personal data in any way, you have the right to access it.
To do so, you must:
• Submit a written request to the address provided in this Privacy Policy;
• Verify your identity;
• Act in good faith and reasonableness when submitting such a request.
17. Right to Request Additional Information
17.1.
We understand that it is difficult to cover every possible way personal data may be collected and used.
We strive to provide clear and comprehensive information and are committed to updating this Privacy Policy whenever changes occur in the processing of personal data.
However, if you have any questions regarding the use of your personal data, we will be happy to provide answers or share any additional information that we are legally allowed to disclose.
If you have specific questions or do not understand the provided information, please contact us.
18. Additional Rights
18.1.
Below is information regarding additional rights you may exercise in accordance with the procedures described:
• You have the right to request that we correct any inaccuracies in your personal data. In such cases, we may ask you to confirm the corrected information.
• You have the right to request that we delete your personal data. This right may be exercised in accordance with the General Data Protection Regulation (EU) 2016/679, Article 17.
• You have the right to request that we restrict the processing of your personal data or cease processing in the following cases:
◦ For the period necessary to verify the accuracy of your personal data, if you have challenged its accuracy;
◦ When our collection, storage, or use of your personal data is unlawful, but you choose not to request deletion of the data.
◦ When your personal data is no longer needed by us, but you require it to establish, exercise, or defend a legal claim;
◦ For the period necessary to determine whether we have a compelling legal basis to continue processing your personal data, if you have exercised your right to object to data processing.
• You have the right to data portability for the data that we have collected from you based on your consent or for the purpose of contract execution. If you exercise this right, we will provide you with a copy of your submitted data upon request.
• You have the right to object to the processing of your personal data:
◦ When we use your data to pursue our legitimate interests, but we do not have a compelling legal basis to continue processing your personal data;
or
◦ At any time, when we use your personal data for sending newsletters or for direct marketing purposes. In such cases, your data will no longer be used for these purposes, but they may still be processed for other lawful purposes.
19. Complaints
19.1.
If you believe that your rights as a data subject have been or may be violated, please contact us immediately via the email address provided in this Privacy Policy.
We assure you that upon receiving your complaint, we will respond within a reasonable timeframe and keep you informed about the progress of the investigation, as well as its final outcome.
19.2.
If you are not satisfied with the investigation results, you have the right to submit a complaint to the supervisory authority – the State Data Protection Inspectorate (www.vdai.lrv.lt).
20. Liability
20.1.
You are responsible for maintaining the confidentiality of the data you provide, as well as ensuring that the information you submit to us is accurate, correct, and complete.
If your provided data changes, you must immediately notify us via email.
We will not be liable for any damage or loss you may suffer as a result of providing incorrect or incomplete personal data or failing to inform us of changes to your data.
21. Contact Us
21.1.
There are several ways you can contact the Company: by phone or email.
All messages are received, reviewed, and responded to directly by us.
If you contact us, we may process the personal data you provide, including:
• Name and surname
• Email address
• Phone number
• Date of communication
• Message content
21.2.
This data will be processed to prepare for contract execution or to respond to your inquiries.
If you do not provide your contact details, we will be unable to respond to you.
21.3.
Correspondence is retained for one (1) year from the date of receipt, except for information that is subject to different retention periods as specified in this Privacy Policy or applicable legal regulations.
21.4.
All personal data you provide when communicating with us is used only for the purposes stated above, including reviewing messages and managing communication flows.
We commit to not using your personal data in any publications in a way that would allow your identity to be determined, without your explicit consent.
21.5.
Please note that we may need to contact you via mail, email, or phone.
If your personal data changes, please inform us as soon as possible.
22. Changes to the Privacy Policy
22.1.
We may update or modify this Privacy Policy at any time.
Any updated or modified version of the Privacy Policy will become effective upon its publication on our Website.
You should periodically review the Privacy Policy to ensure that you are satisfied with the latest version.
22.2.
When we update the Privacy Policy, we will inform you of any significant changes, in our opinion, by publishing them on the Website.
The "Last Updated Date" below indicates when the Privacy Policy was last revised.
22.3.
The last update to the Privacy Policy was made on December 10, 2024.

CONSENT FOR PERSONAL DATA PROCESSING

I, ______________________, date of birth ___________, declare that:
MB Ethos Solutions, legal entity code 306689726, registered office at Gėlių g. 4, Didžiulių k., LT-60295 Raseiniai district,
I have provided accurate personal data related to my qualifications, professional skills, and/or business characteristics. If the above-mentioned data changes during the selection process, I undertake to immediately inform the Company via the email address provided below.
Consent
□ I agree that the Company may store my resume and/or cover letter and/or other information I have provided (name, surname, personal identification number, photo, education, skills, personal characteristics, work experience, date of birth, residential address, bank account number, personal contact phone number, and email address) for a period of no longer than three (3) years after the date of my participation in the selection process, for the purpose of offering me a job opportunity in the future if my candidacy is not selected.
□ I agree that the Company may contact my current employers to obtain information about my work performance, relationships with clients and/or colleagues, job evaluation, and other relevant details to assess the suitability of my candidacy.
□ I agree that the Company may conduct a review of my social media accounts, including but not limited to my public profiles on Facebook, Instagram, LinkedIn, and/or other social networks, to assess the suitability of my candidacy.
I have been informed that:
• The Company will contact my former employers to obtain information about my previous work performance, relationships with clients and/or colleagues, job evaluation, and other relevant details to assess the suitability of my candidacy.
• I have the right to refuse to give my consent for the above-mentioned purposes of personal data processing, as my consent is the sole legal basis for the Company to process my personal data. The Company ensures that my refusal to provide consent will not result in any negative consequences for me.
• If I do not provide my consent for the processing of my personal data after the completion of this recruitment process, my personal data will be deleted and/or destroyed within five (5) business days after the employment contract is signed with the selected candidate.
• If I have given my consent for the processing of my personal data for the above-mentioned purposes, I have the right to withdraw any of my given consents at any time by notifying the Company via the email address provided above.
• I have the right to request, in writing or via email using the contact details provided above, that the Company:
(i) allow me to access my personal data processed by the Company, i.e., the personal data collected about me during this recruitment process;
(ii) correct, delete, or restrict the processing of my personal data;
(iii) grant me the right to data portability; and/or
(iv) cease the processing of my personal data.
• The Company undertakes to respond to my written requests without undue delay and no later than within one month (in exceptional cases, this period may be extended by an additional two months). The Company does not process verbal requests.
• If I believe that the Company is processing my personal data improperly and/or unlawfully, I have the right to contact the Company directly or submit a complaint to the State Data Protection Inspectorate (www.vdai.lrv.lt).
____________________________________________________________________
(Name, Surname, Signature, Date)