Privacy Policy

Last modified: 01/01/2023

1. Overview information

This Privacy Policy (“Privacy Policy”) explains how information about you is collected, used, and disclosed by Coherent Solutions Inc and other Coherent Solutions subsidiaries (collectively “Coherent Solutions”, “Coherent”, “we”, “us” or “our”) depending on the processing purposes described in this Privacy Policy.

The Privacy Policy describes the principles of collection, use, or otherwise processing of information we use on the website, as owned and operated by Coherent Solutions, including https://coherentsolutions.com, its subdomains, and any associated web-based and mobile application, (“Website”) as well as other information about the personal data processed during Coherent Solutions activity, policies and principles applied in order to ensure the protection of personal data.

By using the Website and (or) by providing the personal data to us (unless we have to receive your explicit consent under applicable legal acts), you agree that the personal data you provide to Coherent Solutions would be processed in accordance with this Privacy Policy.

2. Data Controller’s information

Coherent Solutions Inc, with registered address: 1600 Utica Ave S, Ste 120 Minneapolis MN 55416, USA, together with Coherent Solutions subsidiaries (“Coherent Solutions”) are personal data Joint Controllers (“Controller”) and are responsible for compliance with the provisions of the Regulation (EC) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, (“GDPR” or “General Data Protection Regulation”), California Privacy Rights Act, effective of January 1, 2023 (hereinafter “CPRA”), and applicable local laws. More information on how to contact us is available under No.13 below.

An agreement has been concluded between us, which establishes our responsibility for the fulfillment of the obligations set out in the GDPR, CPRA and applicable local laws (we will provide access to the essential provisions of this agreement upon written request). In any case you may exercise your rights in respect of each of the Controller.

Personal data is any information relating to an identified or identifiable natural person. Coherent Solutions respects the privacy of the subjects from which it has received personal data and guarantees the fullest possible protection of personal data. The purpose of the present Privacy Policy is to inform you of what personal data we collect, how we use it, who we can share it with, what rights you have regarding the usage of your personal data, and how you can review and change it.

3. Legal grounds for processing, Processing Purposes

3.1. Legal ground for processing

Coherent Solutions only processes personal data if it is absolutely necessary. The purposes of processing and the legal grounds for doing so are the following:

• For performance of a contract or in the context of pre-contractual relationships (lawful ground for processing is Article 6(1)(b) of the General Data Protection Regulation);
• To implement statutory obligations applicable to Coherent Solutions (lawful ground for processing is Article 6(1)© of the General Data Protection Regulation);
• With the explicit consent of the data subject to process the data for one or more specific purposes (lawful grounds for processing is Article 6(1)(a) and Article 7 of the General Data Protection Regulation). Marketing is part of the purposes for consent processing of data, including sending information about events, trainings, and publications;
• We may use your information where there is a legitimate reason to do so. For example, we may use your information where it would help achieve our business objectives or to facilitate a benefit to you or someone else. We only rely on legitimate interests if the reason for using your information is fair and lawful. Where we want to rely on legitimate interests as a legal basis, we will carry out a balancing test between our legitimate interests and your privacy rights (lawful ground for processing is Article 6(1)(f) of the General Data Protection Regulation).

When data processing is based on “explicit consent”, on the grounds of Article 6(1)(a) and Article 7 of the General Data Protection Regulation, the provision of personal data for this purpose is optional. However, lack of consent may result in Coherent Solutions not being able to respond to your request or an application.

Coherent Solutions as personal data Controller follows the following principles when processing your personal data:

• Legality, acting in good faith and with transparency,
• Limitation of processing purposes,
• Relevance of data to processing purposes and minimization of data collection,
• Accuracy and updates of the data,
• Restriction of data storage in order to achieve the processing purposes,
• Integrity and confidentiality of the processing, ensuring an adequate level of security of personal data.

3.2. Purpose for processing

Coherent Solutions as Controller executes the following operations and processes personal data for the following purposes:

• Recruitment process – the purpose of this operation is to identify, evaluate, and select candidates for an open employment position and with your consent to further store your data in our candidates’ database for future open employment positions (more detailed information about how we process your personal data during recruitment process you can find in Privacy Policy for Job Applicants,
• Employment process - for the purpose of planning and organization of work, protection of employer’s property and for the purposes of the exercise and enjoyment of rights and benefits related to employment,
• Marketing purposes – collecting personal data with your explicit consent in order to provide you information about our open vacancies, services or events,
• Processing of data when necessary for the performance of contractual or pre-contractual obligations or when such data is required by law.

The type of data that we can collect for the listed purposes are:

• Individualized data (e.g. name, personal ID, address, etc.)
• Contact information (e-mail, telephone, etc.)
• Information related to your candidacy to our open positions (e.g. CV, information about education, information about work experience, other information provided by the candidate (including during the interview) or received during an evaluation (tests results), including recommendations, information related to qualification, professional skills and business features received from the former employer of candidate).

4. Information We Collect from our Website

When you consent to use our Website, we collect information about you as you use the Website or as you provide it to us, including:

• Website activity, including data about your browsing activity on our Website, such as which pages you visit and links you click
• Technical information about the device or browser you use to access our Website, such as your device’s IP address, cookie string data and (in the case of mobile devices) your device type and mobile device’s unique identifier such as the Apple IDFA or Android Advertising ID
• Personal data, if you choose to provide via a form submission: your name, email address, place of business, job title, and phone number, other requested information, or information you provide on your own initiative
• Customer service information you may provide to Coherent Solutions representatives including survey responses, email messages, or phone conversations.

We use Cookies, in accordance with our Cookie Policy, which is available on the website here.

5. Recipients of personal data

Personal data collected may be stored and processed within and outside the EEA. Coherent Solutions provides personal data to persons outside the European Union only with the explicit consent of the data subject and (or) only using an adequately high level of protection of personal data, by requiring standard contractual clauses or other instruments to ensure adequate protection of such data under the GDPR. We share data within the Coherent Solutions subsidiaries insofar as necessary to enable the decentralization of business operations, support ongoing business activities and to achieve business continuity.

The Company constantly conducts and improves technical maintenance of its business processes in order to guarantee the security and confidentiality of personal data we process and to provide functionality and availability of its business service. For this purpose we may share your information as follows or as otherwise described in this Privacy Policy:

• Provide to service providers, who act as processors of the personal data and provide services to the us related to Website support and maintenance, maintenance of applications used by us, provision of servers and its maintenance, provision of platform for sending newsletter, etc.,
• In response to legal process, to bailiffs, courts, other bodies dealing with disputes,
• In order to investigate or remedy potential violations of our user agreements or policies, or to protect the rights, property and safety of Coherent Solutions, our users or others,
• With our subsidiaries and related companies,
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company,
• With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

6. Rights of data subjects

You, as the data subject, have all rights specified in the applicable legal acts, including indicated down below.

6.1 Right to information. You may at any time request from us information about your personal data that we store and process, as well as about the origin, recipients or categories of recipients to whom we transmitted it, the purpose of processing it as well as any other information as indicated in the applicable legal acts.

6.2 Right of withdrawal. If you have provided us with your consent to process your data, you can withdraw your consent at any time without giving any reasons (withdrawal of the consent shall not affect the lawfulness of the processing of personal data based on the consent before its withdrawal).

6.3 Rectification right. If your personal data processed by Coherent Solutions is incorrect (inaccurate), you can ask us to correct it at any time.

6.4 Erasure and restriction of processing rights. You have the right to request the deletion of your personal data that Coherent Solutions processes or obtain restriction of processing. Deletion can be done at any time by contacting us. Your data will be deleted without undue delay after exercising this right as a data subject. If deletion is contrary to legal, contractual, criminal or commercial law, or other legitimate reasons, instead of deletion, only restriction of your data may take place. After deleting your data, it is no longer possible for us to recover it.

6.5 Right to data portability. If you require us to provide you with your personal data, we will transfer the data to you or another controller in a structured, widely used and machine-readable format. We will only transfer the data directly if it is technically feasible and we have your request.

6.6 Right of objection. You have the right at any time and without giving any reason to object to our processing of your data, including if we process it for the purposes of marketing.

6.7 Advanced rights in automated data processing, including profiling. Coherent Solutions does not perform automated data processing, including profiling. Notwithstanding the above, with respect to automated data processing, including profiling, you have the additional right to request human intervention from the Controller, the right to challenge the decision and the right to express your point of view.

6.8 Contact (for the exercise of your rights as a data subject). When contacting us by e-mail at privacy@coherentsolutions.com or by post mail, the reported data (including e-mail address, name and telephone number, if any) are stored by us in order to respond to your questions and respond to your case. We will delete the retained data as soon as the storage is no longer necessary or will restrict its processing if there are statutory obligations.

6.9 Right of Complaint. You are entitled to file a complaint against the processing of personal data before the competent control body if you believe that your personal data protection rights have been violated.

We will respond to all your requests related to the implementation of your, as the data subject, rights without undue delay and no later than within 1 (one) month after receiving the request. That period may be extended by 2 (two) further months by informing you in advance.

7. Retention period

The received personal data is stored and processed for the following terms:

• For the relevant statutory period – if the personal data is collected and processed on the basis of the fulfillment of a statutory obligation by Coherent Solutions, such as Labor Code, Accounting laws and other,
• For a period of 10 (ten) years – when personal data is received for the purposes of performance of contracts or pre-contractual relationships. This period starts from the later of the two dates: the date of correspondence on the possible conclusion of the contract or the date of contract termination,
• For 3 (three) years – when personal data is received for marketing purposes, incl. information about events, trainings, and publications,
• For 3 (three) years (unless a consent is withdrawn earlier) – for job applicants who have provided us with an explicit consent to process personal data for recruitment purposes and include their data in our candidates’ database. If you withdraw your consent (you can do this any time by contacting us by email address privacy@coherentsolutions.com), then Coherent Solutions will stop processing your personal data and will delete you from candidates’ database.

8. Data security

Coherent Solutions uses technical and organizational security measures to provide the most comprehensive protection of personal data from unauthorized access. We make every reasonable effort to protect your personal information. All our internal and client data is stored in secure cloud servers and managed in accordance with the best practices quoted in “ISO/IEC 27001 Information Security Management Systems. Requirements”. Data encryption is used for more critical data or by customer’s request.

Personal data for marketing purposes is stored in the Pardot Marketing Automation platform. Coherent Solutions also uses Google’s Universal Analytics tracking on our Website.

9. Use of Coherent Solutions’ website by children

We do not intend our Websites or online services to be used by anybody under the age of 16. If you are a parent or guardian and you think we may have collected information about a child, please contact us at privacy@coherentsolutions.com.

10. Competent supervisory authority

The competent supervisory body in EU for the Coherent Solutions is the State Data Protection Inspectorate, L. Sapiegos str. 17, Vilnius, the Republic of Lithuania, email ada@ada.lt. Internet address https://vdai.lrv.lt/

11. Your Access and Control Over Your Information

You can opt-out of receiving targeted ads served by our advertising partners:

• If you are located in the European Economic Area you may opt out of online advertising via the European Interactive Advertising Digital Alliance (EDAA) Your Online Choices website here

• If you are located in the European Economic Area you may also have the right to access, correct or update some of the information we hold about you. You can also request that we delete your information. If you wish to exercise any of these rights, please contact us at privacy@coherentsolutions.com

• You may opt out of Google Analytics tracking by visiting this website: https://tools.google.com/dlpage/gaoptout/.

• You may also request that we stop emailing you by clicking on the “unsubscribe link” or “email preferences link” in our marketing emails or by contacting privacy@coherentsolutions.com.

12. Amendments to this Privacy Policy

We may change this Privacy Policy from time to time. If we decide to make changes to this Privacy Policy, we will update the Privacy Policy date at the top of the policy and post the amended Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

13. Contact

If you have questions about collecting your personal data or about this Privacy Policy, please contact Coherent Solutions’ Data Protection Officer at privacy@coherentsolutions.com with “PRIVACY POLICY” in the subject line, or write to Data Protection Officer at:

Coherent Solutions Inc
1600 Utica Ave S, Ste 120 Minneapolis MN 55416, USA
Attention: DPO

Coherent Solutions UAB
Konstitucijos ave. K29, Vilnius, 08105, Republic of Lithuania
Attention: DPO