El texto oficial de la política de privacidad está disponible en inglés, idioma corporativo oficial de la entidad.
Transparency & GDPR (Reg. EU 2016/679)

Privacy Notice on Personal Data Processing

Last updated: October 2026 • Version v1.0-202610

Notice Regarding Corporate & Regulatory Status

UAB The Demokra 1 is a private limited liability company incorporated in Lithuania (EU), registration code 308111774, registered office in Vilnius, preparing an EMI licence application with the Bank of Lithuania (Lietuvos bankas). At the time of viewing this website, the company does not provide regulated payment or financial services to the public, does not issue electronic money, and does not accept deposits. Personal data processing conducted via this website pertains solely to technical portal browsing, optional informational registration regarding authorization milestones, and recruitment.

1. Data Controller

The Data Controller responsible for personal data processing is:

Entity Name: UAB The Demokra 1

Registration Code (Kodas): 308111774

Registered Office: Lvivo g. 21-101, LT-09309 Vilnius, Lithuania

Contact Email (including privacy & GDPR rights): info@demokra.com

2. Categories of Data, Purposes, and Legal Bases

The company strictly follows the data minimisation principle (Art. 5(1)(c) GDPR): the website does not collect visitors' personal data, with the sole exception of the email address voluntarily provided to receive informational updates and candidate data spontaneously submitted for employment vacancies.

A. Browsing data and system technical logs

Data processed: Requesting device IP address, UTC timestamp, requested URI paths, HTTP response status codes, browser and OS characteristics (User-Agent), referring URL (Referer).

Purpose: Technical website operation, traffic routing, network diagnostics, and safeguarding infrastructure against unauthorized access or denial-of-service (DDoS) incidents.

Legal basis: Legitimate interest of the Controller in maintaining network security and operational resilience (Art. 6(1)(f) GDPR and Recital 49).

Retention and Hosting: Web infrastructure is hosted on Google Cloud Platform (GCP) with data centers located in Frankfurt (europe-west3 region, European Union); technical network and security logs are retained for no longer than 30 days.

B. Informational launch and milestone updates (Waitlist)

Data processed: Exclusively the email address submitted by the user and the interest profile (Individual / Freelancer). No other personal data is collected or requested.

Purpose: Sending periodic email updates regarding authorization progress, product roadmap milestones, and announcements of future platform release.

Legal basis: Explicit consent of the data subject (Art. 6(1)(a) GDPR), granted via an active, un-preselected optional checkbox.

Procedure notice: Communications are handled directly via corporate email without third-party databases. Immediate deletion is guaranteed upon simple request to info@demokra.com.

Retention: The email address is retained until consent is withdrawn or unsubscription is requested, and for no longer than 24 months from registration.

C. Job applications and recruitment (Careers Section)

Data processed: Full name, email, telephone number (if provided), target role, LinkedIn profile link or portfolio/GitHub link (if provided), cover message.

Purpose: Evaluating professional qualifications, assessing compatibility with open roles, and administering recruitment processes for potential employment.

Legal basis: Performance of pre-contractual steps taken at the candidate's request (Art. 6(1)(b) GDPR).

Explicit prohibition of non-essential and special category data: Candidates are strictly requested not to provide non-essential data (e.g. photos, age, marital status) nor special categories of data under Art. 9 GDPR (health data, religious/philosophical beliefs, political opinions, trade union membership). Any unsolicited sensitive data will be destroyed immediately.

Retention: Candidate application data is retained for no longer than 24 months from receipt or recruitment process conclusion, following which it is permanently deleted.

3. Processing Modalities and Data Recipients

Personal data is processed electronically in compliance with principles of lawfulness, fairness, transparency, and data minimisation. Submissions through website contact forms are delivered directly to the Controller's corporate email inbox, without storage on unverified third-party SaaS databases.

Data may be handled by contracted Processors pursuant to Art. 28 GDPR:

  • Hosting and network infrastructure provider: Google Cloud Platform (GCP), data centers located in the Frankfurt region (europe-west3, European Union);
  • Corporate email service provider (info@demokra.com): Register (Register S.p.A. - team.blue Group), infrastructure and servers located in the European Union;
  • Legal and HR counsel bound by professional secrecy obligations.

No personal data is sold or commercialized to third parties, nor subjected to automated decision-making or profiling (Art. 22 GDPR).

4. Data Subject Rights (Articles 15-22 GDPR)

Data subjects may exercise their statutory rights under Regulation (EU) 2016/679:

  • Right of access (Art. 15): obtain confirmation and access to personal data;
  • Right to rectification (Art. 16): request correction of inaccurate data;
  • Right to erasure (Art. 17): request deletion when data is no longer necessary;
  • Right to restriction (Art. 18): request restriction of processing in statutory circumstances;
  • Right to data portability (Art. 20): receive data in structured, machine-readable format;
  • Right to object (Art. 21): object to processing grounded in legitimate interest;
  • Right to withdraw consent: revoke consent at any time without affecting past lawful processing.

Requests may be addressed to:
info@demokra.com or by postal mail to the registered office in Vilnius.

5. Right to Lodge a Complaint

Without prejudice to other judicial remedies, data subjects have the right to lodge a complaint with the competent supervisory authority:

Supervisory Authority Lithuania (Controller Establishment):
State Data Protection Inspectorate (VDAI)
L. Sapiegos g. 17, LT-10312 Vilnius, Lithuania • Website: vdai.lrv.lt

Supervisory Authority Italy (for Italian residents):
Garante per la protezione dei dati personali
Piazza Venezia 11, 00187 Rome • Website: garanteprivacy.it