Privacy policy

Updated: 28 September 2026

This English translation is provided for convenience. The Lithuanian original is legally authoritative and prevails if the versions differ.

SKELBKNT.LT PRIVACY POLICY Effective from 21 August 2026 1. WHO WE ARE 1.1. This Privacy Policy explains how personal data is processed when you use https://skelbknt.lt and the real-estate listing platform operating on that website (the “Platform”). 1.2. Data controller: MB “Steel Trek” Legal entity code: 306950514 VAT identification number: LT100020410116 Registered office: Partizanų g. 61-806, LT-49282 Kaunas, Lithuania Email for privacy matters: info@skelbknt.lt Telephone: +370 600 50591 1.3. We have not appointed a separate Data Protection Officer. You may submit all requests concerning personal data to the email address specified in clause 1.2. 2. KEY PRINCIPLES 2.1. We process personal data lawfully, fairly and transparently, only for specified purposes and only to the extent necessary to achieve those purposes. 2.2. The Platform is not intended for publishing special categories of personal data, such as health data, political opinions, religious beliefs or biometric data, or national identification numbers or data concerning minors. Please do not enter such information in Listings, Search Requests, search fields or the contact form. 2.3. Confirming that you have read this Privacy Policy does not constitute consent to every processing activity. We rely on the separate legal basis applicable to each purpose. Where consent is required by law, we ask for it separately, and you may withdraw it. 3. WHAT DATA WE PROCESS, WHY WE PROCESS IT AND OUR LEGAL BASIS 3.1. ACCOUNT REGISTRATION AND MANAGEMENT Data processed: your name or display name, email address, telephone number, password hash, account role and status, email verification timestamp, evidence that you read the Privacy and Cookie Policies and accepted the Platform Terms (document-version checksums, timestamp, IP address and browser user-agent string), and account creation and change timestamps. Purposes: to create and administer your account, authenticate you, reset your password, send account-related communications and provide Platform features. Legal basis: entering into and performing a contract (Article 6(1)(b) GDPR) and our legitimate interest in protecting the security of the account and Platform (Article 6(1)(f) GDPR). 3.2. SIGN-IN WITH GOOGLE AND ACCOUNT SECURITY If you choose to sign in with Google, we receive your Google account identifier, name, email address and email-verification status. We do not receive or store your Google account password. If you enable two-factor authentication, we process an encrypted authentication secret, recovery codes and verification timestamps. We also process sign-in session, device, IP address and browser information to the extent necessary for security. Purposes and legal basis: to provide sign-in and security features using the method you choose, perform the contract, and protect accounts and the Platform against unauthorised use (Article 6(1)(b) and (f) GDPR). 3.3. REAL-ESTATE LISTINGS Data processed: - Listing headline, description, price, property features and categories; - location data: county, municipality, settlement, neighbourhood, street, building and apartment numbers, Google Maps address, geographic coordinates and your choices about whether to display the exact address publicly; - photographs, video and technical information about that media; metadata that is not needed to provide the service is removed from uploaded media where technically feasible; - type and role of the contact person, name or company name, telephone number and email address; - publication, expiry, editing, deletion and moderation data; - evidence that you accepted the terms, pricing and withdrawal conditions: checksums of the accepted document versions, timestamp, IP address and browser user-agent string. Purposes: to create, publish, administer, search and moderate a Listing; provide the paid service; evidence the contractual terms; and resolve disputes. Legal basis: entering into and performing a contract (Article 6(1)(b) GDPR); our legitimate interest in preventing abuse and establishing, exercising or defending legal claims (Article 6(1)(f) GDPR); and, where required, compliance with a legal obligation (Article 6(1)(c) GDPR). Public visibility: an active Listing publicly displays its information, media, contact details and the location at the level of precision you have chosen. Building and apartment numbers and the exact Google Maps address are displayed publicly only in accordance with your respective choices. Search engines and other internet users may view, copy or index information that has been published publicly. 3.4. REAL-ESTATE SEARCH REQUESTS Data processed: the title and description of your Search Request, property criteria, location, price and area ranges, contact person's name, telephone number and email address, expiry period and evidence that you accepted the terms. Purposes and legal basis: to publish and administer your Search Request and enable others to contact you—performance of a contract (Article 6(1)(b) GDPR); and prevention of abuse—our legitimate interest (Article 6(1)(f) GDPR). Public visibility: a published Search Request and the contact details it contains are public. Please provide only contact details that you are legally entitled to make public. 3.5. SEARCH, SEMANTIC SEARCH AND SAVED LISTINGS Data processed: the text entered in a search, normalised search text, selected filters, result count, search duration, associated location and property category, your account identifier if you are signed in, and your list of Saved Listings. For semantic search, text intended for public display in a Listing, a public or less precise location description, and search text entered by you may be sent to the provider of the artificial-intelligence infrastructure to create a numerical vector representation (an embedding). We do not send payment data, passwords or non-public contact details for this purpose. Please do not enter personal data or confidential information in a search field. Purposes: to provide more relevant search results, save the Listings you select, assess search quality, diagnose errors and prevent abuse. Legal basis: providing Platform features under the contract (Article 6(1)(b) GDPR) and our legitimate interest in improving search quality and security (Article 6(1)(f) GDPR). Semantic ranking does not produce legal effects or similarly significant effects concerning you and is not automated decision-making within the meaning of Article 22 GDPR. 3.6. PAYMENTS, ORDERS AND INVOICES Data processed: your and the buyer's billing details, Listing and order identifiers, type of service, amount, currency, status, creation and payment timestamps, payment reference, SEB transaction reference, invoice number, a copy of the invoice contents, prices applied and evidence of the versions of legal documents accepted. We do not collect online-banking sign-in details, payment-card numbers, PINs or other bank authentication credentials. We receive from SEB only the data needed to verify and reconcile the payment result. Purposes and legal basis: to receive and reconcile payments, activate a service, issue invoices, maintain accounting records, process refunds and resolve disputes—performance of a contract (Article 6(1)(b) GDPR), compliance with accounting and tax obligations (Article 6(1)(c) GDPR), and our legitimate interest in preventing fraud and defending legal claims (Article 6(1)(f) GDPR). 3.7. CONTACT FORM, SUPPORT AND COMPLAINTS Data processed: your name, email address, message subject and text, related Listing, order or account details, correspondence timestamps and technical data needed to prevent spam. We do not record telephone calls unless we clearly inform you before a particular recording is made. Purposes and legal basis: to respond to your enquiry, perform a contract or take steps at your request before entering into one (Article 6(1)(b) GDPR), comply with a legal obligation to respond to a consumer claim (Article 6(1)(c) GDPR), retain evidence of correspondence and protect the form against abuse (Article 6(1)(f) GDPR). 3.8. TECHNICAL LOGS AND COOKIES Data processed: IP address, request timestamp, browser and device type, page address visited, HTTP response status, errors and security events, session identifiers and essential preferences. Purposes and legal basis: to operate the Platform, maintain sessions and security, diagnose errors and prevent abuse—performance of a contract and our legitimate interest (Article 6(1)(b) and (f) GDPR). Further information is provided in the Cookie Policy. 4. WHERE WE OBTAIN DATA 4.1. We obtain most data directly from you when you register, create content, search, make a payment or contact us. 4.2. We receive payment status and the transaction reference from SEB; authentication data from Google if you choose to sign in using that service; and addresses and coordinates from Google Maps when you use the map or address-search features. 4.3. We automatically obtain technical data from your device, browser and the Platform infrastructure. 5. WHO WE DISCLOSE DATA TO 5.1. Personal data may be processed only by our employees, engaged specialists and service providers who need it to perform specific functions and who are subject to confidentiality and data-protection obligations. 5.2. Where necessary, data may be disclosed to the following categories of recipients: - website hosting, database, backup, security and technical-support providers; - email delivery and communications infrastructure providers; - SEB when a payment is initiated and verified; - Google when you use Google sign-in, Google Maps or address search; - OpenAI or another semantic-vector service provider configured for the Platform, solely for the purpose described in clause 3.5; - accounting, audit, legal and debt-administration service providers; - competent public authorities, courts or law-enforcement authorities where disclosure is required by law or necessary for legal claims. 5.3. Public information in an active Listing or Search Request is disclosed to an unlimited number of internet users. Parties to a real-estate transaction process data they obtain directly from each other after making contact independently, in accordance with the law applicable to them. 5.4. We do not sell personal data or disclose it to independent companies for their own direct-marketing purposes. 6. TRANSFERS OUTSIDE THE EEA 6.1. Some technology providers, including Google and OpenAI, may process data in the European Economic Area and in other countries, including the United States of America. 6.2. Where data is transferred outside the EEA, the transfer relies on an applicable adequacy decision, the EU–US Data Privacy Framework where the particular recipient is duly certified under it, the European Commission's Standard Contractual Clauses, or another safeguard provided for in Chapter V GDPR. 6.3. Information about safeguards applicable to a particular transfer, and a copy of those safeguards, may be requested at info@skelbknt.lt to the extent that providing it does not infringe the rights of others or disclose a trade secret. 7. HOW LONG WE RETAIN DATA 7.1. Account data is retained while your account is active. After an account is closed, data is erased or anonymised except for information that we must retain by law or need to retain for disputes, fraud prevention and legal claims, normally for no longer than three years after the relationship ends. 7.2. An active Listing or Search Request is publicly available until it expires, is deactivated or is removed. Public access ends after removal. Internal copies and moderation history are retained only for as long as reasonably necessary to handle complaints, prevent abuse and address legal claims, normally for no longer than three years, except for data relating to accounting documents. 7.3. Invoices, payment evidence, copies of invoice contents and order data required for a business transaction are retained for 10 years or for another period required by law. Deleting your account does not shorten this period. 7.4. Evidence that legal documents were accepted is retained with the relevant contract or invoice for the applicable retention and potential-claims period. 7.5. Your Saved Listings are retained until you remove them, the Listing is permanently deleted or your account is closed. 7.6. Search-event data linked to a specific account is retained for no longer than 12 months, after which it is erased or anonymised. Search-text vectors that are not linked to an account identifier may be retained for up to 12 months after their last use to support search speed and quality, and are then deleted unless needed for a security incident or legal claim. 7.7. Contact and support correspondence is normally retained for up to three years after the enquiry is resolved. A consumer complaint and related evidence may be retained for longer where required by law or an ongoing dispute. 7.8. Ordinary technical and error logs are normally retained for up to 90 days. Logs relating to a specific security incident may be retained until the investigation and applicable claims periods have ended. 7.9. Deleted data may remain in backups for a limited backup-rotation period. It is not used for other purposes and is deleted again after a backup is restored, in accordance with the applicable deletion rules. 8. HOW WE PROTECT DATA 8.1. We apply access controls, password hashing, encrypted connections, separate administrative permissions, payment-message signature verification, rate limits, backups, updates and other technical and organisational measures selected according to risk. 8.2. No internet system can guarantee absolute security. If we identify a personal-data breach, we assess it and, where required by the GDPR, notify the State Data Protection Inspectorate and affected individuals. 9. YOUR RIGHTS 9.1. Depending on the circumstances and the applicable legal basis, you have the right to: - obtain confirmation as to whether we process your data and access that data; - request rectification of inaccurate data or completion of incomplete data; - request erasure where there is no lawful basis for further retention; - request restriction of processing; - receive data you have provided in a structured, commonly used and machine-readable format and, where technically feasible, transmit it to another controller; - object, on grounds relating to your particular situation, to processing based on legitimate interests; - withdraw consent at any time where a particular processing activity is based on consent, without affecting the lawfulness of processing before withdrawal; - not be subject to a decision based solely on automated processing that produces legal effects or similarly significant effects concerning you. 9.2. Please send your request to info@skelbknt.lt. We may ask for information reasonably necessary to verify your identity, but will not request more data than is needed to identify the person making the request. 9.3. We respond without undue delay and normally no later than one month after receiving your request. In complex cases, the period may be extended by a further two months; we will inform you of the extension and its reasons within the first month. 9.4. If you believe that your data is being processed unlawfully, you have the right to lodge a complaint with the State Data Protection Inspectorate: L. Sapiegos g. 17, LT-10312 Vilnius, email ada@ada.lt, https://vdai.lrv.lt. We encourage you to contact us first so that we can address the matter promptly. 10. CHILDREN'S DATA 10.1. Platform accounts and Listing publication services are intended for people aged 18 or over. We do not knowingly collect account data from minors. 10.2. If we learn that a minor has submitted data without a lawful basis or the consent of a legal representative where required, we will erase or restrict that data to the extent permitted and required by law. 11. CHANGES TO THIS POLICY 11.1. We may update this Policy if Platform features, service providers or legislation change. The new version will be published on this page with its effective date. 11.2. We will notify registered Users of material changes through the Platform or by email where notification is required. If consent is required for a new processing purpose, we will request it before starting that processing. © MB “Steel Trek”, 2026. All rights reserved.