1. Who We Are
This Privacy Policy describes how Viesoji istaiga „Doberman Media“ (hereinafter “we”, “us”, or “the Organisation”) collects, uses, and protects personal data when you visit or interact with our website at ngo.doberman.media.
| Full name | Viesoji istaiga (VsI) „Doberman Media“ |
| Legal entity code | 306984317 |
| Registered address | Giedraičių g. 39, R53, LT-09302 Vilnius, Lithuania |
| Website | ngo.doberman.media |
We are a non-profit public interest organisation engaged in human rights protection activities, registered in the Republic of Lithuania and operating within the European Union. As a data controller, we are committed to protecting your personal information in compliance with Regulation (EU) 2016/679 (GDPR) and applicable Lithuanian law.
2. Data We Collect
We collect personal data only to the extent necessary for the purposes described in this Policy:
| Category | Data collected | How it is collected |
| Contact inquiries | Full name, email address, message content | Contact form on the website |
| Donations | Name, email address, donation amount, payment details (processed by payment provider) | Donation form / payment gateway |
| Technical data | IP address, browser type, pages visited, session duration | Automatically via cookies / server logs |
| We do not collect sensitive special-category data (Article 9 GDPR) such as health information, ethnicity, political opinions, or biometric data. |
3. How We Use Your Data
We use the personal data we collect solely for the following purposes:
- To respond to your inquiries — processing messages submitted via the contact form and following up by email.
- To process donations — verifying transactions, issuing acknowledgements, and fulfilling legal accounting obligations.
- To operate and improve the website — analysing anonymous usage statistics to improve performance and content.
- To comply with legal obligations — fulfilling requirements under Lithuanian and EU law, including financial reporting for non-profit organisations.
We do not sell, rent, or trade your personal data. We do not use your data for automated profiling or automated decision-making that produces legal effects.
4. Legal Basis (GDPR)
For every processing activity, we rely on one of the following legal bases under Article 6 GDPR:
| Processing activity | Legal basis |
| Responding to contact form inquiries | Legitimate interests (Art. 6(1)(f)) — responding to communications addressed to us |
| Processing donations | Performance of a contract / pre-contractual steps (Art. 6(1)(b)); Legal obligation for accounting (Art. 6(1)(c)) |
| Website analytics (cookies) | Consent (Art. 6(1)(a)) |
| Compliance with legal obligations | Legal obligation (Art. 6(1)(c)) |
5. Data Retention
We retain your personal data only for as long as necessary for the purpose it was collected, or as required by applicable law:
- Contact form data — up to 2 years from the date of your inquiry, unless an ongoing case requires longer retention.
- Donation records — 10 years in accordance with Lithuanian accounting and tax legislation.
- Website analytics / server logs — up to 12 months, in anonymised or aggregated form thereafter.
When retention periods expire, data is securely deleted or anonymised.
6. Third Parties and Data Transfers
We may share your data with trusted third-party service providers acting as data processors on our behalf:
- Payment service providers — to process donations securely. These providers maintain PCI DSS compliance. We do not store full payment card details on our own systems.
- Email service providers — to send acknowledgements or reply to your inquiries.
- Web hosting and infrastructure providers — to operate the website.
All third-party processors are bound by data processing agreements. Where data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place (e.g. Standard Contractual Clauses under Art. 46 GDPR).
We do not disclose personal data to third parties for their own marketing purposes.
7. Your Rights Under GDPR
As a data subject under the GDPR, you have the following rights:
- Right of access (Art. 15) — to obtain a copy of the personal data we hold about you.
- Right to rectification (Art. 16) — to correct inaccurate or incomplete data.
- Right to erasure (Art. 17) — to request deletion of your data (“right to be forgotten”), subject to legal retention obligations.
- Right to restriction of processing (Art. 18) — to limit how we process your data in certain circumstances.
- Right to data portability (Art. 20) — to receive your data in a structured, machine-readable format.
- Right to object (Art. 21) — to object to processing based on legitimate interests.
- Right to withdraw consent — at any time where processing is based on consent, without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us using the details in Section 10. We will respond within 30 days of receipt of your request, in accordance with Art. 12 GDPR.
| You also have the right to lodge a complaint with the Lithuanian supervisory authority: State Data Protection Inspectorate (VDAI) — vdai.lrv.lt |
8. Cookies
Our website may use cookies — small text files stored on your device — to ensure basic functionality and, where you have given consent, to collect analytics data.
| Cookie type | Purpose | Consent required? |
| Strictly necessary | Core website functionality (session management) | No |
| Analytics | Anonymous usage statistics to improve the website | Yes |
You may manage or withdraw your cookie consent at any time via your browser settings or our cookie consent banner. Disabling analytics cookies does not affect your ability to use the website.
9. Children’s Privacy
Our website is not directed at children under the age of 16. We do not knowingly collect personal data from minors. If you believe a child has provided us with personal data without parental consent, please contact us and we will promptly delete such data.
10. Contact Us
For any questions regarding this Privacy Policy, to exercise your data subject rights, or to raise a concern, please contact us:
| Organisation | Višoji įstaiga (VšĮ) „Doberman Media“ |
| Address | Giedraičių g. 39, R53, LT-09302 Vilnius, Lithuania |
| privacy@doberman.media [replace with actual email] | |
| Website | ngo.doberman.media/privacy-policy |
We aim to respond to all privacy-related requests within 30 days. If your request is complex, we may extend this period by a further two months and will notify you accordingly.