PRIVACY POLICY


2026-04-27


1. GENERAL PROVISIONS

Braiten Group, MB, legal entity code 306998726, registered office address Rambyno g. 14, Palanga, Republic of Lithuania (hereinafter — Braiten, the Data Controller, or the Portal), establishes by this Privacy Policy the terms for processing personal data through use of the "Braiten" mobile application, website, and other electronic services provided by Braiten.

Braiten enables psychologists, psychotherapists, and other professionals (hereinafter — Service Providers) to provide counselling, psychological assistance, and other services remotely to natural persons (hereinafter — Clients) through the "Braiten" mobile application.

Braiten is not a healthcare institution, does not provide healthcare services, and does not carry out medical activity. Braiten operates solely as the operator of a technology platform and intermediary, enabling Service Providers to provide services to Clients.

Each Service Provider independently determines the content of the consultation, makes professional decisions, and is responsible for the legality and quality of the services they provide, for compliance with professional ethics requirements, and, where applicable, for holding any required licences or permits.

Service Providers are considered independent data controllers to the extent that they process Clients' personal data for the purposes of providing consultations, maintaining professional records, diagnosis, assessment, or other professional activities.

It is very important that you read this Privacy Policy carefully, because each time you visit the Website or Portal belonging to the Data Controller, you agree to the terms described in this Privacy Policy. If you do not agree with these terms, please do not visit our website or use our content and/or services.

By submitting your personal data (including data submitted directly or indirectly while visiting the website and using its services), the Data Subject agrees and does not object to the Data Controller managing and processing that data for the purposes and in the manner set out in this Privacy Policy, in the Data Subject's consent, and as provided by law.

Persons under 18 years of age may not submit any personal data through the Data Controller's Website. If you are a person under 18, you must obtain the consent of your parents or other legal guardians before submitting personal information.

Representative — a person representing the Data Controller's clients or partners (service providers), whether natural or legal persons.

The Data Subject under this Privacy Policy is considered to be the Inquirer, the Client, the Candidate, the Telephone Caller, or any other natural person whose personal data is processed by the Data Controller.

Inquirer — a natural person interested in the services provided by the Data Controller, or wishing to contact the Data Controller on other matters.

Client — a person who has purchased services from the Data Controller, or has entered into an agreement with the Data Controller for the provision of services.

Candidate — a person participating, or intending to participate, in a personnel selection process conducted by the Data Controller.

Telephone Caller — a person calling a publicly announced contact telephone number regarding the Data Controller's services and/or other matters.

The Data Controller will collect personal data in accordance with the requirements of applicable European Union and Republic of Lithuania legislation and the instructions of supervisory authorities. All reasonable technical and administrative measures are applied so that data collected about Data Subjects is protected from loss, unauthorised use, and alteration.

This Privacy Policy has been prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (hereinafter — the General Data Protection Regulation), the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other legislation of the European Union and the Republic of Lithuania. Terms used in this Privacy Policy are to be understood as they are defined in the General Data Protection Regulation and the Law on Legal Protection of Personal Data of the Republic of Lithuania.

Persons under 18 years of age may use Braiten's services only with the consent of their legal representatives, except where legislation provides otherwise.


2. WHAT PERSONAL DATA WE PROCESS

Client data

Braiten may process the following Client personal data:

  • first and last name;

  • telephone number;

  • email address;

  • date of birth;

  • account login data;

  • payment information;

  • consultation booking information;

  • data from correspondence with the Service Provider;

  • technical data about the device used;

  • IP address;

  • information about use of the mobile application.

Braiten does not process the content of consultations, Service Providers' professional notes, diagnoses, or other special categories of personal data, except to the extent necessary to ensure the technical operation of the platform.

Service Provider data

Braiten may process the following Service Provider data:

  • first and last name;

  • individual-activity certificate or legal-entity data;

  • professional qualifications;

  • licence number (if applicable);

  • bank account details;

  • contact details;

  • publicly disclosed professional information;

  • profile photograph.


3. PROCESSING OF PERSONAL DATA AND ITS PURPOSES

We process information you provide to us directly.

Information on how you use our Website and Portal. If you visit our Website or Portal, we also collect information that reveals the specifics of how our services are used, or visit statistics generated automatically. Read more about this in our "Cookie Policy."

Information from third-party sources

We may obtain information about you from public and commercial sources (to the extent permitted by applicable law) and combine it with other information we receive from you or about you. We may also obtain information about you from third-party social network services when you log in through them, for example through a "Facebook" account.

Other information we collect

We may also collect other information about you, your device, or your use of the content on our website, with your consent.

You may choose not to provide us with certain information, but in that case you may not be able to use the service we offer.

Braiten processes personal data for the following purposes:

  • user registration and account administration;

  • organising consultation bookings;

  • administering payments;

  • customer service;

  • handling disputes;

  • fulfilling legal obligations;

  • ensuring platform security;

  • statistical analysis and improving service quality.


4. DATA TRANSFER

Braiten may transfer personal data to:

  • the Service Provider you have selected;

  • payment service providers;

  • information technology service providers;

  • accounting and other service providers;

  • government authorities, in cases established by law.

Braiten does not transfer Clients' personal data to third parties for marketing purposes.


5. STORAGE OF PERSONAL DATA

What we do to protect your information

Personal data is protected from loss, unauthorised use, and alteration. We have implemented physical and technical measures to protect all information we collect for the purposes of providing our services. Please note that, although we take appropriate steps to protect your information, no website, internet-based transaction, computer system, or wireless connection is completely secure.

The Data Controller applies different retention periods for personal data, in accordance with legal requirements and taking into account the purposes of personal data processing.

Personal data retention periods:

Purpose of personal data processing

Retention period

Processing of Data Subjects' personal data for the purpose of fulfilling consultations and inquiries

1 year from the date the consultation or inquiry is fulfilled. Except where the Data Subject applies for the Data Controller's services — in that case, the general 10-year term for retention of contract documents applies.

Personal data of Clients and Service Providers — for service-provision purposes

Contracts, as accounting documents — 10 years from the end of service provision

Processing of personal data of natural persons and Representatives for the purpose of performing agreements with partners

For the duration of the agreement and 10 years after the transaction ends

Processing of Candidates' (persons wishing to provide services through the Portal) personal data for selection purposes

5 years from the last update of the data, or until its deletion at the Candidate's instruction


6. RIGHTS OF DATA SUBJECTS

Clients and Service Providers have the right to:

  • access their data;

  • request that it be corrected;

  • request that data be deleted;

  • restrict the processing of data;

  • object to the processing of data;

  • receive their data in a structured format;

  • lodge a complaint with the State Data Protection Inspectorate.

The Data Subject has the right to submit any request or instruction relating to the processing of personal data to the Data Controller in writing, by one of the following means: delivered directly, by post to Rambyno g. 14, Palanga, or by email to: hello@braitengroup.com.

Upon receiving such a request or instruction, the Data Controller shall, no later than within one month of the date of the request, provide a response and either carry out the actions specified in the request or decline to carry them out. If necessary, this period may be extended by a further two months, taking into account the complexity and number of requests. In that case, within one month of receiving the request, the Data Controller shall inform the Data Subject of such an extension, together with the reasons for the delay.

The Data Controller may decline to enable Data Subjects to exercise the rights listed above — except for the right to object to processing of personal data for direct marketing purposes — in cases provided for by law, where it is necessary to ensure the prevention, investigation, and detection of criminal offences or breaches of official or professional ethics, and to protect the rights and freedoms of the Data Subject, the Data Controller, or other persons.

Third-party websites, services, and products on our websites

The Data Controller's website may contain third-party advertising banners and links to third-party websites and services which the Data Controller does not control — for example, a link to the Data Controller's Facebook profile. The Data Controller is not responsible for the security and privacy of information collected by third parties. You should read the privacy notices that apply to any third-party websites and services you use.

If you have provided information about yourself through "Facebook," we understand this to mean that you agree that we may contact you using the contact telephone number and email address provided, and offer you services.

Final provisions

Additions or amendments to this Privacy Policy take effect from the day they are published on the Website.

Where, following an addition or amendment to the Privacy Policy, the Data Subject uses the Website and/or the services provided by the Data Controller, the Data Subject is deemed not to object to such additions and/or amendments.




Contact us

If you have any questions regarding the information provided in this Privacy Policy, please feel free to contact us in whatever way is convenient for you:

Braiten Group, MB

Email: hello@braitengroup.com