Question 1

External websites

Accepted Answer

The Platform may contain links to external websites - including the social networks where we have accounts, websites where our services are promoted, and websites where customs-related content is hosted. By following any of these links, please be aware that such websites and the services they offer are governed by their own privacy policies. We do not accept any responsibility or liability for these policies or for the handling of personal data collected through those websites or services, such as contact or location data.

We recommend reviewing the relevant privacy policies before submitting any personal data on external websites or using any third-party services. We also encourage you to read the privacy statements of the third parties who operate these websites and contact those service providers directly if you have any questions about how your personal data is used.

Question 2

How long do we store your personal data?

Accepted Answer

We retain your personal data only for as long as necessary to fulfil the purposes of its processing, or as required by law if a longer retention period is prescribed.

We aim not to store outdated or irrelevant personal data. Therefore, when data is updated (e.g. amended or changed), only the latest relevant information is retained. Historical data is stored only where required by law or necessary for the performance of our activities.

Question 3

What are your rights?

Accepted Answer

When we process your personal data, we ensure your rights under the GDPR and the Law on the Legal Protection of Personal Data of the Republic of Lithuania. As a data subject, you have the following rights:

To be informed about the processing of your personal data.
To access your personal data held by us.
To request rectification, clarification, or completion of inaccurate, incorrect or incomplete personal data.
To request the erasure of your personal data when it is no longer necessary for the purposes for which it was collected.
To request the erasure of your personal data if it has been processed unlawfully, or if you withdraw consent or did not provide consent where it was required.
To object to the processing of your personal data or withdraw previously given consent.
To request that we suspend the processing of your personal data (except for storage) during disputes, or when you require verification of the legality or accuracy of the data, or in other cases where we no longer require your data but you do not wish it to be deleted.
To request that your personal data, where technically feasible, be provided in an easily readable format or transferred to another data controller, where it was collected based on your consent or a contract.

We will strive to uphold your rights as a data subject and provide the conditions necessary for their effective exercise. However, we may decline certain requests where necessary to ensure: compliance with legal obligations imposed on us; protection of national security or defence; maintenance of public order, or the prevention, investigation or prosecution of criminal offences; safeguarding important state economic or financial interests; investigation and prevention of breaches of professional or official ethics; or protection of your own rights and freedoms, or those of others.

You may submit requests regarding your data subject rights by email to info@customsclear.net. Upon receiving your request, we may ask for proof of identity and any other information required to process it.

We will respond to your request no later than 30 calendar days after receiving both your request and the necessary supporting documents. For complex or numerous requests, this may be extended by up to two further months; if so, we will tell you within the first 30 days and explain why.

If we consider it necessary, we may suspend the processing of your data (excluding storage) until a decision is reached regarding your request. If you withdraw your consent, we will stop the related processing without delay, and no later than within 30 calendar days - except where legal obligations, court decisions or binding instructions require us to continue.

If we are unable to fulfil your request, we will clearly explain the reasons.

If you use the Learning companion, you have the right to access, correct, or request the deletion of your Learning companion profile, including your conversation history, personalisation data, and learning progress records. You can do this using the controls available within the service, or by contacting us at info@customsclear.net. We will act on your request without undue delay and no later than 30 calendar days after receipt.

If you disagree with our decision or with the way we have handled your request, you can appeal by applying to the competent state authority - see 'Where can you submit a complaint?'.

Question 4

Why and how do we process your personal data?

Accepted Answer

We process your personal data only for the purposes set out in this section. For each purpose we state what we process, our legal basis under Article 6 of the GDPR, and how long we keep the data. If you have questions about the data we hold about you, contact us as set out in 'What are your rights?'.

For managing your account and providing our services. To use our services - reading articles, watching videos, taking courses, receiving certificates - you create an account and profile. We process: your personal information (name, optional profile picture, country and industry details, and other information you choose to add); your email and password; your preferences, such as languages and markets of interest; your courses, with progress, completed tests and certificates; your content use, saved items, plan, purchases and purchase history; and your account activity dates. Our legal basis is the performance of our contract with you (Article 6(1)(b)), and Article 6(1)(c) for records the law requires us to keep. We keep account data while your account is open and delete it within 3 months of closure; accounting records are kept for 10 years, as Lithuanian law requires. Author profiles are public; other users' profile information is not visible to other users.

For payments. We process your order and invoice details, billing name and address, country, and company or VAT identifiers, and we receive from our payment processor the payment method type and its last four digits. We do not receive or store your full card details - they are handled by our payment processor and do not reach our systems. Our legal basis is Article 6(1)(b), and Article 6(1)(c) for accounting obligations.

For providing the AI services. When you use the AI-powered assistants - Classify AI, Smart Taric AI, Sanctions AI, News AI, the Article assistant and the Learning companion - we process the personal data generated through your interactions: the content of your queries and conversations; conversation history, so a conversation can continue between sessions; personalisation data you provide or that follows from your use, such as your professional role, markets of interest, goods categories, learning progress and course completion (Learning companion); and anything you upload or submit. Our legal basis is Article 6(1)(b) - the processing is necessary to provide the services you have asked for. This data may be processed by third-party AI service providers acting as our processors under Article 28 GDPR agreements; where data is transferred outside the European Economic Area, safeguards under Chapter V GDPR apply, such as standard contractual clauses. We do not use the content of your queries, conversations or uploaded content to train or improve any AI model, whether ours or a third party's. Conversation history and personalisation data are kept while your account is active, or until you delete them - you can do this at any time using the controls in the service or by writing to info@customsclear.net.

For direct marketing. With your consent, we send you newsletters about new content, our services and events. We process your email address and name, received directly from you. We keep this data until you withdraw your consent, which you can do at any time - see the direct marketing section below.

For answering enquiries and quality control. When you contact us - or we contact you in response - we process your name, contact details, the content of your enquiry or complaint, dates, and our correspondence, so we can respond and investigate. Our legal basis is Article 6(1)(b) where the matter concerns your contract with us, and otherwise Article 6(1)(f), our legitimate interest in answering people who contact us. We keep enquiry and support correspondence for as long as it remains relevant to our relationship with you - for example, while you hold an account or plan, or while a matter you raised may still need follow-up. We review stored correspondence regularly and delete what is no longer needed. Where an investigation or legal process is under way, we keep the related correspondence until it concludes.

For improving the Platform. We use data generated through your use of the Platform, and cookie data where you consent, to understand how the Platform is used and to develop it. Our legal basis is Article 6(1)(f), our legitimate interest in improving our services, and Article 6(1)(a) for non-essential cookies - see 'How do we use cookies?'. We keep this data for 24 months, then aggregate it so it no longer identifies you.

For content publishing. We process authors' personal data - name, photograph, professional experience descriptions - to publish their contributions with attribution. This data comes from the authors themselves or through course providers and publishers, and is kept for the duration agreed with them.

Other purposes. Where the law requires us to process your data, our legal basis is Article 6(1)(c). Where processing is needed to establish, exercise or defend legal claims, it is Article 6(1)(f), and we keep the data until the applicable limitation period ends.

In each case, data may be processed on our behalf by providers of hosting, IT, maintenance or, where relevant, legal services - 'How do we share your personal data?' explains how.

Question 5

What is this document?

Accepted Answer

This privacy policy (the 'Privacy policy') explains how and why we process your personal data, how we receive it, to whom we provide it, how long and how securely we store it, and what your rights are and how to exercise them. 'Data subject' means any natural person who can be identified, directly or indirectly, from identification information - that is, personal data.

The Privacy policy applies to the use of our websites www.customsclear.net and www.customsclear.ai (together, and each individually, the 'Platform') and of our accounts on social networks. It covers everyone who visits or uses them - whether or not you have an account - and the actions performed there, including reviewing content, using the AI-powered assistants, submitting enquiries and writing comments. Please read it carefully: by visiting the Platform or our social network accounts you accept its conditions, and if you do not accept them, please do not use the Platform or our accounts.

The Platform is intended for professional use and not for anyone under 18. We do not knowingly collect personal data from anyone under 18; if we learn that we have, we delete it. A parent or guardian who believes we hold such data can ask us to remove it.

'Personal data' means any information that allows us to identify you, directly or indirectly - for example first name, last name, email address, telephone number, location data, online identifiers or characteristics, as specified in the GDPR.

Question 6

How do we collect your personal data?

Accepted Answer

We receive your personal data in three ways:

When you provide it to us. You give us personal data by using the Platform and our social network accounts - for example when you register and create your profile, buy a plan or course, register for an event, subscribe to the newsletter, use the AI services, or write to us. If you contact us in writing or by email, we may keep the correspondence.
When you use the Platform or our social network accounts. Certain information is collected automatically - for example IP address, browser type, device information, language, country, internet service provider, date and time of visit, number of visits, pages viewed, time spent on the Platform, and the referring website.
When we receive it from someone else. For example, when a Team plan administrator adds you as a user, they give us your name and work email, and their organisation is responsible for telling you. We may also receive data from payment institutions, or from course providers and publishers where relevant, and in accordance with legal procedures and this Privacy policy.

We may combine data received directly from you with data collected through your use of the Platform - for example with data obtained via cookies, as described in 'How do we use cookies?'. You can always request the correction of incorrect personal data and exercise your rights as a data subject, as set out in 'What are your rights?'.

Question 7

What principles do we follow?

Accepted Answer

When processing your personal data, we:

comply with applicable laws, including the GDPR;
process your personal data in a legitimate, fair and transparent manner;
collect it for established, clearly defined and legitimate purposes, and do not process it in a manner incompatible with those purposes;
take all reasonable steps to ensure that inaccurate or incomplete data is promptly corrected, supplemented, deleted, or no longer processed;
keep it in a form which allows you to be identified for no longer than is necessary for the purposes it is processed for;
do not sell it, and do not share or publish it except in the cases specified in this Privacy policy or under applicable laws;
protect it with appropriate technical and organisational measures against unauthorised or unlawful processing and against accidental loss, destruction or damage;
do not use the content of your queries or conversations with the AI services to train any AI model.

Question 8

How is this Privacy policy updated?

Accepted Answer

We update this Privacy policy when our processing or the law changes. The date at the top shows when it was last updated. Updates are announced in the Notifications section of your account, and where a change materially affects you, we will also tell you by email. Where a change requires your consent, we will ask for it - continued use of the Platform is not consent to a change that needs it. If you have any questions about the changes, contact us at info@customsclear.net.

Question 9

Who are we?

Accepted Answer

The Platform is managed and administered by CC Learning, UAB, company code 305133737, address Mariu st. 17, LT-93264 Klaipeda, Lithuania, contact email info@customsclear.net ('we').

When you provide us with your personal data, or we collect or obtain it from other sources, we are the controller of your personal data and process it for the purposes set out in this Privacy policy. This means we decide why and how your data is processed, and you can exercise all your rights under the GDPR directly with us - see 'What are your rights?'.

Where your organisation's users submit content to the AI services containing personal data that your organisation controls - for example, internal documents - we act as your organisation's processor for that content, under a data processing agreement. Ask us at info@customsclear.net.

Question 10

Do we use your personal data for direct marketing and what are the rules for subscription to our newsletters?

Accepted Answer

With your consent, we use your personal data to send you newsletters - information about new content on the platform, our services, offers and events. You give consent by subscribing to the newsletter, and you can withdraw it at any time.

To unsubscribe, use the unsubscribe link included in every newsletter, or write to info@customsclear.net with your name and the email address you subscribed with. We may ask you to verify your identity. Once you withdraw, we stop sending you newsletters without delay, and we keep a record of your withdrawal so that we do not contact you again by mistake.

If you have given consent, we may also analyse newsletter and platform use to improve our services and communication - for this, depersonalised data is used.

Withdrawing your marketing consent does not delete your other personal data or close your account. If you want that too, make a separate request as set out in 'What are your rights?'.

Please note that some messages are not marketing and do not stop when you unsubscribe: while you hold an account or plan, we may still need to write to you about it - for example about billing, security, or changes to our terms or prices.

Question 11

How do we store your personal data?

Accepted Answer

Data collected from you is primarily stored within the European Union. It may also be transferred to or stored in countries outside the EU, and may be processed by our personnel or the personnel of our partners located outside the EU. When data is transferred outside the EU, we do so on the basis of a European Commission adequacy decision or subject to appropriate safeguards under the GDPR, such as standard contractual clauses, and in accordance with this Privacy policy. You may ask us for more information about the safeguards that apply.

Unfortunately, the transmission of information via the internet is not completely secure. While we take every effort to protect your personal data, we cannot guarantee the security of data transmitted to the Platform - you acknowledge the risks associated with online data transmission.

In the unlikely event that we become aware of a security breach involving your personal data that may pose a significant risk to your rights and freedoms, we will inform you without delay. We will also identify and disclose the type of information that was accessed, and, where the breach is likely to result in a risk to your rights and freedoms, notify the supervisory authority as the GDPR requires.

Question 12

How do we share your personal data?

Accepted Answer

Your personal data will not be sold, supplied, or otherwise shared with third parties without legitimate grounds, nor used for purposes other than those for which it was collected. We will not transfer your personal data in any way other than in accordance with this Privacy policy and applicable legal regulations. However, we may disclose information about you if we are required to do so under applicable law or at the request of lawfully authorised institutions or criminal prosecution authorities.

We may transfer your personal data to companies that assist us in carrying out our activities, under data processing agreements. The ability of these service providers to use your data is limited - they may not use your data for any purpose other than to provide services to us.

Question 13

Where can you submit a complaint?

Accepted Answer

If you wish to submit a complaint regarding the processing of your data, please do so in writing, providing as much relevant information as possible, using the contact details set out in 'How to contact us?'. We will cooperate fully and aim to resolve all matters promptly.

If you believe your rights have been violated, you may lodge a complaint with the State Data Protection Inspectorate of the Republic of Lithuania, our lead supervisory authority (further information and contact details at https://vdai.lrv.lt), or with the supervisory authority of the country where you live or work, as permitted by applicable legal provisions. However, our main goal is to resolve any disputes quickly and amicably, in cooperation with you.

Question 14

How to contact us?

Accepted Answer

All correspondence related to this Privacy policy should be sent to us at info@customsclear.net or to CC Learning, UAB, Mariu st. 17, LT-93264 Klaipeda, Lithuania. You may also contact us with any questions or concerns about your personal data.

Question 15

How do we use cookies?

Accepted Answer

We use cookies and similar technologies. Cookies are small text files recorded on your device that allow us to recognise you on future visits to the Platform. They help keep you logged in, remember your preferences, adapt content to your needs, and make the Platform faster and more reliable.

We use the information collected through cookies to ensure the functionality of the Platform, to improve and develop it, to analyse how it is used, and - where you consent - to make our marketing more relevant. Subject to applicable laws, we may combine information collected via cookies with other data, such as Platform usage information.

The following types of cookies may be used on the Platform:

Technical cookies - essential for the functioning of the Platform.
Functional cookies - not strictly necessary, but they improve the performance, quality and user experience of the Platform.
Analytical cookies - used to produce anonymous statistics on how visitors use the Platform.
Targeted or advertising cookies - used to display offers or information that may be of interest to you.
Social network cookies - required to enable sharing of Platform content to your social media profile.

We set only technical cookies until you give your consent. You give consent by selecting 'Accept' on the cookie banner displayed on the Platform.

You can withdraw your consent to the use of cookies at any time by changing your browser settings to block or delete cookies. When cookies are deleted, the banner appears again on your next visit, and you can choose anew. If technical or functional cookies are disabled or deleted, parts of the Platform may work slowly or not at all, or access may be restricted.

For external websites, including social networks, see 'External websites'.