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Last Updated: July 20, 2026

PRIVACY POLICY

BERKUUBIK MB

Therefore, in this privacy policy (the Policy) we explain what kind of personal data we collect and for what purposes, when providing you with our products and/or services (the Services), when you are using our application GuideWay: Travel and Guide and/or when you otherwise make contact with us.

PURPOSE AND SCOPE

Berkuubik MB (also referred to as we, us or the Company), company registration number 308012954, having its registered office in Lithuania at Vilnius, Vilkpėdės g. 22, LT-03151, is committed to protecting and respecting your privacy.

Therefore, in this privacy policy (the Policy) we explain what kind of personal data we collect and for what purposes, when providing you with our products and/or services (the Services), when you are using our application GuideWay: Travel and Guide and/or when you otherwise make contact with us.

In any case, all personal data collected by us are processed in accordance with the EU General Data Protection Regulation No. 2016/679 (the GDPR), the UK GDPR, Law on the Legal Protection of Personal Data of the Republic of Lithuania and other applicable legal acts.

For any questions regarding this Policy or any requests regarding the processing of your personal data, please contact us at privacy@berkuubik.com.

HOW WE COLLECT YOUR PERSONAL DATA

We collect information you provide directly to us when you:

  1. fill out any form in our mobile application;
  2. when you register;
  3. purchase our services;
  4. communicate with our customer support team;
  5. contact us via any means of communication (e.g., via our social network accounts);
  6. use our Services.

We may also receive your personal data from third parties. In particular:

  1. we may receive personal data from a third party which is connected to you or is dealing with us, for example, business partners, sub–contractors, service providers, merchants, etc.;
  2. we may receive purchase, subscription and entitlement information from Apple, Google and RevenueCat, including transaction identifiers, product identifiers, purchase dates, subscription status, price, currency, cancellation status and refund status. We do not receive or store your complete payment-card details;
  3. we may receive personal data from other entities that we collaborate with;
  4. we may receive personal data when you use social login features;
  5. we may receive or process technical, analytics, crash-reporting, purchase and entitlement information through third-party SDKs and similar technologies, including Firebase, RevenueCat and Mapbox.

DIRECT MARKETING

In case you are our existing client (i.e. you already use our Services), we may use your e-mail address for direct marketing purposes, but only with regard to products and/or services that are similar or related to the Services, and only if you do not object to such use of your e-mail address. You are also granted with a clear, free of charge and easily realisable possibility to object or withdraw from such use of your contact details.

In other cases, we may use your personal data for the purposes of direct marketing, only if you give us your prior consent regarding such use of the data.

We provide a clear, free of charge and easily realisable possibility not to give your consent or, at any time, to withdraw your consent to receive our marketing communications. We shall state in each communication sent by e-mail that you are entitled to object to such processing of your personal data, and to refuse receiving communications from us. You shall be able to refuse receiving our marketing communications by clicking on the respective link in each marketing e-mail received from us.

HOW WE SHARE YOUR PERSONAL DATA

We may disclose your personal data to the recipients of the following categories:

  1. public authorities, institutions, organisations, courts and other third parties, but only upon request and only when required by applicable laws, or in cases and under procedures provided for by applicable laws, e.g. for the purposes to secure and/or defend Company’s legitimate interests;
  2. third parties providing services to the Company including providers of legal, financial, auditing, tax, business management, personnel administration, accounting, direct marketing, communications, data centres, hosting, cloud and/or other services. In each case, we provide such third parties with only as much data as necessary to provide their services. Service providers engaged by us may process your personal data only in accordance with our instructions and may not use them for other purposes;
  3. third parties for the purpose of performance of the contract concluded with you;
  4. third parties, when the Company intends to enter into a business sale transaction and/or to perform legal and/or financial due diligence of the Company prior to such transaction;
  5. other persons with your consent.

Specifically, we integrate the following third-party services into our Application: Google/Firebase (for analytics, crash reporting, and notifications), Apple App Store & Google Play (for app distribution and analytics), RevenueCat (for subscription management), Hostinger (for cloud hosting) and MapBox (for map functionality). You can find more information about their data processing in their respective privacy policies.

INTERNATIONAL DATA TRANSFERS

Berkuubik MB is established in Lithuania. GuideWay’s primary backend and database infrastructure is hosted through Hostinger on a virtual private server located in Germany.

Germany and Lithuania are both within the European Economic Area (“EEA”). The storage and processing of personal data between Lithuania and Germany therefore does not constitute a transfer to a third country under the GDPR.

Some of our service providers or their authorised subprocessors may process personal data outside the EEA. Where this occurs, we ensure that an appropriate legal safeguard is used, such as a European Commission adequacy decision or the European Commission’s Standard Contractual Clauses, together with any additional safeguards required by applicable data-protection law.

You may contact privacy@berkuubik.com for further information about the safeguards used for international data transfers.

HOW LONG WE KEEP YOUR PERSONAL DATA

We will keep your personal data for as long as it is needed for the purposes for which your data was collected and processed, but not longer than it is required by the applicable laws and regulations, including for the purposes to comply with any legal, regulatory, tax, accounting or reporting obligations. If the legislation of the Republic of Lithuania does not provide any applicable data retention period, it shall be determined by us, taking into account the legitimate purpose of the data retention, the legal basis and the principles of lawful processing of personal data. Personal data that is important for the contractual relationship between you and Company is normally stored for as long as the contractual relationship lasts and thereafter for a maximum period of 10 (ten) years after the relationship.

If you do not enter into a contract with us, the personal data are normally stored for a maximum of 12 months. We may retain your personal data for a longer period when:

  1. it is necessary for the Company to be able to defend itself against existing or threatened claims or to exercise its rights, or for the proper resolution of dispute, complaint or claim;
  2. there is a suspicion of illegal activity;
  3. it is required by applicable laws.

Upon expiration of the retention period, we will delete and/or reliably and irrevocably depersonalize your data as soon as possible, within a reasonable time required to perform such action.

YOUR RIGHTS

  1. The right to be informed. You have the right to be provided with a clear, transparent and easily understandable information about how we process your personal data.
  2. The right to access. You have the right to request from us the copy of your personal data. Where your requests are excessive, in particular if they are a repetitive, we may refuse to act on the request, or charge a reasonable fee taking into account the administrative costs for providing the information.
  3. The right to rectification. You have the right to request us to correct or update your personal data at any time, in particular if your personal data is incomplete or incorrect.
  4. The right to data portability. When a legal basis for data processing is consent or contract, you have the right to request that we transfer your data that we have collected to another organisation, or directly to you, under certain conditions.
  5. The right to be forgotten. Where the applicable legal conditions are met, you may request deletion of your personal data. You may initiate deletion of your GuideWay account directly in the Application by navigating to Profile > Delete My Account. You may also request deletion through the external account-deletion resource available on our website or by contacting privacy@berkuubik.com.
    When a GuideWay account is deleted, the account is permanently closed and the personal data associated with it is deleted or irreversibly anonymized.
    Data normally deleted or irreversibly anonymized includes account and profile information, authentication information, countries marked as visited, wishlist countries, selected passport issuing countries, saved preferences, notes, guides and other account-linked content.
    We may retain a strictly limited amount of information where retention is necessary:
    1. to comply with tax, accounting, financial-reporting or other legal obligations;
    2. to verify purchases, subscriptions, refunds and transactions;
    3. to prevent, detect or investigate fraud, abuse and security incidents;
    4. to resolve complaints and disputes; or
    5. to establish, exercise or defend legal claims, including court, administrative or out-of-court proceedings.

    Information retained for these purposes will be limited to what is reasonably necessary, kept separately or access-restricted where appropriate, and will not be used to recreate the deleted account, provide ordinary GuideWay features, conduct marketing or rebuild the user’s travel profile.

    6. Deleting your GuideWay account does not automatically cancel an active subscription purchased through the Apple App Store or Google Play. The subscription must be managed or cancelled separately through the applicable store account.
  6. The right to restrict processing. You have the right to restrict the processing of your personal data in certain situations (e.g., when you want us to investigate whether that data is accurate; we no longer need your personal data, but you want us to continue holding it for you in connection with a legal claim).
  7. The right to object to processing. Under certain circumstances you have the right to object to certain types of processing (e.g., to receive our marketing communications).
  8. The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with a competent supervisory authority, if you believe that your personal data is processed in a way that violates your rights and legitimate interests stipulated by applicable legislation. Our data processing is supervised by the State Data Protection Inspectorate of the Republic of Lithuania (address: L. Sapiegos st. 17, LT-10312 Vilnius, phone No.: +370 5 271 2804 / 279 1445, e-mail address: ada@ada.lt, for more information, visit https://vdai.lrv.lt/en/).
  9. Right to withdraw your consent. If personal data is processed on the basis of your consent, you can withdraw it at any time. Withdrawal will not affect the lawfulness of processing of your data before the withdrawal.

If you would like to exercise any of these rights, please contact us via e-mail: privacy@berkuubik.com.

Your request shall be fulfilled, or fulfilment of your requests shall be refused by specifying the reasons for such refusal, within 30 (thirty) calendar days from the date of submission of the request that complies with our internal rules and the GDPR. The aforementioned term may be extended by 60 (sixty) calendar days taking into account the complexity and number of the requests. The Company will inform you of any such extension within 30 (thirty) calendar days of receipt of the request, together with the reasons for the delay.

We may refuse to satisfy your request if the exceptions and/or limitations to the exercise of data subjects' rights set out in the GDPR apply, and/or if your request is found to be manifestly unfounded or disproportionate. If we refuse to satisfy your request, we will give you our reasons for such refusal in writing.

Information for US Residents (including California): We do not 'sell' your personal data as defined by the California Consumer Privacy Act (CCPA). We only share data with service providers to deliver our Services. US residents have the right to request access to the specific pieces of personal information we have collected, request deletion. You can exercise these rights by contacting us at the email provided below.

HOW WE PROTECT YOUR PERSONAL DATA

Please note that, although no system of technology is completely secure, we have implemented security measures to minimize the risk of unauthorised access to or improper use of your personal information.
We and our third-party service providers that may be engaged in the processing of personal data on our behalf (for the purposes indicated above) are contractually obligated to respect the confidentiality of the personal data.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the competent supervisory authority without undue delay, as required by applicable law.

CHILDREN’S PRIVACY

Our Services are not directed to children under the age of 13 (or 16 in the EEA). We do not knowingly collect personal data from children. If we become aware that we have inadvertently received personal data from a child under the applicable age of consent, we will delete such information from our records. If you believe we might have any data from or about a child, please contact us.

CHANGES TO THIS POLICY

We regularly review this Policy and reserve the right to modify it at any time in accordance with applicable laws and regulations. Any changes will take effect immediately upon their publication in our application.

Please review this Policy from time to time to stay updated regarding any changes.

CONTACT US

You may contact us by writing an e-mail to privacy@berkuubik.com or post by address Vilnius, Vilkpėdės g. 22, LT-03151.