This Privacy Policy explains how NNL Sales ("NNL", "we", "us") processes personal data in connection with the NNL Field Orders mobile application (the "App"). The App is an internal business tool provided to authorized NNL field sales agents. It requires a company-issued agent account and cannot be used by the general public.
NNL Sales
Marijampolės g. 27, Pagirių k., LT-53283 Kauno r.
Contact: karolis.aulosevicius@nnl.lt
| Category | Data | Purpose |
|---|---|---|
| Account & authentication | Agent ID, password (stored only as a secure hash), session token | To sign the agent in and keep the session active |
| Two-factor authentication | Agent mobile phone number, one-time SMS code | To verify identity at sign-in when 2FA is enabled |
| Location | Approximate/precise device GPS location | To sort nearby delivery points to the top of the list. Used on-device; not stored on our servers as location history |
| Order & visit data | Orders, quantities, prices, discounts, order type, agent comments, questionnaire answers | To create and transmit orders and record visit outcomes |
| Photos | Photos taken or selected as questionnaire answers | Only when a questionnaire requires a photo answer; uploaded and stored with that answer |
| Business/customer data shown in-app | Delivery points, buyers, contact details, credit limits, debts, stock, prices | Displayed to the agent to support ordering; sourced from masterdata.nnl.lt |
| Technical, diagnostic & interaction data | Device type, operating-system version, connectivity state, crash and error logs, performance diagnostics, and limited interaction data recorded when an error occurs. Diagnostic events may include the authenticated agent ID and role. | To diagnose errors, prevent crashes, maintain performance and improve the reliability of the App |
The App is not used for advertising, and we do not sell personal data or use it for third-party marketing or profiling.
| Permission | Why | Optional? |
|---|---|---|
| Location | Sort delivery points by distance | Yes — if denied, the list falls back to alphabetical order and the App still works |
| Camera | Take a photo for a questionnaire answer | Yes — only requested when a photo answer is needed |
| System photo picker | Select an existing photo for a questionnaire answer; the App receives access only to the item explicitly selected | Yes — only when adding a photo answer |
| Phone (dialer) | Start a call to a delivery point when the agent taps a phone number | Yes — triggered only by the agent |
| Network | Sync data and send orders | Required |
To work without a network connection, the App caches business data (delivery points, products, prices, stock, debt/blocking status, questionnaires, coordinates and schedules) and stores unsent orders locally on the device. This local data is transmitted to our servers when connectivity is available and unsent orders are sent automatically once online.
We process personal data on the following bases: performance of the employment/agency relationship and our legitimate interests in operating field sales and order processing (Art. 6(1)(b) and (f) GDPR); and compliance with legal obligations such as accounting (Art. 6(1)(c)). Where required, processing of an agent's data is also covered by the agreement under which the agent is granted access.
All communication between the App and our systems uses encrypted HTTPS (TLS). Order and visit
data is sent to our back-office system masterdata.nnl.lt. SMS one-time codes are
delivered through NNL's messaging API (nordnetapi.nnl.lt), which passes the agent's
phone number and message text to an SMS delivery provider solely to send the code.
These parties process data only on our instructions and are not permitted to use it for their own purposes.
Account and session data is kept while the agent's account is active. Order, questionnaire and photo data is retained for as long as required for business and legal (e.g. accounting) purposes. Locally cached data remains on the device until it is refreshed, the agent signs out, or the App is uninstalled. Sessions are invalidated when an administrator changes the password or triggers "sign out from all devices".
Passwords are stored only as salted hashes. Data in transit is encrypted with TLS. Access to the App requires authentication, with optional SMS two-factor verification. Administrators can revoke all sessions for an agent at any time.
Subject to applicable law, you may request access to, correction or erasure of your personal data, restriction of or objection to processing, and data portability, and you may lodge a complaint with a supervisory authority (in Lithuania, the State Data Protection Inspectorate — Valstybinė duomenų apsaugos inspekcija). To exercise these rights, contact karolis.aulosevicius@nnl.lt. Note that most business data shown in the App is managed by your employer/administrator through masterdata.nnl.lt.
The App is a workplace tool for authorized adult sales agents and is not directed to or intended for use by children.
We may update this Privacy Policy from time to time. Material changes will be communicated through the App or by your administrator, and the "Last updated" date above will be revised.
NNL Sales
Marijampolės g. 27, Pagirių k., LT-53283 Kauno r.
Privacy contact: karolis.aulosevicius@nnl.lt
Data protection contact: Karolis Aulosevičius — karolis.aulosevicius@nnl.lt