NNL Field Orders — Privacy Policy

Last updated: 3 September 2026

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.

1. Data controller

NNL Sales
Marijampolės g. 27, Pagirių k., LT-53283 Kauno r.
Contact: karolis.aulosevicius@nnl.lt

2. What data we process

CategoryDataPurpose
Account & authenticationAgent ID, password (stored only as a secure hash), session tokenTo sign the agent in and keep the session active
Two-factor authenticationAgent mobile phone number, one-time SMS codeTo verify identity at sign-in when 2FA is enabled
LocationApproximate/precise device GPS locationTo sort nearby delivery points to the top of the list. Used on-device; not stored on our servers as location history
Order & visit dataOrders, quantities, prices, discounts, order type, agent comments, questionnaire answersTo create and transmit orders and record visit outcomes
PhotosPhotos taken or selected as questionnaire answersOnly when a questionnaire requires a photo answer; uploaded and stored with that answer
Business/customer data shown in-appDelivery points, buyers, contact details, credit limits, debts, stock, pricesDisplayed 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.

3. Device permissions

PermissionWhyOptional?
LocationSort delivery points by distanceYes — if denied, the list falls back to alphabetical order and the App still works
CameraTake a photo for a questionnaire answerYes — only requested when a photo answer is needed
System photo pickerSelect an existing photo for a questionnaire answer; the App receives access only to the item explicitly selectedYes — only when adding a photo answer
Phone (dialer)Start a call to a delivery point when the agent taps a phone numberYes — triggered only by the agent
NetworkSync data and send ordersRequired

4. Offline storage on the device

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.

5. Legal basis (GDPR)

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.

6. How data is transmitted and where it goes

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.

7. Third parties / sub-processors

These parties process data only on our instructions and are not permitted to use it for their own purposes.

8. Retention

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".

9. Security

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.

10. Your rights

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.

11. Children

The App is a workplace tool for authorized adult sales agents and is not directed to or intended for use by children.

12. Changes to this policy

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.

13. Contact

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