Privacy Policy

Effective date: 2026-09-02


1. What this Privacy Policy covers

This Privacy Policy explains how Genz way, MB (operating as “Agenzy”) collects, uses and protects personal data when you visit agenzy.lt or contact us about our services.

It covers our website and our sales and marketing activity. Work we carry out for a client under a signed contract is governed by that contract and by the data processing agreement attached to it, where one applies.


2. Who we are

Genz way, MB (operating as “Agenzy”)

  • Company code: 307589052

  • VAT number: LT100019956413

  • Registered address: Girulių g. 18, LT-12122 Vilnius, Lithuania

  • Operating address: Žalgirio g. 131, LT-08217 Vilnius, Lithuania

  • Email: info@agenzy.lt

  • Phone: +370 604 20012

We are the data controller for the personal data described in this policy.


3. What we collect


3.1 Data you give us directly

When you submit a form on our website, book a call or email us, we collect:

  • Your name

  • Your email address

  • Your phone number, where the form asks for it

  • Your company name or website

  • Which service you are interested in

  • Your indicated monthly marketing or advertising budget range

  • Anything you write in the message field

  • Your answer to “Where did you hear about us?”

  • Your answer to “What prompt did you use?”, where you tell us an AI tool referred you


3.2 Data collected automatically when you submit a form

Every form on our site carries a block of hidden fields that record how you reached us. These are submitted together with the form and stored against your record in our CRM:

  • The page you submitted the form from, and its address

  • The page you first landed on, and the site that referred you there

  • The site that referred you on this visit

  • Campaign parameters in the link you arrived through (utm_source, utm_medium, utm_campaign, utm_term, utm_content), for both your first visit and this one

  • The time you were first seen on the site, and the time you submitted the form

  • Advertising click identifiers present in the link you arrived through: oppref (OpenAI), gclid (Google), fbclid (Meta), ttclid (TikTok), li_fat_id (LinkedIn), msclkid (Microsoft)

  • Whether you are on a desktop or a mobile device

  • Your browser language

  • Which form you used

We use this to understand which pages, campaigns and channels bring us enquiries.


3.3 Data collected automatically as you browse

  • IP address

  • Browser and device information

  • Pages viewed and interactions on the site

  • Analytics identifiers


3.4 Browser storage

To make the attribution described in 3.2 work, our site stores two small records in your browser: your first-touch information in `localStorage` under the key `agenzy_attr`, and your current-session information in `sessionStorage` under `agenzy_attr_last`. Your cookie choice is stored in `localStorage` under `agenzy_consent`.

We treat all of the above as personal data wherever it can be linked to an identifiable person.


4. How we collect it

We collect data when you:

  • Submit the booking form on our website

  • Submit an enquiry form on one of our service pages

  • Book a call through our scheduling link

  • Email us or reply to an email from us

  • Browse our website, through analytics and, with your consent, our advertising pixel

  • Are identified through publicly available professional sources such as a company website or LinkedIn, for business development purposes, on the basis of our legitimate interest


5. Why we use it

  • To answer your enquiry and present our services

  • To manage the sales process and keep a record of our conversations with you

  • To deliver work under a signed client contract and to invoice for it

  • To measure which pages, campaigns and channels produce enquiries

  • To measure the performance of our own advertising, including ads we run on ChatGPT

  • To understand how visitors use the site and improve it

  • To meet accounting and tax obligations

We do not sell personal data to anyone.


6. Legal basis

Under the GDPR we rely on:

  • Consent, for non-essential cookies and tracking technologies and for marketing emails. You can withdraw consent at any time.

  • Contractual necessity, where processing is needed to deliver services you have engaged us for or to take steps before entering a contract at your request.

  • Legitimate interest, for website analytics, measuring our own marketing, keeping records of business conversations, and business development outreach to companies, where your interests and rights do not override ours.

  • Legal obligation, for accounting and tax records.


7. Who we share it with

We use the following service providers. Each one processes data on our instructions.

  • Framer. Hosts our website and serves its content. Data involved: Technical data from your visit.

  • Cloudflare. Runs the relay that receives our form submissions and passes them on. Data involved: Everything the form sends, in transit.

  • HubSpot. Our CRM, where enquiries and the sales record are stored. Data involved: Everything in sections 3.1 and 3.2.

  • OpenAI. ChatGPT Ads Pixel and conversion measurement for the ads we run on ChatGPT. Data involved: See 7.1.

  • Google. Analytics 4, Search Console, Gmail and Workspace, and our calendar booking link. Data involved: Analytics data, and your emails and booking details.

We may also share data where the law requires it, or with our accountants and legal advisers where necessary.

We do not run advertising retargeting on this website beyond the ChatGPT Ads measurement described below. Advertising platforms we operate on behalf of clients process client data under those clients’ own arrangements.


7.1 What we send to OpenAI

We advertise on ChatGPT. To measure whether those ads produce enquiries, two things happen.

First, if you accept cookies, the OpenAI ChatGPT Ads Pixel loads in your browser and records that you visited and, if you submit a form, that a lead was created.

Second, when a form is submitted, our server sends one conversion event to OpenAI’s Conversions API containing: the type of event, the time, the page it happened on, your IP address, your browser’s user agent string, the OpenAI click identifier if your visit carried one, and a SHA-256 hash of your email address. Your email address itself is never sent to OpenAI, only the irreversible hash, which lets OpenAI match the conversion to a click without learning who you are.


7.2 Transfers outside the EEA

Some of these providers are established outside the European Economic Area or process data there, including in the United States. Where that happens, transfers are covered by the safeguards those providers offer, which include Standard Contractual Clauses approved by the European Commission and, where applicable, certification under the EU-US Data Privacy Framework. Our HubSpot account is hosted on HubSpot’s EU infrastructure.


8. How long we keep it

  • Enquiries and leads: up to 2 years from our last contact with you.

  • Client data: for the duration of the contract, plus 5 years afterwards, which covers our accounting and limitation-period obligations.

  • Marketing contacts: until you withdraw consent or opt out.

  • Analytics data: up to 26 months.

  • Email correspondence: for as long as it remains relevant to an ongoing or possible business relationship, and in any case no longer than the periods above.

After these periods data is deleted or anonymised.


9. Cookies and similar technologies

We use cookies and browser storage in three ways.

Necessary. Required for the site to work and to remember your cookie choice. These load without consent because the site cannot function without them.

Analytics. Google Analytics 4 (measurement ID G-SHD7WTS8XJ) tells us how many people visit, which pages they read and how they found us. Google Search Console tells us which searches lead people here. We rely on legitimate interest for these and they currently load on every visit.

Advertising. The OpenAI ChatGPT Ads Pixel measures whether our ads on ChatGPT produce visits and enquiries. It loads only after you click “Accept” in our cookie banner. If you choose “Only necessary”, it never loads, on this visit or any later one.

When you first visit, our banner asks you to choose. Your choice is stored in your browser and the banner does not reappear. To change it, clear your browser storage for agenzy.lt and the banner will ask again. You can also block or delete cookies through your browser settings at any time.


10. Marketing emails

We send marketing emails only where we have a lawful basis to do so. You can opt out at any time by clicking unsubscribe in any marketing email or by writing to info@agenzy.lt. Opting out does not affect any work we are delivering for you.


11. Your rights

Under the GDPR you have the right to:

  • Access the personal data we hold about you and receive a copy

  • Correct data that is wrong or incomplete

  • Delete your data, where no legal ground requires us to keep it

  • Restrict how we process it, in certain circumstances

  • Object to processing based on legitimate interest, and to direct marketing at any time and without giving a reason

  • Receive your data in a structured, commonly used, machine-readable format, and have it sent to another controller where technically feasible

  • Withdraw consent at any time, which does not affect processing that already happened on the basis of that consent

Write to info@agenzy.lt to exercise any of these. We respond within one month, and will tell you if we need longer because a request is complex.

If you are not satisfied with how we handled your request, you can complain to the Lithuanian State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija, VDAI) at vdai.lrv.lt.


12. Security

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration and disclosure. Access to our CRM and our email is restricted to the people who need it and is protected by two-factor authentication. Our form relay transmits data over encrypted connections only, and the credentials it uses are held as encrypted secrets rather than in our code.


13. Automated decision-making

We do not make decisions about you by automated means that produce legal effects or similarly significantly affect you.


14. Children

Our website and services are aimed at businesses. We do not knowingly collect personal data from anyone under 16. If you believe we have, write to info@agenzy.lt and we will delete it.


15. Changes to this policy

We update this policy when our practices or the law change. The effective date at the top of this page always reflects the current version. Where a change is significant we will say so on the page.


16. Contact

Genz way, MB (Agenzy) Email: info@agenzy.lt Phone: +370 604 20012 Address: Žalgirio g. 131, LT-08217 Vilnius, Lithuania