LITIDEAL PRIVACY POLICY INFORMATION
The terms of this privacy policy apply to the activities of LITIDEAL UAB (“Ideal” or “we”).
Ideal is a company belonging to the Osaühing Ideal Baltic group of companies and acts as an independent representative in Lithuania of the car rental brands Avis, Budget and Payless, owned by Avis Budget Group, Inc.
Please take the time to read our privacy policy and how we collect and use your personal information. We consider “personal information” to be any information relating to a natural person that identifies or can be used to identify that person.
Ideal may change some parts of this privacy policy in certain cases and we recommend that you review it periodically. If we make changes that materially affect your rights or (to the extent permitted by us) materially change the way we use your personal information, we will notify you promptly by posting information on our websites, by email and/or by regular mail before the changes take effect.
Choose one of the topics below to find out how we collect, use, share and disclose personal information:
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VEHICLE RENTAL
VEHICLE DATA
PHOTOS AND VIDEOS
ONLINE DATA
ONLINE ADVERTISING
MARKETING
ANALYTICS
CHILDREN
INFORMATION SHARING
YOUR CHOICES
SAFEGUARDS
INFORMATION STORAGE
INTERNATIONAL TRANSFERS
YOUR PRIVACY RIGHTS
CONTACT DETAILS OF THE DATA CONTROLLER
HERE
Ideal wants you to feel at ease by giving us access to your personal information. This privacy policy notice tells you what is done with your personal information when you interact with Ideal, and what choices you have in relation to this.
This Privacy Policy applies to the personal information that Ideal collects, uses and discloses when you use our products and services, whether online or offline.
Ideal needs to collect your personal information in order to rent you a vehicle or provide other services. We collect personal information when you provide it, for example, by phone, fax, mail, email, at the rental location, when you fill out an application or enrollment form, when you participate in our Avis Preferred loyalty program, or when you use any of Ideal’s websites, mobile applications, or our products and services.
Please note that in some cases, if you do not provide us with the personal information we need, we may not be able to provide products or services in accordance with our contract with you, or we may not be able to comply with applicable legal obligations. For example, when you rent a vehicle from us, we will ask for information such as your name, address, payment information and driving licence. If you do not provide us with this information, we will not be able to rent the vehicle. We will inform you if this happens and let you know the consequences of not providing your personal information.
Sometimes we share the personal information we receive from you with other information from other sources so that we can provide you with a more tailored service that you can use without hassle. This information may include your name, contact information, travel itinerary, booking details and other information relating to your booking. Such third parties include:
- The travel agents or third-party booking services you used to make your booking.
- Your employer or association if you use a company/association account.
- Our affiliates when you want to use an AWD number, or when you make a reservation with any company operated by our affiliates for rental services with another company operated by us.
- The police and other law enforcement authorities if you have been involved in an accident or suffered any damage, or if the vehicle has been damaged or stolen during the rental period, or if you have been fined for speeding, parking, had to pay a toll or a traffic-related fine, or committed any traffic-related offence during the rental period.
The purposes for which we use this information are described in more detail in the rest of this privacy notice. Data protection laws establish various grounds on which Ideal may use your personal information for the following purposes, namely: 1) if you have given us your consent to use your personal information for this purpose (e.g. if you have given us your consent to send you marketing communications by email); 2) if we need to use such personal information in order to fulfil our obligations under a contract to provide you with products or services (e.g, 3) if the processing is necessary for the fulfilment of our legitimate interests, provided that they outweigh your rights and interests; 4) if we are required to comply with a legal obligation (e.g. to respond to a request for information from a government or law enforcement authority).
Our legitimate interests include the following: (a) to ensure the effective administration and management of your relationship with us, including the rental relationship; (b) to understand how our customers use our services and manage our fleet of vehicles; (c) to carry out research and analysis of what services or products our customers need and how they would like us to improve our services and products; and (d) to find out how our customers use our websites and apps, to identify any problems with their use of the websites and apps, and to find out how we can improve the customer’s experience; e) tell our customers about the different products and services we can offer; f) learn about and respond to customer feedback; g) better tailor and personalise the promotions and benefits we offer to our customers; h) prevent, detect or investigate unauthorised use of our vehicles and systems, ensure that we comply with the law and our own policies; and i) deal with any disputes and situations, in the event of an accident, and obtain legal or other professional advice.
When you use our website and app, we will collect technical information about your devices where permitted. If you would like to know how we collect data online, please see the Online Data section.
VEHICLE RENTAL
When you make a reservation, rent a vehicle or participate in one of our programmes, such as our corporate programme or our Avis Preferred loyalty programme, we collect information to enable us to provide our services to you in the best possible way (such as the rental of a vehicle, including the performance of the vehicle rental contract) in accordance with our General Terms and Conditions of Rental, specific rental company’s terms and conditions and the rental agreement, to provide optional extras as requested, to accept payment, to issue a permit and accept a deposit, to provide discounts, to make offers and to provide other benefits) and for our legitimate business interests (for example, to research and develop new products and services, to carry out fraud prevention and safety checks, to protect our legal rights). The information we collect includes:
- name and surname:
- your email address (if you book online or want to receive an email receipt);
- your home address (for sending bills)
- details of your employer and the address of your company (if you are participating in the company scheme);
- telephone numbers where we can contact you;
- date of birth (for certificate verification and legal requirements)
- gender (for certificate verification);
- payment information, such as your credit or debit card details (the security code is only received for the transaction – we do not store it);
- tax identification number (if specifically requested);
- the information on your driving licence and/or other government-issued identification document, including if you are an additional driver of the specific vehicle you are renting (for licence verification and legal requirements);
- information contained in another identity document, such as a passport or ID card if your driving licence does not have a photo or makes it difficult to identify you, and in proof of address, such as a utility bill (for security and fraud prevention purposes). The information we collect and retain will only include your photo ID in cases where we inform you of this;
- special discount codes, partner membership numbers, association memberships, company rewards programmes (if you want discounts, special privileges and points programmes);
- special requests and requests, including:
Your preferences on optional extras, such as indemnity waivers and other protections;
where a delivery or pick-up service is available, the address where we will drop off or pick up the vehicle, as well as any optional extras you want;
- any other information we may need to rent a vehicle and/or provide services to you.
Some vehicles are equipped with a Global Positioning System (GPS) or similar type of tracking device that can also collect information about the vehicle. To find out what kind of vehicle data we collect, see the Vehicle data section.
If you are involved in an accident, suffer any damage, or if the vehicle is damaged or stolen, or if there is a mechanical breakdown during the rental period, we will collect information about the incident, including your incident report and any reports from the police or other third parties, including details of the persons involved, the nature of any personal injury and/or damage to the vehicle, and for optional extras. We will use this information for the performance of our contract with you (for example, the vehicle rental agreement and/or the terms of any optional extras such as insurance); for our legitimate business interests (for example, to cover any loss or damage to the vehicle); to comply with our legal obligations (for example, to provide the relevant authorities with the necessary notifications of the incident); and to formulate, enforce and defend any legal claims in relation to such incident.
During your rental period, we will collect information about where and when you rented the vehicle, where and when you returned it, as well as insurance preferences, fuel consumption, mileage, accident history and other information related to the vehicle and your use of it. This information is necessary to enable us to provide you with the services you have requested under the lease agreement or to meet our legitimate business interests (for example, to monitor the use of our fleet of vehicles).
In addition to the above, we use this information for the purposes of better understanding our customers and providing you with relevant offers.
We will also collect information about any speeding, parking, toll or other traffic-related fines imposed on you during the rental period, or traffic offences committed by you, when such information is provided to us by any law enforcement authority. We will use such information to arrange payment of such fine or to resolve an offence under a vehicle rental agreement we have entered into with you.
Where you inform us that you require an adapted vehicle or the assistance of another driver because of a disability, we will use this information to provide you with the service you have requested, provided that you give us your explicit consent to use this information.
When you purchase a gift voucher or a voucher, we collect information about the name and postal address of the recipient of the gift so that we can fulfil your order. We will only use this information for the specific purpose for which it was provided. If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our databases, please contact our customer service department using the details provided in the Data Controller Contact Information section below.
“SHEEP PREFERRED”
If you choose to join our Avis Preferred loyalty programme, we will collect and store information about your name, contact details, driver’s licence details and date of birth in order to create an Avis Preferred account for you in accordance with the terms and conditions of the Avis Preferred programme.
We will use this information, together with details of your past and future rental transactions, to enable you to take advantage of the benefits of Avis Preferred membership, including the express check-in service at our rental locations, the ability to manage your booking information independently via our app, and other benefits you are entitled to as a member of the programme, such as free upgrades to your vehicle and free rental.
We will also use this information to tailor the communications we may send you and/or promotions we may offer you as an Avis Preferred member in certain cases.
We will also use this information for our own internal analysis of how customers use our services and how we can improve our services.
INSURANCE PRODUCTS
If you have opted for any of the insurance products we offer with your rental, we will pass on your personal information to the insurer that owns that product.
In the event that you make a claim in respect of any of these insurance products, your personal information relating to the claim will be provided to the insurer and to any appointed investigator. We do this in order to enforce the terms of the contract we have entered into with you and to formulate, exercise or defend any related legal claims.
Your personal information will be used by the insurer in accordance with the terms of its privacy notice.
VEHICLE DATA
Some of the vehicles that you rent from us are equipped, at the time of manufacture or at a later date, with a device designed to connect to the internet (a “connected car”) and to allow us to send commands and receive certain information about the vehicle, including geolocation data provided by a global positioning system (GPS). If you rent a connected car from us, your personal information will be treated in accordance with this privacy notice and the privacy addendum for connected cars attached to the general terms and conditions of the rental (or any similar notice we may provide to you in the future).
PHOTOS AND VIDEOS
As indicated by signs in the relevant locations, Ideal rental locations are equipped with security CCTV systems as well as cameras that record our cars leaving/returning to our car park. The purpose of the security CCTV system and cameras is for the protection and safety of Ideal’s property as well as Ideal’s employees and customers. The legal basis is Ideal’s legitimate interest.
Below is a brief description of the basic conditions for video surveillance:
- The legal basis for the use of CCTV cameras is legitimate interest
- Brief description of the monitoring system – digital
- To whom the video can be passed on – police, Border Guard
- Who has access to monitoring systems and records – only those Ideal employees who need access to perform their job functions
- How long the data is stored – recordings are stored for 1 month, after a specified period of time the video system automatically starts overwriting the information
- Observation time – 24 hours a day
- Type of observation – recording with on-demand viewing
- What is done to protect the data collected by the monitoring system – the recordings are stored in the server room, with access to the persons listed above
- How a person can access the data collected about him or her – if you wish to access the data collected, please contact us at sales@avis.lt. When accessing the data, you should bear in mind that we only keep the records for 1 month, and also that we are obliged to keep the identity of other people in the records confidential in order to protect their rights and interests, so we cannot guarantee that you will be able to access the data straight away
DATA ON THE INTERNET
Ideal automatically collects technical information when you download, visit and use our websites and/or apps. This section explains more about what technical information we collect and why we collect it.
IP addresses and other automatically collected information: when you visit our websites, we may collect information about your IP address to help diagnose problems with our mainframe computers, for system administration purposes, to provide aggregate information to our business partners, and to audit the use of our website. We generally do not associate IP addresses with anything personally identifiable. In certain circumstances, we may use IP addresses to help us identify you if we believe it is necessary to enforce our website’s terms of use or to protect our services, website, users, or others. We may also collect information about your browser type, Internet Service Provider (ISP), landing/exit pages, files viewed on our site (e.g. HTML pages, graphical objects), operating system, date/time stamp and/or clickstream data to analyze trends and administer the site in aggregate.
Session replay: when you visit our website, we sometimes also record information about your browsing session, including which pages you have visited and what forms you have filled in on the website. We review this information to identify any technical problems with the operation of our websites and to improve the user interface on our websites. We work with third parties to assist in the context of this service and this information will be shared with such third party for this purpose but will not be disclosed to any other third party.
Cookies and other similar technologies: you can view details of how we use cookies in our Cookie Policy, available at https://www.avis.lt/cookie-policy
Mobile usage analytics: when you download and use our Avis, Budget and Payless car rental apps, we use mobile usage analytics software to better understand how our app works on your mobile device. Our analytics software may record how often you use the app, how you use the app, aggregated usage and performance data, and where you downloaded the app from. If you would like to know more about how we use information for research purposes, please see the Analytics section.
Mobile GPS and Push notifications: if you give us permission, when you use our Avis, Budget or Payless car rental apps, we may collect location markers using the GPS on your device. If we know roughly where you are, the app can provide you with a better service, for example by finding you the nearest Avis, Budget or Payless rental point. It also helps us to send you push and other notifications tailored to your location (for example, special offers nearby) in connection with the provision of certain services, such as arrival and return notifications, vehicle location information, possible updates, etc. We will only share this information with our map service provider for the purposes of providing our services. In order to ensure that you receive relevant notifications, we need to collect certain information about your device, such as your operating system and user identification information. If you change your mind and no longer wish to share your location or receive Push Notifications from the App, you can adjust your mobile device settings at any time to disable the transmission of geolocation data or stop receiving Push Notifications. However, please note that disabling these features will stop you from receiving information tailored to your location, as well as special location-specific offers.
ONLINE ADVERTISING
Ideal uses third party services that provide online or electronic advertising on our behalf. These third parties use data about your visits to our websites and use of our apps to send you tailored advertising that may be of interest to you. This information is collected through the use of cookies, scripts, pixel tags, ETags, web beacons and other technologies by Ideal and our third party advertising partners in accordance with our Cookie Policy.
MARKETING
Ideal may share personal information with third parties (as detailed in the “Information Sharing” section) who assist us with marketing and promotional projects, such as administering our social media pages, running contests, sweepstakes or other promotions, or sending promotional communications.
When we send you promotional communications, we will only use your personal information when you have consented to receive promotional communications, or when we are permitted to do so by applicable law. These promotional communications will be sent to you electronically or to your postal address.
Don’t want to receive promotional and marketing letters, emails and text messages from Ideal and our partners? No problem! You can withdraw your consent to direct marketing at any time or let us know that you do not want to receive such promotional communications. How to do this is set out in the section Your choices.
ANALYSIS
We use analytics software such as Adobe Analytics, Google Analytics and others to better understand how our software works on our websites and apps on your device. These software tools record technical information about your device, as well as usage information such as how often you use our website or app, which features of the website or app you do or do not use, which pages of the website you visit, where you downloaded the app from, and information about your visit to the website, including some universal address clickstream data to, on and from our website. For more information about these measures, please see our Cookie Policy.
Want to know what happens when you visit our websites or use our apps? You can find out more in the Online Data section.
VAIKAI
Ideal’s websites, apps and services are not directed at children under the age of 16. This includes any links to other websites that we provide for your convenience. We do not knowingly collect personal information from children for any reason. If you believe that Ideal has obtained personal information from your child or another minor, please contact us at the address listed in the Data Controller Contact Information section.
INFORMATION SHARING
Ideal may use and share your personal information and vehicle data as described below:
| Third country beneficiary | Purpose of disclosure | Legal basis for processing |
| Companies within the Avis Budget Group, Inc. and Osaühing Ideal Baltic groups of companies – to fulfil our contract with you and to understand your use of our services and to improve our performance |
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| Travel agents – to fulfil our contract with you when you use travel agents, to understand how you use our services and to improve our performance |
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| Your employer or organisation – to enable you to take advantage of the programme for companies or associations, to understand how you use our services and to improve your performance |
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| Brokers – to fulfil our contract with you when you book a rental through them, and to protect our business from fraud and debt |
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Booking systems – to fulfil our contract with you when you use our booking systems, to understand your use of our services and to improve our performance |
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| Credit card issuers – to receive payment from you |
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| Business Account Manager – to enable you to take advantage of the programme for companies or associations, as well as to understand how you use our services and to improve your performance | If you rent through a company, membership or similar account with a commercial organisation, we may share personal information with the organisation that manages the account for its own purposes. We recommend that you review the company’s privacy policy to learn more about its privacy practices. |
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| Advertising agent – to enable you to take advantage of the programme for companies or associations, as well as to understand how you use our services and improve your performance |
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| IT service providers, including IT platform providers and web analytics providers – to fulfil our contract with you and to understand how you use our services and to improve our performance |
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| Government, regulators and law enforcement – to meet our legal obligations |
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| Parking service providers and car park operators |
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| Insurance companies and claims investigators – for any insurance product you bought with your rental |
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| Professional advisers, including legal and financial advisers |
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| Other service providers, to the extent reasonably necessary to provide specific services (e.g. postal service providers, couriers) or to ensure business continuity (e.g. accounting service providers, debt collection service providers) |
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We may also transfer or assign your personal information to third parties in the event of a sale, merger, consolidation, change of control, transfer of assets, bankruptcy, reorganisation or liquidation of the company. If we are defending legal claims, information about you relating to such claims may be disclosed to third parties in the course of related legal proceedings.
In accordance with the provisions set out in the Marketing section, we may share your information with business and advertising partners (if you have consented to the sharing of information) to send you information about products and services that may be of interest to you. If you decide that you no longer wish to receive such promotional and marketing communications, please read the section on Your Choices to learn how you can opt out.
YOUR CHOICES
If you wish to opt-out of receiving promotional and marketing emails, text messages, mailings and other forms of communications from Ideal or our advertising partners that you may receive under the Marketing section, it is best to do so in one of the following ways:
- Log in to your account and update your profile.
- At the bottom of the email sent to you, click on the “Unsubscribe” link.
- Please write to our customer service representative at the email address provided in the Data Controller Contact Information section.
If you opt-out of receiving promotional and marketing messages, we may still contact you about our business relationship with you, such as updates on your account status and activity, requesting to participate in surveys about products and services provided to you after you have rented from us, confirming a reservation or responding to your queries or complaints, and sending similar communications.
Would you like to close your account, terminate your business relationship with Ideal, or otherwise opt-out of Ideal’s collection, use or disclosure of your personal information? We will be sorry if you wish to leave us. Please contact our customer service representatives, whose contact details can be found in the Data Controller Contact Information section.
Please also review your rights, which are set out in the section Your privacy rights.
PROTECTIVE MEASURES
The security of your personal information is important to us. We take reasonable steps to ensure that your information is protected from unauthorised use, access, disclosure, alteration, destruction or loss. We use firewalls and Transport Layer Security (TLS) encryption for financial and payment information. We take security very seriously, but because no system is 100% secure, we cannot guarantee (any more than any other organisation could) that your personal information will be protected.
We do not ask for financial or payment information, such as your credit card number, password, account number or PIN, in the emails, text messages or other communications we send you. Always check to see if any website that asks you for financial or payment information in connection with our rentals or services is operated by Avis Budget Group, Inc. or affiliated companies. If you receive a suspicious request, please do not provide your information and report it by contacting any of our customer service representatives, whose contact details can be found in the Data Controller Contact Information section.
It is your responsibility to keep your account access password, membership numbers and PINs safe and secure. Do not disclose them to anyone. In the event of unauthorised use or any other breach of security involving your information, you must notify us as soon as possible using the Customer Service contact details below.
STORAGE OF INFORMATION
Ideal will keep your personal information for no longer than is reasonably necessary or required by law. How long we keep it depends on the type and purpose of the information.
The criteria we use to determine the retention period for certain categories of data are as follows:
- how long you have been a member of Avis Preferred or any of our other loyalty programmes, or any programme for companies;
- how often you rent from us or when you last rented from us;
- whether there are contractual or legal obligations that oblige us to keep the data for a certain period of time;
- whether there are any legal proceedings relating to the lease you have entered into with us or otherwise relating to the relationship between us and you;
- or any applicable law, statute or regulation permits the retention of data for a specified period of time;
- whether personal information is considered special categories of personal information, in which case a shorter retention period usually applies;
- what the storage expectations were at the time the data was provided to us.
INTERNATIONAL FORWARDING
Rent
As we offer the possibility to rent a vehicle and use our services in many locations around the world, we will share your personal information with our affiliates, Avis Budget Group, Inc. and travel agents in those locations in order to fulfill your rental request and/or enter into a rental agreement. The exact location where your personal data will be transferred depends on the rental location. A list of these locations can be found on our website at https://www.avis.lt/drive-avis/car-hire-locations
Many of the non-EU countries to which your personal information may be transferred for these purposes are not subject to an EU Commission Decision on the adequate level of protection of personal information in that country. Details of these specific countries can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
Such a transfer is made either because it is necessary for the performance of a contract to which you will be a party or for pre-contractual reasons. Alternatively, an adequate level of data protection is further ensured by the standard data protection terms and conditions that we have established for the recipients concerned. A copy of these standard data protection terms and conditions can be obtained by contacting the Data Controller at the address indicated in the contact details.
Business activities
In addition, the information we collect from you may be transferred to and stored by IT service providers acting on our behalf. In particular, this includes our reservation system hosting provider located in the United States of America. We also transfer information to a number of providers of business applications – such as CRM and marketing applications – and marketing service providers. These providers are mainly based in the United States.
In the United States, the EU Commission’s decision on the protection afforded to personal information does not apply. Instead, an adequate level of data protection is ensured by the standard data protection terms we have established for third parties. A copy can be obtained by contacting the Data Controller’s contact information at the address provided.
As our business is global, we also share information with Avis Budget Group, Inc. and Osaühing Ideal Baltic group companies, as the group uses common IT functions for certain activities. Information sharing for these purposes from the European Union is mainly to the United States of America, although information may also be transferred to other countries. The United States and many other countries outside the European Union are not subject to the EU Commission’s decision on the appropriate level of protection of personal information in that country. Therefore, an adequate level of data protection is ensured by the standard data protection terms and conditions that we have established for recipients. A copy can be obtained by contacting the Data Controller’s contact details at the address provided.
YOUR PRIVACY RIGHTS
You may have the following rights under applicable data protection laws in relation to the processing of your personal information.
- Right of access to information – You may have the right to request a copy of the personal information we hold about you, as well as additional information explaining how the personal information is used.
- Right to rectification – you may have the right to ask us to correct inaccurate personal information about you.
- Right to Remove – You may have the right to ask us to remove personal information about you.
- Right to restrict processing – In some cases, you may have the right to request that we do not use personal information that you have provided (e.g. if you believe it is inaccurate).
- Right to data portability – You may have the right to receive certain of your personal information in a structured, commonly used and machine-readable format, and to transfer such information to another controller.
- Right to withdraw consent – where we process your personal information on the basis of your consent (including consent for direct marketing), you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of processing based on consent that took place prior to the withdrawal of consent. In addition, even in the event of withdrawal of consent, we may continue to use your personal information to the extent permitted or required by law.
- Right to object – where we process your personal information on the basis of our legitimate interests or those of third parties, you may object to this. However, we may have the right to continue to process your information on the basis of our legitimate interests or where it is related to legal requirements. You also have the right to object to our processing of your personal information for direct marketing purposes.
- Please contact us at the address listed in the Data Controller Contact Information section if you wish to exercise any of these rights or if you have any questions about how we process your personal information. You may also lodge a complaint with the supervisory authority, the State Data Protection Inspectorate, vdai.lrv.lt/, if you believe that we are processing your personal information in violation of applicable law.
CONTACT DETAILS OF THE CONTROLLER
UAB “LITIDEAL”
Legal entity code: 111444388
Address: 3, Laisvės pr., Vilnius, LT-04215
E-mail: sales@avis.lt