Privacy policy
Updated 27 October 2026. This is a translation; the Lithuanian version prevails.
This privacy policy (the Privacy Policy) describes how RG top, UAB and the related Real Game companies (Real Game or we) process the data of clients, partners, suppliers, visitors of the website realgame.lt (the Website) and other persons. We explain what data we collect, on what legal basis and for what purposes we use it, how long we keep it, to whom we disclose it and what rights you have.
1. Data controller
| Name | RG top, UAB |
|---|---|
| Company code | 306190673 |
| Address | J. Tiškevičiaus g. 9-15, LT-02231 Vilnius, Lithuania |
| start@realgame.lt |
RG top, UAB controls the data collected on the Website and through its forms, and the Real Game client relationship management system (CRM). If your enquiry concerns a service of a specific Real Game company, RG top, UAB passes it to that company, which then processes the data as a separate controller:
| Company | Code | |
|---|---|---|
| Real Game, UAB | 304169424 | am@realgame.lt |
| Real Game Kaunas, UAB | 300638290 | ea@realgame.lt |
| Real Game Industry, UAB | 305077651 | ts@realgame.lt |
| Real Game Management, UAB | 305636329 | dk@realgame.lt |
We process personal data in accordance with Regulation (EU) 2016/679 (the GDPR) and the laws of the Republic of Lithuania. Terms have the meaning given in the GDPR. The Website may be used, and data provided to us, only by persons aged 18 or over.
2. What data we process and why
2.1. Enquiries via the Website and by email
| Who | Persons who fill in the contact form, email, call or otherwise contact Real Game. |
|---|---|
| Data | Name, company, purpose of the enquiry (to lease, buy, sell, etc.), phone number or email address, content of the enquiry, date and time. |
| Legal basis | Legitimate interest in replying to the enquiry (GDPR Art. 6(1)(f)); where the enquiry relates to a contract, steps prior to entering into a contract (GDPR Art. 6(1)(b)). |
| Retention | Up to 1 year from receipt. If the enquiry leads to a contractual relationship, the periods in section 2.2 apply. |
2.2. Contracts with clients, partners and suppliers
| Who | Clients, service providers, suppliers, partners, subcontractors and their representatives (including prospective ones). |
|---|---|
| Data | Name / company name, position, contact details, information on the relationship and correspondence, payment data and, where needed, qualification documents. |
| Legal basis | Entering into and performing a contract (GDPR Art. 6(1)(b)) or legitimate interest in maintaining business relations (GDPR Art. 6(1)(f)). |
| Retention | According to the Lithuanian General Document Retention Index: contracts and accounting documents for 10 years, cooperation documents and correspondence for 5 years. |
2.3. Client relationship management (CRM)
| Who | Clients, prospective clients, tenants, buyers, owners and their contact persons. |
|---|---|
| Data | Name, company, position, work contact details, notes from meetings and calls, interest in properties, deal progress. Company data may be supplemented from public registers. |
| Legal basis | Legitimate interest in carrying out and developing real estate advisory and brokerage activities (GDPR Art. 6(1)(f)). |
| Retention | For the duration of the business relationship and 3 years after the last contact, unless the law requires a longer period. |
2.4. Confidential property information
| Who | Persons requesting confidential information on properties for sale or lease. |
|---|---|
| Data | Name, company, email, confirmation of the confidentiality undertaking, date and time. |
| Legal basis | Legitimate interest in protecting clients' confidential information (GDPR Art. 6(1)(f)). |
| Retention | Until the end of the transaction and 3 years thereafter. |
2.5. Know your customer (KYC)
| Who | Clients, their representatives, shareholders and beneficial owners. |
|---|---|
| Data | Identity data, citizenship, personal identification number, ID document details and copy, information on politically exposed persons, transaction value, source of funds, links to sanctioned persons. |
| Legal basis | Legal obligation under the Law on the Prevention of Money Laundering and Terrorist Financing and the Law on International Sanctions (GDPR Art. 6(1)(c)). |
| Retention | 8 years after the end of the business relationship; up to 2 years longer at the instruction of a competent authority. |
2.6. Recruitment
| Who | Candidates for positions at Real Game. |
|---|---|
| Data | CV, contact details, education, work experience, cover letter, selection assessments. |
| Legal basis | Legitimate interest in selecting employees (GDPR Art. 6(1)(f)) or steps at your request prior to an employment contract (GDPR Art. 6(1)(b)). |
| Retention | During the selection and 3 years thereafter. |
2.7. Legal claims
We may process all of the above data to establish, exercise or defend legal claims (GDPR Art. 6(1)(f)), until the relevant proceedings end and for 1 year after the final decision.
We do not send newsletters. The Website does not use analytics or advertising cookies; see our Cookie policy.
3. Who we share data with
We may share data with related Real Game companies to the extent needed to provide a service. RG top, UAB provides them with data protection, KYC and IT services and therefore also acts as their processor.
We use the following service providers (processors):
| Provider | Service | Data location |
|---|---|---|
| Netlify, Inc. | Hosting of the Website and CRM, receipt of contact form enquiries | USA |
| Supabase, Inc. | CRM database and sign-in | EU (Frankfurt) |
| Google (Google Workspace) | Email, calendar, document storage, staff sign-in with Google | EU / USA |
| Anthropic (Claude) | AI assistant used by staff to work with emails, documents and the CRM | USA |
Data may also be received by banks, accounting, legal and other professional advisers, courts, the State Tax Inspectorate, the Financial Crime Investigation Service and other authorities where required by law, and by potential acquirers in the event of a reorganisation or business transfer of Real Game.
4. Transfers outside the EU / EEA
Where service providers process data in the USA, the transfer is based on the European Commission's decision on the EU-US Data Privacy Framework and/or standard contractual clauses. Providers' data processing terms: Netlify, Supabase, Google, Anthropic.
5. Security
We apply technical and organisational measures: encrypted connections (HTTPS), role-based CRM access for authorised staff only, and regular review of access rights. However, no method of transmission or storage is completely secure.
6. Your rights
- To be informed and to access your data, and to receive a copy.
- To have inaccurate data corrected or incomplete data completed.
- To have your data erased ("right to be forgotten") where there is no longer a basis for processing.
- To restrict processing.
- To receive your data in a machine-readable format and transfer it to another controller.
- To object to processing based on legitimate interest.
- To withdraw consent where processing is based on consent.
- To lodge a complaint with the State Data Protection Inspectorate (L. Sapiegos g. 17, LT-10312 Vilnius, ada@ada.lt, vdai.lrv.lt).
Send requests to start@realgame.lt. We reply within 1 month; in complex cases this may be extended by 2 more months and we will let you know. We may ask you to confirm your identity.
7. Changes
We may change this Privacy Policy. The new version is published on the Website; we will inform you separately about material changes.
8. Liability and intellectual property
Information on the Website is for information purposes only and is not an offer to enter into a transaction. The Website content, design, code, trademarks and databases belong to Real Game (except partners' marks) and are protected by intellectual property law. They may not be copied, distributed or otherwise used without Real Game's written permission.