2. Personal data collection and purposes of its processing
2.1. Personal data is information about the Customer collected by the Seller, submits by the Customer, necessary to comply with the terms of the concluded agreement, as well as for further contact with the Customer.
2.2. The Seller processes personal data applying following legal bases:
- to sign and fulfil the contract with the Customer;
- to comply with relevant regulatory acts – to fulfil requirements specified by the applicable regulatory acts;
- in accordance with consent given by the Customer;
- for the purposes of the legitimate interests pursued by the Seller.
2.3. Personal data are collected by the Seller providing contact information (name, surname, postal address, e-mail address, phone number, birthday data, bank accounts, purchase and search history) on the website by Customer, as well data related to the website usage and information contained in the cookie files
2.4. All Customer’s personal data are confidential except cases described in regulatory enactments.
2.5. The Seller also collects other information that is not relevant to a particular person — gender, age, language, country of residence — and is collected solely for statistical purposes.
2.6. Personal data are processed by the Seller for following purposes:
- to provide services;
- to identify customer;
- to prepare and sign contracts;
- to maintain service;
- to fulfil warranty conditions;
- to improve existing services and for new business development;
- to advertise and sell services for commercial purposes;
- for customer service;
- to review and process customer claim requests;
- for customer retention and customer loyalty and experience surveys;
- to issue and administer invoices;
- for collection of account receivables (unpaid invoices);
- to maintain and enhance the website.
- For Business planning and analytics:
- for business analytics and statistics;
- for planning and metrics measurements;
- for key performance indicator measurements;
- to ensure data quality and integrity;
- for market research and consumer surveys;
- for reporting purposes;
- for risk assessment activities;
- to provide information requested by government institutions in compliance with law.
2.7. Personal data might be used by the Seller to inform the Customer about the products, events and news related to the Internet site. These notifications sent per email to the Customer always includes the opt out link.
2.8. The Customer has rights to opt out if he or she does not want to receive further notifications about products, campaigns and news. The Seller ceases sending further notification, as soon as the customer has opted out.
2.9. The Customer’s data are used for delivery of goods and fulfilment of obligations arising from the purchase contract, as well to assure legitimate interests of the Seller. Seller’s legitimate interests are:
- To conduct business;
- To check Customer’s identity before signing the contract;
- To ensure fulfilment of the contract;
- To mitigate financial risks;
- To store customer inquiries and applications related to the service, other inquiries and applications, notes and remarks incl. verbal agreements and agreements communicated per email;
- For Website analytics, usage, develop and implement improvements;
- For activities to retain customers;
- Develop and enhance services;
- To advertise services;
- To communicate contract fulfilment status updates and relevant deadlines and events;
- To carry out surveys related to the delivered services and customer experience;
- To avoid fraud;
- To ensure corporate governances, finance and business process reporting and analytics;
- To ensure effective management of business processes;
- To ensure effectiveness of service delivery;
- To ensure and improve quality of services;
- For account receivable collections;
- To defend legitimate and legal interest at government institutions;
- To inform community about business and activities.
2.10. Customer communication
- The Seller communicates with the Customer using contact data provided by the Customer (phone number, email address, postal address).
3. Storage period of personal data
3.1. The Seller will store personal data, until at least one criteria listed below applies:
- As long as contract with the Customer or other service contract is valid, that is legal bases for personal data processing;
- As long as the Seller or the Customer can claim their legitimate interest in accordance with the applicable regulatory acts (e.g., submit complaint or initiate or conduct juridical proceeding in a court);
- as long as the Seller legally is required to store personal data;
- as long as there is Customer’s consent to store and process the data and there is no other legitimate rationale to process the data.
3.2. If none of the criteria listed above in point 3.1 are not valid anymore, the personal data are being securely and irretrievably deleted.
4. Security and Safety of personal data
4.1. The Seller processes the Customer data applying current technological capabilities, considering privacy breach risks and reasonable organizational, financial and technical resources. It includes technical measures as:
- Data pseudonymization and encryption techniques if feasible;
- Security breach prevention and detection software
- Other safety and security measures in line with current technological capabilities.
4.2. The Seller uses secure data systems, in particular of the risks that are presented by processing to protect Internet site user’s data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data.
4.3. Access to the personal data submitted by the Customer on the Internet site is restricted to specially authorized Seller’s employees.
4.4. In order to deliver the service effectively, the Seller might authorize business partners to deliver specific service delivery activities as for example, goods delivery, warranty services or invoicing activities, website maintenance etc. The business partners are considered as data processors and the Seller has rights to provide to them Customer’s personal data that are required to fulfil their services.
4.5. Business partners of the Seller use the personal data only to fulfil contractual liabilities on behalf the Seller and process the personal data according to the instructions from the Seller, and fully comply with regulatory acts.
5. The recipients or categories of recipients of the personal data
5.1 The Seller does not disclose to the third parties personal data or any other information collected during the service delivery, except:
- if data has to be provided to the third party to ensure service fulfilment or it is regulated by law (e.g. bank wire transfers);
- in accordance with freely given, specific, informed and unambiguous consent from data subject;
- to the persons specified in the applicable regulatory acts, after their request, in accordance with the regulatory acts;
- in situations specified in regulatory acts. As well protecting legitimate interests of the Seller, e.g., by initiating juridical proceeding against the subject that has violated legitimate interests of the Seller.
6. Access rights of the data subject
6.1 Customer data can be viewed on the Internet site, in the section My Account.
6.2 The Seller ensures the accuracy of the Customer data collected.
6.3 The Customer have to inform the Seller about changes of his or her personal data, via the e-mail email@example.com.
6.4 Data subject has rights in accordance with the applicable regulatory acts to request and to receive information related to his or her personal data processing, to ascertain the correctness of his or her personal data and to correct the personal data.
6.5 Data subject has rights in accordance with the applicable regulatory acts to request access to his or her personal data, and to request additions, corrections, deletion or transfer of personal data. Data subject has rights to request transfer, restrictions or prohibition of his or her personal data processing (incl. restriction of prohibitions of data processing which is done due to legitimate interests of the Seller). These rights of the data subject are satisfied by the Seller, if the request is specified in the regulatory acts as the obligation of the Seller.
6.6 Data subject can submit his or her request:
- in written form sent by post or in presence at legal address of the Seller by showing identification document;
- by securely signed electronical document sent by e-mail;
6.7 After receiving the request, the Seller checks identity of the requestor, evaluates the requests and executes it in accordance with the applicable regulatory acts. The Seller provides reply to the data subject by post at indicated contact address per registered letter.
6.8 The Seller ensures fulfilment of the data processing and data safety request in accordance with the applicable regulatory acts and in case of complains, takes appropriate actions to resolve complains. If complains cannot be resolved, the requestor has right to claim at the supervisory authority – Datu Valsts Inspekcija of Latvia.
7. Using Internet Protocol addresses
7.1 An IP address is a set of numbers that are automatically assigned to a computer every time a user connects to the Internet service provider. The IP address can automatically identify the user’s computer.
7.2 The Seller can collect IP addresses for system administration and website audit purposes. The Seller does not intend to add a user’s IP address to his or her personally identifying information, which means that every user’s session is registered, but the user himself remains anonymous.
8.1 Cookies are small files which are stored on a user's computer. They are designed to hold a modest amount of data specific to a particular client and website, and can be accessed either by the web server or by the client’s computer. This enables the server to deliver a page tailored to a particular user. Cookies do not contain any personally identifying information, however if user provides such information himself, information can be combined with the data contained in the cookies.
8.2 User can enable or disable cookies, however disabling cookies the site loses full functionality.
- To ensure functionality of the website;
- Adjust website’s content according to the user’s previous preferences, e.g. language, search and content history;
- To collect statistics on usage frequency, duration etc.;
- To authenticate the user.
8.4 If cookies are not required to ensure website functionality they are erased.
8.5 Enabling and disabling cookies:
Opening the website user receives notification window informing that website is using cookies. Closing the notification windows user accepts that he or she have acknowledged information about cookies, purpose of their usage, and when information is passed to the third parties.
8.6 User acceptance by enabling cookies asserts Seller’s rights to use information collected by cookies.
8.7 Usage of cookies are required to use the website and to fulfil the contract with the customer, or to carry out legitimate interests of the Seller.
8.8 Each internet browser allows through settings to restrict or erase cookies. However, the website will not function properly if cookies are disabled. We suggest enabling cookies in order to ensure full functionality of the website.
9. Binding conditions
11. Dispute resolution
Any dispute between the Parties arising out of the policy shall be settled in plaintiff’s discretion in the courts of the Republic of Latvia.