The purpose of this Privacy Policy is to provide to a natural person - the customer of the Limited Liability Company Attēls R (hereinafter referred to as - Attēls R) - information about the purpose, volume, protection of the personal data processing, processing period and rights of the data subject during the acquisition of data, as well as when processing the personal data of the customer.
THE OPERATOR AND ITS CONTACT INFORMATION
1. The operator of the personal data processing shall be the Limited Liability Company Attēls R (registration number 40003326540, legal address Maskavas iela 454C, Riga, LV-1063).
2. The contact information of the company Attēls R on the matters related to personal data processing shall be: vdar@attelsr.lv. Questions regarding the personal data processing may be asked by using this contact information. The request for use of your rights may be submitted in accordance with Paragraph 22.
AREA OF APPLICATION OF THE DOCUMENT
3. Personal data shall mean any information regarding identified or identifiable natural person (data subject). Personal data categories are specified here.
4. The privacy policy is applied in order to ensure privacy and personal data protection with regards to:
• natural persons – customers and other buyers of goods and service users of the company Attēls R (including the potential, former and current ones), as well as third persons, who receive or delivers any information (including, contact persons, payers etc.) to the company Attēls R with regards to product delivery or service provision to a natural person (customer, user); persons, who turn to the company Attēls R with any kind of request or claim, submits any kind of document, contacts with the company Attēls R in presence or by using remote communication means, including mail or e-mail;
• visitors of stores, offices and other premises of the company Attēls R, visitors of the events organized by the company Attēls R, including with regards to whom video surveillance is performed;
• visitors of websites and mobile applications maintained by the company Attēls R and persons calling to the contact phones of the company Attēls R (hereinafter - the Customers).
5. The company Attēls R takes care for the privacy and personal data protection of the Customers, complies with the right of the Customers to lawfulness of personal data processing in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (Regulation) and other applicable legal acts in the area o privacy and data processing.
6. The Privacy Policy shall refer to data processing regardless of the fact in what form and/or environment the Customer provides his or her personal data (on the website, mobile applications, e-commerce portal of the company Attēls R, in a paper form or via phone) and in what systems of the company or paper form they are processed.
7. Additional and specific conditions may be determined with regards to specific data processing types (such as processing of cookies etc.), environment, purposes, regarding which the Customer shall be informed at the moment, when he or she provides the relevant data to the company Attēls R.
PURPOSES OF THE PERSONAL DATA PROCESSING
8. The company Attēls R processes the personal data for the following purposes:
• provision of services and sale of goods:
- identification of the customer;
- preparation, conclusion of the agreement and proving of the fact of conclusion;
- product delivery and provision of services (fulfilment of contractual liabilities);
- fulfilment of guarantee liabilities;
- improvement of products and services, development of new products and services;
- promotion, advertising and distribution of the service use and product sale;
- customer service;
- review and processing of submissions and objections;
- maintaining of customers, loyalty increase, satisfaction measurements;
- administration of payments;
- assessment of creditworthiness, supervision of the fulfilment of liabilities;
- recovery of debts;
- maintenance of websites and mobile applications and improvement of operation;
• business planning and analytics:
- statistics and business analysis;
- planning and accounting;
- measuring of effectiveness;
- data quality provision;
- performance of market and public opinion research;
- preparation of reports;
- performance of customer surveys;
- within the framework of risk management activities;
• security provision of the information, information systems and company;
• provision of information to the state administration authorities and subjects of investigatory operations in the cases and in the scope determined by external regulatory enactments;
• for other specific purposes, regarding which the Customer shall be informed at the moment, when he or she provides the relevant data to the company Attēls R.
LEGAL GROUND FOR PERSONAL DATA PROCESSING
9. The Company Attēls R processes personal data of the Customer, on the basis of the following legal grounds:
• for conclusion and execution of the agreement - in order to conclude the agreement on the basis of the application of the Customer, and ensure the fulfilment thereof;
• for execution of regulatory enactments - in order to perform the duty determined by external regulatory enactments, binding to the company Attēls R;
• in accordance with the consent of the Customer - data subject;
• for legitimate interests - in order to implement the legitimate interests, arising from the liabilities existing between the company Attēls R and the Customer or the concluded agreement, or law;
• for provision of vital interests of the data subject or any other natural person - in order to ensure physical and property safety of persons employed by the company Attēls R, Customers and visitors.
10. The legitimate interests of the company Attēls R are:
• to perform commercial activity;
• to examine the identity of the Customer before conclusion of the agreement;
• to ensure fulfilment of contractual liabilities;
• to prevent unreasonable financial risks for its commercial activity (including to perform credit risk assessment before sale of products and services and during the fulfilment of the agreement);
• to save applications and submissions of Customers regarding purchase of products and provision of services, other applications and submissions, notes on them, including the ones that are made in writing or verbally by calling to the contact phone, on the websites and e-commerce portal;
• to analyze the operation of websites, online sites and mobile applications of the company Attēls R, to develop and introduce improvements thereof;
• to administer Customer's account on the websites, online sites and mobile applications of the company Attēls R;
• to perform activities for retention of Customers;
• to segment the customers data base for more effective provision of services and products;
• to create and develop products and services;
• to advertise our products and services;
• to send other notifications regarding the course of fulfilment of the agreement and significant events for fulfilment of the agreement, regarding requests for products and services, as well as to perform Customer surveys regarding products and services and usage experience thereof;
• to avoid fraud;
• to ensure effective company management processes;
• to ensure effectiveness of service provision, product sale and delivery;
• to ensure and improve service quality;
• to administer payments;
• to administer non-performed payments;
• to turn to the state administration and investigatory operations authorities and court for protection of our legal interests;
• to inform public on our activity.
PERSONAL DATA PROCESSING
11. The company Attēls R may perform automated decision making with regards to the Customer. The Customer shall be informed on such activities of the company Attēls R separately, in accordance with the regulatory enactments. The Customer may object to automated decision making in accordance with legal acts, however being aware of the fact that in certain cases it may restrict the rights of the Customer to use certain possibilities potentially available for him or her (for example, to receive commercial proposals).
12. Automated decision making, causing legal consequences to the Customer (such as approval or rejection of the application of the Customer) may be performed only during the course of conclusion or execution of the agreement between the company Attēls R and the Customer, on the basis of explicit consent of the Customer, or in cases determined by external regulatory enactments.
13. In order to ensure high quality and operative fulfilment of liabilities of the agreement concluded with the Customer, the company Attēls R may authorise its cooperation partners to perform certain product delivery or service provision activities, such as performance of transportation, sending of invoices and letters etc. If during the performance of such assignments, the cooperation partners of the company Attēls R process the Customer's personal data, being at the disposal of the company Attēls R, the relevant cooperation partners of the company Attēls R shall be considered as the data processing operators of the company Attēls R (processors), and the company Attēls R shall have the right to deliver the Customer's personal data necessary for cooperation partners of the company Attēls R for performance of such activities to the extent it is necessary for performance of such activities.
14. Cooperation partners of the company Attēls R (in the status of the personal data processor) shall ensure the fulfilment of the requirements for processing and protection of personal data, in accordance with the requirements of the company Attēls R and legal acts, and shall not use the personal data for any other purposes than only for fulfilment of liabilities of the agreement concluded with the Customer on the assignment of the company Attēls R.
PERSONAL DATA PROTECTION
15. The company Attēls R shall process the Customer's data by using the possibilities of modern technologies, considering the existing privacy risks and organizational, financial and technical resources reasonably available for the company Attēls R.
CATEGORIES OF PERSONAL DATA RECIPIENTS
16. The company Attēls R shall not disclose to third persons any Customer's personal data or any other information, which is acquired from provision of services, product delivery and during the validity period of the agreement, except:
• if data are to be delivered to the relevant third person within the framework of the concluded agreement, in order to perform any function necessary for fulfilment of the agreement or delegated by law (for example, to the bank within the framework of settlement of accounts, for accounting);
• in accordance with clear and explicit consent of the Customer;
• to persons provided for in the external regulatory enactments pursuant to their reasonable request, in accordance with the procedure and in the amount prescribed by external regulatory enactments;
• in cases determined by external regulatory enactments for protection of legitimate interests of the company Attēls R, for example, when turning to the court or any other public authorities against the person, who has violated the legitimate interests of the company Attēls R.
THIRD COUNTRY ACCESS TO PERSONAL DATA
17. In certain cases, in compliance with the requirements of regulatory enactments, the developers or service providers located in third countries (that is, countries outside of the European Union and the European Economic Area) may have access to the personal data of the company Attēls R (for the purpose of the Regulation - transfer to third countries) in the status of a data processor (operator).
18. In such cases the company Attēls R shall ensure procedures determined in regulatory enactments for provision of the level of the personal data protection and protection, which is equal to the one stipulated in the Regulation.
DURATION OF STORAGE OF PERSONAL DATA
19. The company Attēls R shall store and process the personal data of the Customer as long as at least one of the following criteria exists:
• only as long as the agreement concluded with the Customer is in force;
• data are required for the purpose they were received for;
• as long as the company Attēls R or the Customer may implement its legitimate interests (for example, submit objections or raise or handle the claim in a court) in accordance with the procedure prescribed by external regulatory enactments;
• as long as a legal obligation exists for any of the parties to store data (for example, in accordance with the Accounting Law, the issued invoices shall be stored for 5 years, etc.);
• as long as the consent of the Customer for the relevant personal data processing is in force, unless any other legal ground for processing of data is existing.
Afterwards, when the circumstances referred to in this paragraph cease to exist, the Customer's personal data shall be erased. Auditing records shall be stored for at least one year from the day of making thereof, in accordance with the provisions of regulatory enactments.
ACCESS TO PERSONAL DATA AND OTHER RIGHTS OF THE CUSTOMER
20. A Customer shall have the right to receive information set forth in regulatory enactments in relation to his or her data processing. The majority of Customer's information is already placed on the e-commerce portal attelsr.lv and online sites and applications of the company Attēls R, which the Customer uses for receipt of the services of the company Attēls R and acquisition of products and where the Customer could make sure on the correctness of his or her data and manage them, in case of need, including to change.
21. A Customer, in accordance with regulatory enactments, shall have the right to request to the company Attēls R for access to his or her personal data, as well as to request the company Attēls R to perform supplementation, modification or erasure thereof, or restriction of processing with regards to the Customer, or the right to object against processing (including against personal data processing, which was performed on the basis of legitimate interests of the company Attēls R), as well as the right to data portability. Such rights shall be implemented to the extent the data processing does not follow from the obligations of the company Attēls R, imposed to it pursuant to effective regulatory enactments, and which are performed in public interests.
22. A Customer may submit a request regarding exercise of his or her rights:
• in writing in presence at the stores or legal address of the company Attēls R, upon presenting the personal identity document;
• in the form of electronic mail by signing with a safe electronic signature.
23. Upon receiving the Customer’s request regarding exercise of his or her rights, the company Attēls R shall make sure on the identity of the Customer, assess the request and execute it in accordance with the regulatory enactments.
24. The company Attēls R shall send a reply to the Customer via mail to the contact address specified by him or her via registered mail or taking into account the type of receipt of the reply specified by the Customer.
25. The company Attēls R shall ensure performance of data processing and protection requirements, in accordance with the regulatory enactments, and in case of objections of the Customer shall perform useful activities in order to settle the objection. However, if it is not possible, the Customer shall be entitled to turn to the supervisory authority – the State Data Inspectorate.
CUSTOMER’S CONSENT TO DATA PROCESSING AND THE RIGHT TO REVOKE IT
26. A Customer may give his or her consent for personal data processing, the legal ground of which is consent (for example, data analysis of habits of service use, individually prepared advertisement etc.), by performing authorisation on the e-commerce portal attelsr.lv, on portals and applications of the company Attēls R, by calling to the contact phone of the company Attēls R or in presence in the stores of the company Attēls R.
27. A Customer has the right at any time to withdraw the consent given for data processing by calling to the contact phone of the company Attēls R, sending an e-mail to the address vdar@attelsr.lv or in the presence in the stores of the company Attēls R, and in such a case the further data processing that was based on the previously given consent for the particular purpose, will be terminated within three working days after the day of withdrawal.
28. Withdrawal of the consent shall not affect data processing that was performed at the time, when the consent of the Customer was in force.
29. Upon withdrawal of consent, the data processing that is performed on the basis of other legal grounds shall not be terminated.
COMMUNICATION WITH THE CUSTOMER
30. The company Attēls R communicates with the Customer by using the contact information specified by the Customer (phone number, e-mail address, mail address).
31. The company Attēls R performs communication regarding fulfilment of contractual liabilities on the basis of the concluded agreement (for example, information regarding fulfilment of the order, information about invoices etc.).
COMMECIAL NOTICES
32. The company Attēls R performs communication on such commercial notices that are not related to the services and products of the company Attēls R and other services related to direct provision of agreed liabilities (such as customer surveys) in accordance with the provisions of external regulatory enactments or in accordance with consent of the Customer.
33. A Customer may give his or her consent for receipt of commercial notices of the company Attēls R and/or cooperation partners thereof on the service portals/ applications of the company Attēls R, websites of the company Attēls R and other websites (for example, subscription forms for receipt of news).
34. A consent given by the Customer for receipt of commercial notices shall be in force until withdrawal thereof (also after expiry of the agreement on service or product delivery).
A Customer may at any time withdraw from further receipt of commercial notices in any of the following forms:
• by sending an e-mail to the address vdar@attelsr.lv;
• by calling to the contact phone of the company Attēls R 67844873;
• in presence at the stores of the company Attēls R;
• by using the automated possibility to withdraw from receipt of further notices, provided for in the commercial notice, by clicking on the withdrawal reference at the end of the relevant commercial notice (e-mail).
35. The company Attēls R terminates sending of commercial notices as soon as the Customer’s request is being processed. Processing of the request depends from the technological possibilities, which may last up to seven days and nights.
36. When showing his or her opinion in surveys and leaving his or her contact information (e-mail, phone), the Customer agrees that the company Attēls R may contact with him or her due to the assessment provided by the Customer, by using the contact information left by the Customer.
WEBSITES VISITS AND USE OF COOKIES
37. Cookies may be used on websites and online services of the company Attēls R. A cookie is a simple text file, saved by the server of the website on the computer or mobile device of the Customer. This server will later be able to recover or read the content of the cookie. Cookies are managed by the software of the Customer. Every cookie is unique and includes anonymous information, such as a unique identifier, name of the site, numbers and letters. It enables the website to remember the browsing preferences of the Customer. Terms and conditions for use of cookies are available here.
38. Some cookies are deleted at the same time with closing the browser. Some cookies are stored after closing the web browser, in order to store and take into account the Customer's preferences, settings and to improve the usage experience.
39. When using the web browsers tools, the Customer may control the data collected by cookies. For example, the Customer may use guides on the web browser in order to restrict that the websites visited by the Customer may use cookies, and in order to withdraw his or her consent by deleting or blocking cookies.
40. If a Customer deletes or blocks cookies, there is a possibility that some of the functions offered by the website may not work or access to certain sections thereof may be denied.
41. Different browsers have different types how to block and delete cookies. For example, information about managing cookies on the most often used browsers:
Chrome: https://support.google.com/chrome/answer/95647?hl=lvhlrm=en
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Opera: http://help.opera.com/Windows/10.20/en/cookies.html
Internet Explorer: https://privacy.microsoft.com/lv-LV/privacystatement#maincookiessimilartechnologiesmodule
Safari: https://support.apple.com/kb/ph21411?locale=lv_LV
42. Links to websites of third persons may be placed on the websites of the company Attēls R and they have their own terms and conditions for use and protection of personal data, regarding which the company Attēls R shall not bear any responsibility.
OTHER PROVISIONS
43. The company Attēls R has the right to make changes in the Privacy Policy at any time, making the updated version thereof available to Customers on the website of the company Attēls R.
44. This wording of the Privacy Policy shall come into force on 25 May 2018.