Controller’s Contact Information
The personal data controller is SIA Intelligent Systems (hereinafter – IS), unified registration No. 40003757281, legal address: Sigulda, Krišjāņa Barona Str. 4 – 18, LV-2150.
Contact information in matters related to processing of personal data is: firstname.lastname@example.org. You can ask questions in relation to personal data processing using the given contact information.
Scope of Application of the Document
Personal data are any information about an identified or identifiable natural person.
- natural persons – clients and other service users (including potential, former and existing ones), as well as third parties who receive and pass on any information (including contact persons, payers, etc.) to IS in relation to provision of services to a natural person (a client, a user);
- visitors of IS premises, including visitors subject to video surveillance;
- Visitors of websites and mobile applications maintained by IS (hereinafter – Clients).
IS takes care of Clients’ privacy and the protection of personal data, observes the Clients’ rights to the lawfulness of personal data processing in accordance with the applicable legal acts – Personal Data Processing Law, Regulation (EU) of the European Parliament and of the Council No. 2016/679 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 (Regulation) and other applicable legal acts in the field of privacy and data processing.
For specific types (e.g., cookie processing, etc.), environment, purposes of data processing, additional, specific regulations may be determined for the purposes of which the Client will be informed upon providing the according data to IS.
Purposes of Data Processing
IS processes personal data for the following purposes:
- Provision of services and selling of goods:
- client identification;
- preparation and conclusion of a contract;
- supply and delivery of goods and services (performance of contractual obligations);
- provision/maintenance of services;
- fulfilment of warranty obligations;
- improvement of goods and services, development of new goods and services;
- promotion of use of the service;
- advertising and distribution of services or commercial purposes;
- client service;
- handling and processing objections;
- client retention, promotion of loyalty, satisfaction measurements;
- administration of settlements;
- recovery and levy of debts
- maintenance of websites and mobile applications and improvement of the performance thereof.
- Business planning and analysis:
- statistics and business analysis;
- planning and accounting;
- measuring efficiency;
- service quality assurance;
- market and public opinion research;
- preparation of reports;
- client surveys;
- within the framework of risk management activities.
- Providing information to state administration institutions and subjects of operational activities in the cases and at the volume specified in external laws and regulations.
- Other specific purposes for which the Client is informed upon providing the according data to IS.
Legal Basis for Data Processing
IS processes the Client's personal data based on the following legal grounds:
- for the conclusion and execution of a contract – to conclude a contract following the Client’s application and to ensure its execution;
- execution of laws and regulations – to fulfil an obligation specified in external laws and regulations binding to IS.
- in accordance with the consent of the Client – the data subject;
- in lawful (legitimate) interests – to realise the lawful (legitimate) interests of IS arising out of existing obligations or a contract concluded between IS and the Client or arising out of law.
The lawful (legitimate) interests of IS are:
- to carry out commercial activities;
- to verify the Client's identity prior to the conclusion of a contract;
- to ensure fulfilment of contractual obligations;
- to store the Client’s applications and submissions for purchase of goods and provision of services, other applications and submissions, notes on them, including ones made orally, by telephone, on websites;
- to analyse the performance of IS websites and mobile applications, to develop and implement their improvements;
- to administer the Client’s account on IS websites and mobile applications;
- to carry out activities for client retention;
- to segment client database for more efficient provision of services;
- to develop and improve goods and services;
- to advertise goods and services by sending commercial communications;
- to send other reports on the progress of the execution of the contract and events relevant to the execution of the contract, and to conduct Client surveys on goods and services and their experience of use;
- to ensure corporate management, financial and business accounting and analysis;
- to ensure effective governance of the company;
- to ensure the efficiency of the supply of services and the sale and delivery of goods;
- to ensure and improve the quality of services;
- to administer payments;
- to administer outstanding payments;
- to apply to state administration institutions and institutions of operational activities and court for the protection of its legal interests;
- to inform the public about its activities.
IS processes Client data using the options provided by modern technologies, taking into account the existing privacy risks and organisational, financial, and technical resources that are reasonably available to IS.
For the high-quality and fast execution of the contractual obligations arising out of a contract concluded with the Client, IS can authorise its cooperation partners to perform separate deliveries of goods and activities for provision of services, such as service deployment works, billing, and the like. If, in carrying out these tasks, the co-operation partners process the Client’s personal data at the disposal of IS, the according partners of IS are considered to be data processing operators (processors) and IS is entitled to transfer the Client’s personal data to the co-operation partners for the performance of these activities to the extent necessary to carry out these activities.
Co-operation partners of IS (in the status of a processor of personal data) will ensure the fulfilment of the requirements for personal data processing and protection in line with the requirements of IS and other legal acts, and will not use personal data for other purposes, except for the fulfilment of the contractual obligations arising out of the contract concluded with the Client on behalf of IS.
IS protects Client data using the options provided by modern technologies, taking into account the existing privacy risks and organisational, financial, and technical resources that are reasonably available to IS, including using the following security measures:
- Data encryption by transmitting data (SSL encryption);
- Intrusion prevention and detection programs;
- Other protective measures in line with the possibilities provided by current technical developments.
Categories of Data Recipients
IS does not disclose to third parties the Client’s personal data or any other information obtained through the provision of services and during the validity period of the contract, except:
- if data has to be transferred to the third party within the framework of the concluded contract to perform any function necessary for the execution of the contract or any function delegated by law (e.g., to a bank within a settlement or for the provision of services for which the Client is informed in the respective service contract);
- in accordance with the Client’s explicit and unambiguous consent;
- to persons provided for in the external laws and regulations upon their reasonable request, in accordance with the procedure and volume specified in the external laws and regulations.
- In cases provided for in the external laws and regulations to protect the lawful interests of IS, e.g., by appealing to a court or other state institutions against a person who has violated these lawful interests of IS.
Data Storage Period
IS stores and processes the Client's personal data as long as at least one of the following criteria exists:
- only as long as the contract entered into with the Client is valid;
- as long as IS or the Client can realise their lawful interests in line with the procedure specified in the external laws and regulations (for example, to submit objections or to bring an action in court);
- while one of the parties has a legal obligation to store the data;
- while the Client’s consent to the respective personal data processing is valid if there are no other legal grounds for data processing.
Upon expiry of the previously mentioned circumstances, the Client’s personal data are anonymised or erased.
Access to Personal Data and Other Client’s Rights
The Client has the right to receive information specified in laws and regulations regarding the processing of his data.
In accordance with the laws and regulations, the Client also has the right to request from IS access to his/her personal data, as well as to request from IS the supplementation, correction or deletion thereof, or to restrict the processing with respect to the Client, or the right to object against the processing (including against processing of personal data carried out on the basis of the lawful (legitimate) interests of IS), as well as the right to data portability. These rights are exercisable insofar as the processing does not arise out of the obligations of IS imposed on it by the applicable laws and regulations and which are carried out in the public interest.
The Client may submit a request for the exercise of his rights:
- via electronic mail by signing it with a secure electronic signature and sending it to the e-mail address indicated in the contact information section;
- by submitting a signed application in a paper form on-site or sending it via mail as a registered letter to the address indicated in the contact information section.
Upon receiving the Client’s request for the exercise of its rights, IS verifies the Client’s identity, evaluates the request and executes it in accordance with laws and regulations.
IS sends a reply to the Client via e-mail.
IS ensures the fulfilment of data processing and protection requirements in accordance with laws and regulations and, in the case of the Client’s objections, performs useful actions to resolve the objection. However, if this fails, the Client has the right to contact the Supervisory Authority – the Data State Inspectorate.
Client’s Consent to Data Processing and the Right to Withdraw it
The Client may provide his/her consent for processing of personal data, the legal grounds for which is consent (such as an individually prepared advert, etc.), in IS service application forms, IS service websites/applications and other websites (for example, newsletter subscription forms).
The Client has the right to withdraw his consent to the data processing at any time in the same manner as it was provided, that is – IS service application forms, IS service websites/applications, and in this case further data processing based on previous consent for the specific purpose will not be carried out in the future.
The withdrawal of consent does not affect the processing performed at the time when the Client’s consent was valid.
Withdrawal of consent cannot stop the processing of data carried out on the basis of other legal grounds.
Communication with the Client
IS communicates with the Client using the contact details provided by the Client (telephone number, e-mail address, mailing address, IS websites, as well as using application notifications).
Communication regarding the fulfilment of obligations arising out of a service contract is carried out by IS on the grounds of a concluded contract (e.g., co-ordination of delivery time or repairing damage, information on invoices, planned work, changes in services, etc.).
IS carries out commercial communication regarding IS and/or third-party services and other communications not related to the provision of directly contracted services (such as client surveys) in accordance with external laws and regulations or with the consent of the Client.
The Client may consent to the receipt of commercial communications from IS and/or its business partners on IS service application forms, IS service portals/applications, and other websites.
Client's consent to receive commercial communications is valid until its withdrawal (also after the termination of the service contract). The Client may at any time refuse to receive further commercial communications in any of the following ways:
- by making an appropriate mark on his/her user profile on IS website;
- by changing the notification settings on devices;
- by using the automated option provided in the commercial communication to unsubscribe from further communications by clicking on the unsubscribe link at the end of the relevant commercial communication (e-mail).
IS stops sending commercial communication as soon as the Client’s request is processed. The processing of a request depends on technological possibilities and may take up to three days.
When expressing his/her opinion in the surveys and leaving his/her contact information (e-mail, telephone), the Client agrees that IS can communicate with him/her using the provided contact information in relation to the assessment provided by the Client.
Website Traffic and Processing of Cookies
IS website can use following cookies:
- User chosen settings - for website usability improvement.
- Cookies created by “Google Inc” software “Google Analytics”
Cookies are not used to identify You personally.
If You wish, You can control and delete cookies - all web browsers security settings offer cookies restrictions and deletion.
IS websites can contain links to third party websites, who has their own use and personal data protection rules, for which IS is not responsible.