Privacy Policy

The purpose of this Privacy Policy is to provide information to a natural person – a client of the services provided by SIA ATVADAS – about the purpose, scope, protection, processing period and rights of the data subject during data collection, as well as when processing the client’s personal data.

Controller and its contact information
 
  • The controller of personal data processing is SIA ATVADAS (hereinafter – ATVADAS), unified registration No. 50103114641, legal address in Riga, Tēraudlietuves iela 3.
  • ATVADAS contact information for issues related to personal data processing is: info@atvadas.lv. Using this contact information or visiting the ATVADAS legal address, you can ask questions about personal data processing. A request for the exercise of your rights can be submitted in accordance with paragraph 23.
Scope of the document 3. Personal data is any information relating to an identified or identifiable natural person. 4. The Privacy Policy applies to ensure privacy and personal data protection in relation to:
 
  • natural persons – clients and other users of ATVADAS services (including potential, former and current), as well as third parties who, in connection with the provision of services to a natural person (client, user), receive or transmit any information to ATVADAS (including contact persons, payers, etc.);
  • visitors to ATVADAS-maintained websites, and callers to ATVADAS contact numbers (hereinafter – Clients).
  • ATVADAS takes care of the Client’s privacy and personal data protection, respects the Client’s right to lawful processing of personal data in accordance with applicable laws – 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 (the Regulation) and other applicable laws in the field of privacy and data processing.
  • The Privacy Policy applies to data processing regardless of the form and/or environment in which the Client provides personal data (ATVADAS website, self-service portal, paper format or by telephone) and in which company systems or paper format they are processed.
  • With regard to specific types of data processing (e.g. cookie processing, etc.), environments, and purposes, additional specific rules may be established, and the Client will be informed when they provide the relevant data to ATVADAS.
Purposes of personal data processing ATVADAS processes personal data for the following purposes: Provision of services and sale of goods:
  • client identification;
  • preparation, conclusion and proof of conclusion of the contract;
  • delivery of goods and installation and provision of services (performance of contractual obligations);
  • ensuring the operation/maintenance of services;
  • improvement of goods and services, development of new goods and services
  • promotion, advertising and distribution of services;
  • customer service;
  • consideration and processing of applications and objections;
  • customer retention, loyalty building, satisfaction measurement;
  • administration of payments;
  • creditworthiness assessment, credit monitoring;
  • debt recovery and collection;
  • maintenance and improvement of website operation.
Business planning and analysis:
 
  • statistics and business analysis;
  • planning and accounting;
  • planning and accounting;
  • efficiency measurement;
  • conducting market and public opinion research;
  • report preparation;
  • conducting customer surveys;
  • risk management activities.
Ensuring information, information system and enterprise security. Providing information to public administration bodies and operational entities in cases and to the extent specified in external regulations. Other specific purposes for which the Client is informed when providing the relevant data to ATVADAS.
Legal basis for personal data processing 9. ATVADAS processes the Client’s personal data based on the following legal grounds:
 
  • veikt komercdarbību;
  • compliance with regulatory enactments – to fulfill the obligation imposed on ATVADAS by applicable external regulations;
  • in accordance with the consent of the Client – the data subject;
  • legitimate interests – to realize ATVADAS’ legitimate interests arising from the existing relations or the concluded contract or law between ATVADAS and the Client;
  • ensuring the vital interests of the data subject or another natural person – to ensure the physical and property safety of ATVADAS employees, Clients and visitors.
  • ATVADAS’ legitimate interests are:
  • to conduct commercial activities;
  • to provide electronic communications services;
  • to verify the Client’s identity before concluding a contract;
  • to ensure the performance of contractual obligations;
  • to prevent unjustified financial risks to its commercial activities (including assessing credit risk before selling goods and services and during the performance of the contract);
  • to retain Clients’ applications and submissions for the purchase of goods and provision of services, other applications and submissions, notes on them, including those made in writing or orally by calling the office, on websites and in the self-service portal;
  • to make recordings of conversations with the Client for the purpose of ensuring the operation, maintenance and billing of services, in order to monitor the quality of customer service;
  • to make recordings of conversations with the Client in order to organize the performance of service contract obligations;
  • to analyze the operation of ATVADAS websites and websites, to develop and implement improvements;
  • to administer the Client’s account on ATVADAS websites and websites;
  • to take actions to retain Clients;
  • to segment the customer database for more efficient service provision;
  • to develop and evolve products and services;
  • to advertise its products and services;
  • to send other messages about the progress of contract performance and events relevant to contract performance, as well as to conduct Customer surveys on products and services and their usage experience;
  • to prevent fraud;
  • to ensure corporate governance, financial and business accounting and analysis;
  • to ensure efficient enterprise management processes;
  • efficiency of service provision and sale and delivery of goods;
  • to ensure and improve service quality;
  • to administer payments;
  • to administer non-payments;
  • to approach public administration and operational institutions and the court to protect its legitimate interests, e.g. against a person who has infringed on these legitimate interests of ATVADAS;
  • to inform the public about its activities.

Personal data processing

11. ATVADAS processes the Client’s data using modern technology capabilities, taking into account existing privacy risks and ATVADAS’ reasonably available organizational, financial and technical resources.
12. ATVADAS may engage in automated decision-making in relation to the Client. The Client will be informed separately of such ATVADAS activities in accordance with regulatory enactments. The Client may object to automated decision-making in accordance with the law, but recognizing that in some cases this may limit the Client’s right to use certain potentially available opportunities (e.g. receive commercial offers).
13. Automated decision-making that has legal consequences for the Client (e.g. approval or rejection of the Client’s application) may only be carried out in the course of concluding or performing a contract between ATVADAS and the Client, based on the Client’s unambiguous consent or in cases specified in external regulations.
14. To ensure the quality and efficiency of fulfilling the obligations under the contract concluded with the Client, ATVADAS may authorize its partners to perform certain tasks of delivering goods or providing services. If, in carrying out these tasks, ATVADAS partners process the Client’s personal data held by ATVADAS, the respective ATVADAS partners are considered to be data processing operators (processors) of ATVADAS and ATVADAS has the right to transfer to the partners the Client’s personal data necessary for the performance of these tasks to the extent necessary for their performance.

15. ATVADAS partner companies (in the status of data processor) will ensure compliance with personal data processing and protection requirements in accordance with ATVADAS requirements and the law, and will not use personal data for purposes other than the performance of the obligations under the contract concluded with the Client on behalf of ATVADAS.

Protection of personal data

16. ATVADAS ensures, continuously reviews and improves security measures to protect Clients’ personal data from unauthorized access, accidental loss, disclosure or destruction. To achieve this, ATVADAS applies modern technologies, technical and organizational requirements, including the use of firewalls, intrusion detection, analysis software and data encryption.

17. ATVADAS carefully checks all service providers who process Clients’ personal data on behalf of and on behalf of ATVADAS, and assesses whether partners (data processors) apply appropriate security measures to ensure that Clients’ personal data processing is carried out in accordance with ATVADAS’ delegation and regulatory requirements. Partners are not allowed to process the Client’s personal data for their own purposes.
18. ATVADAS assumes no responsibility for any unauthorized access to personal data and/or loss of personal data, if it is not dependent on ATVADAS, for example, due to the Client’s fault and/or negligence.

19. In case of a breach of the Client’s personal data, ATVADAS will notify the Client about it.

Categories of personal data recipients

20. ATVADAS does not disclose the Client’s personal data or any information obtained during the provision of services and the term of the contract to third parties, including information about received electronic communications, content or other services, except:
 
  • if the data must be transferred to the respective third party within the concluded contract to perform a function necessary for the execution of the contract or delegated by law in accordance with the Client’s clear and unambiguous consent;
  • to persons prescribed by external regulatory enactments upon their reasonable request, in the manner and to the extent prescribed by external regulatory enactments;
  • in cases prescribed by external regulatory enactments for the protection of ATVADAS’ legitimate interests, for example, by applying to a court or other state institutions against a person who has violated these legitimate interests of ATVADAS. Personal data retention period
    AS leģitīmās intereses.
21. ATVADAS stores and processes the Client’s personal data as long as at least one of the following criteria is met:
 
  • only as long as the contract concluded with the Client is in force;
  • the data is necessary for the purpose for which it was received;
  • as long as ATVADAS or the Client can exercise their legitimate interests in the manner prescribed by external regulatory enactments (for example, submit objections or file or bring an action in court);
  • as long as either party has a legal obligation to store the data (for example, according to the Accounting Law, invoices issued to the company must be kept for 5 years, etc.);
  • as long as the Client’s consent for the respective personal data processing is valid, if there is no other legal basis for data processing.
  • After the circumstances mentioned in this point cease to exist, the Client’s personal data is deleted. Audit logs are kept for at least one year from the day they were made in accordance with the regulatory enactments. Access to personal data and other rights of the Client
22. The Client also has the right, in accordance with regulatory enactments, to request from ATVADAS access to their personal data, as well as to request ATVADAS to supplement, correct or delete it, or restrict processing in relation to the Client, or the right to object to processing (including processing of personal data based on ATVADAS’ legitimate interests), as well as the right to data portability. These rights are exercised insofar as the data processing does not arise from ATVADAS’ obligations imposed on it by applicable regulatory enactments, and which are carried out in the public interest.
23.The Client may submit a request for the exercise of their rights:
 
  • in written form in person at the ATVADAS office by presenting an identity document;
  • by e-mail, signed with a secure electronic signature;
24. Upon receiving the Client’s request for the exercise of their rights, ATVADAS verifies the Client’s identity, evaluates the request and fulfills it in accordance with regulatory enactments.
25. ATVADAS sends the response to the Client by post to the contact address specified by them in a registered letter or taking into account the method of receiving the response specified by the Client.
26. ATVADAS ensures compliance with data processing and protection requirements in accordance with regulatory enactments and, in case of an objection from the Client, takes reasonable actions to resolve the objection. However, if this is unsuccessful, the Client has the right to turn to the supervisory authority – the Data State Inspectorate. Client’s consent for data processing and the right to withdraw it
27. The Client can give consent for personal data processing, the legal basis of which is consent (for example, analysis of service usage habits, individually prepared advertising, etc.) in the ATVADAS service agreement, ATVADAS service portals/applications, by calling the ATVADAS contact number or in person at the ATVADAS office.
28. The Client has the right to withdraw the consent given for data processing at any time in the same way as it was given, i.e. by calling the ATVADAS contact number or in person at the ATVADAS office, and in such case, further data processing based on the previously given consent for a specific purpose will no longer be carried out.
29. The withdrawal of consent does not affect data processing that was carried out during the time when the Client’s consent was valid.
30. By withdrawing consent, data processing carried out on other legal grounds cannot be terminated. Communication with the Client
31. ATVADAS communicates with the Client using the contact information provided by the Client (telephone number, e-mail address, postal address and/or other agreed methods with the Client).
32. ATVADAS communicates about the fulfillment of service contract obligations on the basis of the concluded contract. Website visits and cookie processing
33. ATVADAS websites may use cookies.
34. ATVADAS websites may contain links to third-party websites, which have their own terms of use and privacy policies, for which ATVADAS bears no responsibility. Other provisions
35. ATVADAS has the right to make additions to the Privacy Policy by making the current version available to the Client by posting it on the ATVADAS website.
36. This version of the Privacy Policy enters into force on August 1, 2019.

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