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PRIVACY POLICY
SIA "ENNA"
FOR CLIENTS, COOPERATION PARTNERS, REPRESENTATIVES/CONTACT PERSONS OF CLIENTS AND COOPERATION PARTNERS, PARTICIPANTS IN THE DRAWS AND LOTTERIES, WEBSITE VISITORS, BUILDING AND SITE VISITORS AND ANY OTHER PERSONS WHOSE DATA MAY COM INTO OUR POSSESION WITHIN THE SCOPE OF OUR COMMERCIAL ACTIVITY.
1. Information on the controller
Our company name is SIA “ENNA", registration number: 52103030501, legal address: Rietumkrasta street 3-18, Liepaja, LV-3416, Latvia.
You may contact us by calling: +371 6348 9333 or writing to the following e-mail address: enna@upb.lv.
2. Contact information for communication regarding matters of personal data protection
If you have any questions in relation to this notice or your personal data processing, you may contact us by writing to the following e-mail address: das@upb.lv.
3. General description of our performed personal data processing
This notice describes how we process the personal data of our clients, cooperation partners, representatives/contact persons of clients and cooperation partners, participants in the draws and lotteries, website visitors, building and site visitors and any other persons whose data may come into our possession within the scope of our commercial activity.
This is an updated wording of the notice. We reserve the right to make amendments and update this notice upon necessity.
The purpose of this notice is to give you a general overview of the personal data processing activities carried out by us and purposes thereof, but we still ask you to take into account that other documents (for example, service agreements, cooperation agreements) may also contain additional information regarding your personal data processing.
We would like to inform you that the terms for the personal data processing included in this notice shall only apply to the personal data processing of natural persons.
We understand that the personal data is your value and we shall process it in conformity with the confidentiality requirements while caring for the safety of your personal data in our possession.
4. For what purposes do we process your personal data and what are the legal grounds for personal data processing?
We shall only process your personal data for the previously defined legitimate purposes, including:
a) Starting and provision of services, as well as for fulfilment and ensuring of the obligations prescribed in the agreement (including in the cooperation agreement).
Within the scope of this purpose we will also need to identify you, ensure the appropriate calculation of payments and the payment performance process, contact you in matters related to the provision of service and/or matters related to execution of the agreement (including for the sending of invoices), and in some situations also ensure collection of the outstanding payments.
For this purpose and for the aforementioned sub-purposes we could require at least the following personal data: name, surname, identity number, address, bank account number, phone number, e-mail address of the client, the contact person and/or cooperation partner of the client.
The main legal grounds used for reaching these goals are as follows:
- entering into and fulfilment of the agreement with the data subject (Section 6, Clause 1, Sub-clause b of the General Data Protection Regulation);
- fulfilment of legal obligation (Section 6, Clause 1, Sub-clause c of the General Data Protection Regulation);
- compliance with the legitimate interests of the controller (Section 6, Clause 1, Sub-clause f of the General Data Protection Regulation), for example identification of you as a client, a contact person of the client and/or cooperation partner, ensuring communication with you.
b) Fulfilment of the requirements prescribed in the laws and regulations in respect of the provision of services or fulfilment of the requirements prescribed in other laws and regulations
Within the scope of this purpose we might need to fulfil both the requirements of the laws and regulations regulating the construction field and also the requirements prescribed in the Law on Accounting, Law on Archives and other laws and regulations.
For this reason we might need to process the following personal data: name, surname, identity number, address, of the client, the contact person of the client and/or cooperation partner, working hours recording data at the construction sites of the cooperation partner’s employees.
The main legal grounds used for reaching these goals are as follows:
- fulfilment of legal obligation (Section 6, Clause 1, Sub-clause c of the General Data Protection Regulation).
c) Ensuring marketing activities
Within the scope of this purpose, we could send you commercial notices, ensure your participation in our organised lotteries and/or draws, as well as publish materials from our organised public events.
For this purpose we could require at least the following personal data: name, surname, phone number, e-mail address of the client, the contact person of the client and/or cooperation partner.
The main legal grounds used for reaching this goal are as follows:
- consent of the data subject (Section 6, Clause 1, Sub-clause a of the General Data Protection Regulation);
- entering and fulfilment of the agreement with the data subject (Section 6, Clause 1, Sub-clause b of the General Data Protection Regulation);
- compliance with the legitimate interests of the controller (Section 6, Clause 1, Sub-clause f of the General Data Protection Regulation).
d) Prevention of endangerment to safety, property interests and ensuring of other significant legitimate interests of us or third parties
Within the scope of this purpose we might need to carry out video surveillance of our territory, buildings and other property, use personal data processors for ensuring various functions, if necessary, disclose information to courts and other state authorities, exchange information within the company group, use the rights granted in the laws and regulations for ensuring our legitimate interests.
For this reason we might need to process at least the following personal data: name, surname, identity number, appearance (image), location and time thereof of the client, the contact person of the client and/or cooperation partner, and other data based on necessity.
The main legal grounds used for reaching these goals are as follows:
- compliance with the legitimate interests of the controller (Section 6, Clause 1, Sub-clause f of the General Data Protection Regulation), for example for the purposes of the detection of criminal offences, ensuring the recovery of damages, preservation of evidence.
e) For ensuring the adequate provision of services
Within the scope of this purpose we might need to carry out maintenance and improvement of technical systems and IT infrastructure, use technical and organisational solutions that may also use your personal data (for example, by using cookies) with a purpose to ensure the adequate provision of services.
The main legal grounds used for reaching this goal are as follows:
- compliance with the legitimate interests of the controller (Section 6, Clause 1, Sub-clause f of the General Data Protection Regulation).
5. Who can access your personal data?
We take the necessary measures to process your personal data according to applicable laws and regulations and ensure that any third parties may not access your personal data who do not have any legal grounds for processing your personal data.
Upon necessity your personal data may be accessed by:
- our employees or directly authorised persons who need it for the fulfilment of their work responsibilities;
- personal data processors in accordance with their provided services and only in the required volume;
- in the events prescribed in the State and local government institution laws and regulations, tax administrations, sworn bailiffs;
- third parties by carefully assessing whether legal grounds exist for such data transfer, for example, debt collectors, courts, institutions handling out-of-court disputes, bankruptcy or insolvency administrators, third parties maintaining registers (for example, Population Register, debtor and other registers).
6. What cooperation partners do we choose for personal data processing or for personal data processors?
We take the necessary measures to ensure the processing, protection and transfer of your personal data to the data processors in accordance with the applicable laws and regulations. We carefully select the personal data processors and by transferring data assess the necessity for it and the volume of the data transferred. Transfer of data to the processor takes place in conformity with the personal data confidentiality and safe processing requirements.
Currently we can cooperate with the following personal data processing categories:
- outsourced accountants, auditors, financial management and legal consultants;
- owner/designer/technical maintainer of IT infrastructure/data base;
- other persons related to ensuring the provision of our services.
Personal data processors may change from time to time, regarding which we shall also make changes in this document.
7. Are your personal data being sent to countries outside the European Union (EU) or European Economic Area (EEA)?
We do not transfer data to countries outside the European Union or the European Economic Area.
8. How long will we store your personal data?
Your personal data will be stored for as long as the storing thereof is necessary for the relevant personal data processing purposes, as well as in accordance with the requirements of the applicable laws and regulations.
Upon the assessment of the length of storing personal data, we take into consideration the requirements of the laws and regulations, aspects of fulfilment of the contractual obligations, your instructions (for example, in the event of consent), as well as our legitimate interests. If your personal data is no longer necessary for the established purposes, we shall delete or destroy it.
Hereinafter we have provided the most common terms for the storing of personal data:
- we shall store the personal data necessary for the fulfilment of contractual obligations until the agreement is completed and until the expiration of other storage terms (please refer to the information hereinafter);
- we shall store the personal data to be stored to comply with the requirements of the laws and regulations for the terms established in the relevant laws and regulations, for example, the Law on Accounting states that supporting documents must be stored until the day when they are necessary to establish the beginning of each economic transaction and follow its course but not less than 5 years;
- we shall store the data to prove the fulfilment of our obligations for the general period until the expiration of the right to file a claim in accordance with the claim limitation periods defined in the laws and regulations - 10 years in the Civil Law, 3 years in the Commercial Law and other terms, also taking into account the terms for bringing claims prescribed in the Civil Procedure Law.
9. What are your rights as the data subject in respect of your personal data protection?
Restoration of personal data
If any changes have taken place in your personal data which you have provided to us, for example, changes to identity number, correspondence address, phone number or e-mail, please contact us and submit the updated data so we may satisfy the purposes for the processing of personal data.
Your rights to access your personal data and correct it
In accordance with the terms of the General Data Protection Regulation, you are entitled to request access to your personal data in our possession, request their correction, deletion, limitation of access, object to processing of your data, as well as the right to data portability in the events and pursuant to the procedure prescribed in the General Data Protection Regulation.
The company respects these rights of yours to access your personal data and control it, so if we receive your request, we will respond to it pursuant to the deadline prescribed in the laws and regulations (usually not later than within one month if it is not a special case requiring a longer period of time to prepare a response), and if it will be possible, we shall correct or delete your personal data.
You may obtain information regarding your personal data in our possession or exercise your other rights as the data subject in one of the ways prescribed hereinafter:
- by submitting an application in person and identifying yourself in our office (address: Dzintaru street 17, Liepaja, LV-3405, Latvia) each business day from 10 - 16;
- by submitting a relevant application by sending it to us by mail to the following address: Dzintaru street 17, Liepaja, LV-3405, Latvia;
- by submitting a relevant application, sending it to our e-mail address: upb@upb.lv, and we recommend to sign it with a safe electronic signature.
Upon the receipt of your application, we shall evaluate its content and the possibility of identifying you, and depending on the relevant situation we shall reserve the right to ask you for additional identification to ensure the safety of your data and disclosure to the relevant person.
Withdrawal of Consent
If your personal data processing is based on your given consent, you may withdraw it at any time, and we shall discontinue using your personal data which took place based on consent for the relevant purpose. We, however, would like to inform you that withdrawal of consent may not affect the processing of personal data which is necessary for the fulfilment of requirements of the laws and regulations or which is based on the agreement, our legitimate interests or other grounds for lawful data processing established in the laws and regulations.
You may also object to your personal data processing if the personal data processing is based on legitimate interests or is used for marketing purposes (for example, sending of commercial notices or participation in draws).
10. Where can you submit a complaint in respect to matters related to personal data processing?
If you have any questions or objections in respect of our performed processing of your personal data, we ask you to contact us.
If you still believe that we have not been able to mutually solve the problem and you still consider that we have violated your rights to personal data processing, you may file a complaint to the Data State Inspectorate. You may find sample applications to the Data State Inspectorate and any other information related thereto on the Data State Inspectorate website at (http://www.dvi.gov.lv/lv/datu-aizsardziba/privatpersonam/iesniegumu-paraugi/).
11. Why do you need to provide your personal information to us?
We mostly collect your information to fulfil the assumed contractual obligations, comply with the legal obligations binding on us and exercise our legitimate interests. In these situations we need specific information to meet the relevant purposes, thus a failure to provide it may endanger the beginning of business relations or fulfilment of the agreement. If data is not mandatory, but the submission thereof could improve the service or offer you convenient terms of the agreement and/or offers, during the collection of data we shall indicate that the provision of data is voluntarily.
12 How do we collect your personal data?
We may acquire your personal data in one of the ways provided hereinafter:
- in the process of signing a mutual agreement, by acquiring data from you;
- if the agreement has been signed with a third party, and it has indicated you as a contact person and/or the representative;
- from you if you submit any applications, e-mails to us or call us;
- from you if you subscribe to our services online;
- on the website www.upb.lv , by using cookies;
- in some situations from the databases of third parties, for example, when evaluating your creditworthiness, we may obtain data from third parties for this purpose;
- in some situations from video surveillance recordings.
13. Are your personal data used for adopting automated decisions?
We do not use your data for adopting automated decisions.