1. Controller of personal data processing:
Controller of personal data processing is AS “Dzintars”, reg. No. 40003040607, registered address 30 Malu Street, Riga, LV-1058, telephone number +371 20009831, firstname.lastname@example.org (hereinafter referred to as the “Dzintars”), websites www.dzintars.com.
2. Processor of personal data:
The processor AS "Dzintars”, reg. No 40003040607, 30 Malu Street, Riga, following the instructions of Dzintars and using technical and organisational data protection measures, will process the Client's personal data to the extent and procedures required and permitted by the laws and regulations of the Republic of Latvia and the European Union. Other personal data processors of Dzintars shall be authorised to receive and process Client's data.
3. Applicable laws:
- Regulation of the European Parliament and of the Council No. 2016/679 on the protection of individuals regarding processing of personal data and on the free circulation of such data (April 27, 2016).
- Personal Data Protection Law.
4.3. In order to provide better and more appropriate products and services to the Client and to ensure, maintain, protect and improve existing products and services, Dzintars processes data collected from the provision of services.
5. What personal data is processed by Dzintars?
5.1. Personal data categories processed by Dzintars depend on the products and services used by the Client. Dzintars is entitled to process the following personal data categories for the purposes of paragraph 7 of this Policy:
- name, surname, correspondence address, telephone number and e-mail address;
- bank details;
- communication data - e-mail, letter or other information regarding Client's communication with Dzintars;
- data disclosed to Dzintars by Client himself.
5.2. Dzintars shall process the following data on the use of products and services for the purposes of paragraph 7 of this Policy:
- Client's IP address information;
- cookies (website browsing data) - data on browsing Dzintars websites (www.dzintars.com), (hereinafter referred to as “Dzintars websites”);
- date, time, and Internet browsing volume, location during browsing;
- other personal data, depending on the type of service provided to the Client, by informing the Client in advance.
6. What are the grounds for processing Client's personal data?
6.1. Client's consent - Client, as personal data subject, gives consent to the collection and processing of personal data for certain purposes. The Client's consent for direct marketing purposes to express new and individual offers will be attributed to Dzintars activities following the entry into force of the E-Private Regulation. The Client's consent is his free will and an independent decision that can be made at any time, thereby allowing Dzintars to process personal data for certain purposes. The Client's consent is bound by it if it is given in writing (by filling out the form in Dzintars store, by sending the electronic request to email@example.com). The Client is entitled to withdraw his previously given consent at any time using the specified channels of communication with Dzintars. Appropriate changes will be applied within three working days. The withdrawal of consent shall not affect the legality of the processing based on the consent prior to the withdrawal.
6.2. Conclusion and fulfilment of the Agreement - to allow Dzintars to conclude and execute an agreement with the Client, by providing quality services and serving the Client, it must collect and process certain personal data collected prior to the conclusion of the agreement with Dzintars or during an agreement period.
6.3. Legitimate interests of Dzintars - by observing Dzintars interests, based on ensuring quality services and timely support to the Client, Dzintars is entitled to process the Client's personal data to the extent that it is objectively necessary and sufficient for the purposes specified in paragraphs 7.1 to 7.2 of this Policy. Legitimate interests of Dzintars can be considered processing of personal data by direct marketing, as a result Client receives offers for new and/or individual Dzintars products and services (see also paragraphs 8.2 and 8.3 of this Policy).
6.4. Enforcement of legal obligations — Dzintars is entitled to process personal data in order to comply with regulatory requirements and to provide answers to legitimate requests from state and local government.
7. For what purposes Dzintars will process Client's personal data?
7.1. Dzintars processes personal data to ensure the quality, timely and convenient service during the contractual relationship with Dzintars:
- for the management of the Client's relationship (including remote), ensuring the conclusion and execution of the Agreements, as well as the implementation of the related processes;
- for reviewing Client's complaints and ensuring support (including technical support) for the services provided;
- to inform Client about products and services of other companies;
7.2. Dzintars processes personal data to promote industry development and to offer new services to Clients, including:
- to create new products and make offers regarding them;
- statistical data processing of Dzintars clients is carried out to analyse the market and develop business model.
7.3. Dzintars processes personal data to create and maintain Dzintars internal processes, ensure circulation of documents and other internal processes (e.g. archiving of contracts and other documents) for the necessary and adequate extent.
7.4. Dzintars is entitled to process data for the following, as well as for other purposes, receiving a free and explicit consent from the Client:
- to promote image of Dzintars on the market, by sending the Client a nice wishes, awarding bonuses, organizing surveys for improving existing products and services and creating new products.
8. Is Client entitled to restrict the data processing?
8.1 Customer personal data profiling as data processing:
- profiling means the processing of any kind of automated personal data manifested as the use of personal data for the purpose of assessing certain personal aspects related to a natural person, in particular to analyse or predict aspects regarding natural person's individual wishes, interests, reliability, behaviour, location or movement;
- when processing Client's personal data Dzintars can carry out profiling to send nice wishes, gifts, award bonuses, creating and expressing individual offers. Automated individual decisions are only accepted for business purposes and will not result in legal consequences for the Client. The client has the right at any time to object to the adoption of an automated decision and not to be the subject of a decision, by informing Dzintars (see also the provisions of paragraph 8.3 of this Policy).
8.2 Direct marketing and basis for sending commercial messages to the Client: Dzintars shall perform direct marketing by distributing commercial reports to the Client so that the Client is always informed about new, modern and/or directly established products, services and special contract terms (e.g. discounts) in accordance with the basis for the processing of personal data specified in paragraph 6.3 of this Policy. The Client is entitled to waive the refuse to receive commercial communications at any time and without charge, by informing Dzintars (see also the provisions of paragraph 8.3 of this Policy).
8.3. The Client is entitled to object to the profiling of his personal data (see paragraph 8.1) or refuse to receive commercial communications (see paragraph 8.2) at any time, by informing Dzintars in writing (by sending an electronic request to a firstname.lastname@example.org signed with a secure electronic signature or writing to email@example.com). Changes will not affect the legality of the processing of personal data before the Client's objections and/or refusal specified in this clause.
9. What are cookies and how can Dzintars process them?
9.1. Cookies are small text files that are created and stored on the Client's device (computer, tablet, mobile phone, etc.) by visiting Dzintars websites. The cookies “remember” user experience and basic information and thus improve the ease of using the Dzintars website.
9.2. By using cookies, common user habits and website usage history is processed, diagnoses problems and deficiencies in the site's operation, collected user statistics, and ensured full and easy use of website functionality.
9.4. The websites maintained by Dzintars use functional, analytical, advertising and mandatory cookies.
10. How Dzintars receives Client's personal data?
10.1. Dzintars receives Client's personal data when Client:
- purchases and uses Dzintars products or services (in Dzintars stores or remotely);
- sign up for news and other services from Dzintars;
- asks Dzintars for more information about the product used by the Client or the service connected to the Client or is contacted by Dzintars in connection with complaints or information request by identifying the Client;
- participates in contests, lotteries or surveys;
- visit or browse Dzintars website;
10.2. Dzintars can process Client's personal data received from third parties if the Client has agreed to it.
10.3. Dzintars can process customer personal data on the Client from other companies and partner companies (see paragraph 12 of this Policy) with prior consent from the Client.
11. What is the Client's personal data processing time?
Dzintars will process the Client's personal data while at least one of the following conditions exists:
- agreement between the Client and Dzintars;
- the period for the retention of personal data is determined or resulting from the regulatory enactments of the Republic of Latvia and the European Union;
- the extent necessary for Dzintars to realise and protect legitimate interests;
- until Client's consent to the processing of personal data has been revoked.
12. Sharing Client's personal data
12.1. To provide services to Client, Dzintars can share Client's personal data with:
- partners or representatives involved in the provision of products and services ordered or used by the Client.
12.2. Dzintars is obliged to provide information on personal data to the following institutions and services:
- law enforcement authorities, court or other state and local government authorities, if this arises from regulatory enactments or requests for information from the institution concerned;
12.3. Dzintars will provide the Client’s personal data only in the necessary and sufficient amount in accordance with the requirements of regulatory enactments and the objective conditions of the situation.
13. How Dzintars protects Client's personal data?
13.1. Dzintars shall ensure, continuously review and improve protective measures to protect customer personal data from unauthorised access, accidental loss, disclosure or destruction. To ensure this Dzintars applies modern technology, technical and organisational requirements, including firewalls, intrusion detection, analysis software.
13.2. Dzintars thoroughly examines all the service providers that handle and process the Client’s personal data on behalf of the Dzintars, and assess, whether cooperation partners (personal data processors) apply appropriate security measures in order to process the Client's personal data in accordance with Dzintars delegation and requirements of the regulatory enactments. Cooperation partners are not allowed to process Client's personal data for their purposes.
13.3. Dzintars shall not take responsibility for any unauthorised access to personal data and/or loss of personal data if it is does not depend on Dzintars, for example due to the fault and/or negligence of the Client.
13.4. In case where Client's personal data is threatened, Dzintars will notify the DSI and, if necessary, the Client.
14. What are the Client's rights?
14.1. To contact Dzintars (by writing to firstname.lastname@example.org), to receive a copy of personal data held by Dzintars.
14.2. To correct all personal data about themself held by Dzintars by writing to email@example.com.
14.3. The Client is entitled to receive information about those natural or legal persons who have received information about this Client within a certain period of time from Dzintars. Dzintars will not provide the Client with information about the state institutions that are the guarantors of the criminal proceedings, operative entities or other institutions for which the law prohibits disclosure of such information.
14.4. To request to delete or restrict the processing of personal data if processing is no longer necessary in accordance with the purposes for which they were collected and processed (right to “be forgotten").
14.5. The Client is entitled to the transferability of their personal data, if processing is carried out in an automated manner, by submitting a written application.
From May 25, 2018, the Client is entitled to:
- object to the processing of personal data by Dzintars on the basis of legitimate interests, however, Dzintars will continue to process the data, even if the Client has objected to it, if there are compelling reasons to continue processing the data. In order to implement the rights referred to above, the Client must submit to Dzintars a written submission to firstname.lastname@example.org;
- in certain circumstances the Client is entitled to request that Dzintars deletes personal data, but it does not apply to cases where the law requires the retention of data. In order to implement the rights referred to above, the Client must submit to Dzintars a written submission to email@example.com;
- in certain circumstances the Client has the right to restrict the processing of personal data. Please note that if the Client requests to restrict the processing of data, the execution of the order may be affected. In order to implement the rights referred to above, the Client must submit a written submission to firstname.lastname@example.org;
- The customer has the right to receive or transfer personal data to another data manager (“data transferability”). This right shall include only the data provided by the Client to Dzintars on the basis of its consent or contract, and if the processing is carried out in an automated manner. In order to implement the rights referred to above, the Client must submit a written submission to email@example.com.
14.6. To contact Dzintars or supervising body of personal data (Data State Inspectorate, www.dvi.gov.lv) regarding matters about the processing of personal data.
14.7. To contact Dzintars by writing to firstname.lastname@example.org to receive information about processing and protection of client's personal data.