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Privacy Policy

Privacy Policy


1.    Introduction 


SIA “Skonto Plan Ltd” (hereinafter referred to as the "Company", "We"), registration No.: 40003079615, legal address: Rupniecibas Street 6, Tukums, LV-3101, has developed this privacy policy (hereinafter referred to as the  "Privacy Policy") with the aim of:

  1. to ensure that Our processing of personal data is transparent and fair;
  2. to inform You about Our processing of personal data, its purposes and legal basis, as well as;
  3. provide You with information about Your rights and how to exercise them. 

This is the current version of the Privacy Policy, which comes into force in September 25, 2023. We have the right to make amendments and supplement this Privacy Policy as necessary.


2.    Personal data processing controller
Name: SIA "Skonto Plan Ltd"
Registration number: 40003079615
Legal address: Rupniecibas Street 6, Tukums, LV-3101
Phone. +371 63165100
E-mail address: info@skontoplan.com. 

Contact information in case You have any questions about this Privacy Policy or Our processing of personal data: datu.aizsardziba@skontoplan.com  

3.    Purposes and legal basis for the processing of personal data
We ensure fair and lawful processing of personal data by processing Your personal data only for specific, pre-defined purposes and with an appropriate legal basis. We process Your personal data for the following purposes:


3.1. For the selection of potential employees
In order to carry out the selection of potential employees, with the aim of evaluating the suitability of potential employees for the vacancy and finding the most suitable candidate, We process Your personal data. 
The legal basis for the processing of this data is:

  • for the purposes of the legitimate interests pursued by the controller or by a third party (Article 6(1)(f) of the General Data Protection Regulation).

3.2. Conclusion and execution of the Contract
In order to conclude and execute certain types of contracts (employment contracts, contracts for the execution of a project, for the provision of goods or services, cooperation agreements, delivery contracts), We need to process the following personal data: identification data of an employee, customer, cooperation partner or supplier (e.g., name, surname, personal identity number); contact information for communication (e.g.  job position, e-mail, phone number, address); information required to make payments (e.g. account number). 
In the course of conclusion and execution of the contract, We also process other types of information provided to Us by an employee, customer, cooperation partner or supplier (for example, any information contained in the contract or information provided prior to conclusion of the contract regarding experience, the works performed and the orders executed).
Within the scope of this purpose, We also need to process data of the customer’s, cooperation partner’s or supplier’s contact persons: identification data (e.g. name, in certain cases, also personal identity number); contact details for communication (e.g. job position, e-mail, telephone number, workplace address), and information of the contact person’s identification document where We purchase and pay for airline tickets to the contact person.
The documents related to conclusion and execution of the contract shall be stored to ensure evidence in the case of potential claims, as well as in order to fulfil the legal obligation imposed on Us to store certain types of documents.

The legal bases for the processing of these data are:

  •  processing is necessary in order to take steps prior to entering into a contract or for the performance of a contract (Article 6(1)(b) of the General Data Protection Regulation1);
  •  for compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation), for example for the fulfilment of the requirements of the “Accounting Law”;
  • for the purposes of the legitimate interests pursued by the controller or by a third party (Article 6(1)(f) of the General Data Protection Regulation)

 

3.3. For safety and health protection at work

Within the scope of this purpose, in order to comply with the Labour Protection Law and the Cabinet Regulation No. 749 “Regulations Regarding Training in Labour Protection Matters”, We must provide training and briefing on labour protection issues to those persons who will perform certain jobs in the territory of the Company, as well as to document the performance of such training.
In order to meet the requirements of the legislation in the field of occupational safety, We need to process the following personal data: name, personal identity number, job position, profession, information about when and what training or briefing has been obtained, signature of the visitor (a representative of the service provider or an employee who will perform jobs in the territory of the Company).

The legal basis for the processing of these data is:

  • compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

 

3.4. For ensuring security, prevention of risks to property interests and provision of other essential legitimate interests of the Company or third parties

Within the scope of this purpose, We are conducting video surveillance of Our territory (Rupniecibas Street 3 and Rupniecibas Street 6, Tukums). The purpose of video surveillance is the prevention or detection of criminal offences related to protection of the Company property and protection of the property of persons (visitors and employees). The following processing of Your personal data – image (appearance), behaviour, location and time – is taking place during video surveillance. Data collected during video surveillance shall not be used other than for prevention or detection of criminal offences.

In order to ensure Our legitimate interests, We are accounting for people access to the territory (Rūpniecības Street 6, Tukums, Latvia). In order to ensure a passage regime in the Company, passes shall be issued for the visitors, for which entries are made in the visitor registration journal. For the purposes of the pass regime, We shall process the visitor’s identification data (given name, surname) as well as data regarding the visit - date and time of the visit.

The legal basis for the processing of these data is:

  • for the purposes of the legitimate interests pursued by the controller or by a third party (Article 6(1)(f) of the General Data Protection Regulation).

 

3.5. Promoting the Company profile

Within the scope of this purpose, the Company organizes events for its employees and customers. In order to promote the Company profile, the course of the event is photographed and/or filmed and the resulting photos and/or videos may be published on social networks for which employees, customers and their contacts are informed prior to the appropriate event, with getting an invitation to the event. The materials obtained may contain the following personal data: image, behaviour, location and time of employees, customers and contact persons.
The legal basis for the processing of these data is:

  • legitimate interests pursued by the controller (Article 6(1)(f) of the General Data Protection Regulation).

 

4.    In what way do We receive Your personal data and why do You need to provide Your personal data?
We receive Your personal data mainly from You – from Your presented business card, CV and cover letter, sent email, contract or invoice. If you are the customer’s, cooperation partner’s or supplier’s a contact person, We obtain Your personal data from You or from the contract, invoice or delivery document sent to Us by the customer, cooperation partner or supplier.

In certain cases when You visit Our production site at Rupniecibas Street 3 or Rupniecibas Street 6, Tukums, LV-3101, Your personal data is also obtained by Us via  video surveillance, if You have entered the video camera area, as well as by controlling access to the territory from access control systems, such as the pass registration system.

We also obtain personal data by filming and/or taking photographs at Our arranged events, notifying before the event that the course and conduct of the event may be filmed and/or photographed.

We need to obtain certain types of data for the conclusion and execution of the contract, for the fulfilment of legal obligations related to the Company, and for the implementation of legitimate interests of the Company. If We need to obtain data for the purposes indicated above, failure to provide data may threaten the conclusion and performance of the contract, as well as the fulfilment of legal obligations arising from the transaction relationship and implementation of the Company rights. 

 

5.    Who can access Your personal data?
We are processing Your personal data in accordance with the applicable law and transfer personal data to other persons only where there is an appropriate legal basis for the transfer of personal data.
Your personal data could be accessed, depending on the type of personal data, as appropriate, by:
•    Our employees or directly authorised persons who need this information for performance of their duties or delegated tasks, such as the employees of the financial department, the employees responsible for the contract performance, including Our contact persons, which We have specified in the contract, unit managers, directors, lawyers;
•    personal data controllers according to the services they provide, in accordance with a written signed agreement and only to the necessary extent, such as providers of accounting services, auditors, financial management and legal advisers, provider of security services, other persons associated with the provision of services to the Company;
•    the controlling and law enforcement authorities, upon a reasoned request, in the cases specified in the legislation;
•    in some cases, third parties in respect of published photographs and videos from the events organised by the Company.

 

6.    Are Your personal data sent outside the European Union (EU) or the European Economic Area (EEA) countries?
Your personal data is not sent outside the European Union (EU) or the European Economic Area (EEA). 


7.    Is Your personal data used for automated decision-making?
Your personal data is not used for automated decision-making.


8.    How is the period for storing Your personal data determined?
Your personal data is stored for as long as it is necessary to achieve the purposes of personal data processing specified in Paragraph 3 of this Privacy Policy, unless You withdraw Your consent to the processing of personal data or otherwise provided for in the applicable legislation.
We will store personal data related to the conclusion and execution of the contract for as long as the contract is in force and for a certain period thereafter:

  1. in order to comply with the requirements laid down in the legislation for the time limits for the storage of certain types of documents;
  2. in order to ensure an opportunity to prove the fulfilment of one’s obligations or to require the fulfilment of the obligations of the other party, in conformity with the type of transaction and the limitation period for the claim specified in laws and regulations.

We will store video surveillance records for 2 months, unless the data has previously been requested by competent state or law enforcement authorities, or criminal offenses have been detected. 


9.    Your rights
In accordance with the provisions of the General Data Protection Regulation, You have certain rights in relation to Your personal data. You can exercise Your rights as a data subject by contacting Us in one of the following ways:

  1. by submitting an application in person and identifying Yourself in Our office: SIA "Skonto Plan Ltd", Rupniecibas street 6, Tukums, LV-3101 or Jurkalnes street 15/25, 3rd floor, Riga, LV-1046, every working day from 8:00 to 17:00;
  2. by sending an application to Us by mail to the following address: Jurkalnes street 15/25, 3rd floor, Riga, LV-1046;
  3. by sending an application to Us by Our e-mail: datu.aizsardziba@skontoplan.lv  (the application must be signed with a qualified electronic signature).

Upon receipt of Your application for the exercise of Your rights, We will evaluate its content and the possibility of identifying You, and depending on the relevant situation, We reserve the opportunity to ask You to additionally identify Yourself in order to ensure the security of Your data and disclosure to the relevant person. We will respond to the request received by You within the time limits specified in regulatory enactments.


9.1.     Right of access 
You have the right to ask Us to provide information on whether and what personal data We process, as well as, to request access to Your personal data. 
To exercise this right, please contact Us using the contact details provided in paragraph 9 of the Privacy Policy.


9.2.    Right to rectification
You have the right to request that Your personal data be updated and corrected if You believe that Your personal data is not accurate, correct or complete. Your personal data will be corrected as soon as possible, without undue delay. 
To exercise this right, please contact Us using the contact information specified in paragraph 9 of the Privacy Policy.


9.3.     Right to erasure 
You have the right to request the deletion of Your personal data if You believe that We no longer need Your personal data for the purpose for which they were collected, or You have withdrawn Your given consent, or in other cases provided for in Article 17 of the General Data Protection Regulation. 
After receiving Your request, We will delete Your personal data immediately, except in cases where We are not bound by this obligation in accordance with Article 17 of the General Data Protection Regulation, for example, if Your personal data will be necessary for the fulfillment of a legal obligation or for the defense of Our legal requirements. 
To exercise this right, please contact Us using the contact information specified in paragraph 9 of the Privacy Policy.


9.4.    Right to restriction or objection of processing
You can also object to the processing of Your personal data if the processing of personal data is based on legitimate interests. Upon receipt of Your objections, We will stop processing Your personal data, except if the processing of data is necessary for Our legal interests or for the protection of Our legal claims.
To exercise this right, please contact Us using the contact details provided in paragraph 9 of the Privacy Policy.


9.5.    Right to data portability
You have the right to receive personal data concerning Yourself, which You have provided to Us and which is processed on the basis of Your consent or performance of a contract in written and electronic format. 
To exercise this right, please contact Us using the contact details provided in paragraph 9 of the Privacy Policy.


9.6.    Right to withdraw Your consent 
If the processing of Your personal data is based on consent, You have the right to withdraw the given consent at any time. 
To exercise this right, please contact Us using the contact details provided in paragraph 9 of the Privacy Policy. 


10.    Where to apply to ensure protection of Your rights?
If any claims arise for You in relation to the processing of personal data that We have made, please contact Us first to address the situation. We will evaluate all received claims and respond to them.
If You consider that Your rights in the field of personal data protection have been infringed, You have the right to submit a complaint to the Data State Inspectorate (address: Elijas Street 17, Riga, LV-1050, e-mail: pasts@dvi.gov.lv).