The purpose of this Privacy Policy is to provide information to individuals—data subjects, including Clients, business partners, and employees of the company—about the purposes, scope, protection, and retention period of personal data processing during the data collection and processing of the data subject’s personal data.
Data Controller
The Data Controller is PRO-BALTIC, SIA, Registration No. 40003850621, Valguma iela 4A-2, Riga, LV-1048, Phone: +371 67201190, Email: info@probaltic.lv, hereinafter referred to as the COMPANY.
The COMPANY’s contact information for issues related to personal data processing is: info@probaltic.lv.
General Provisions
- This Privacy Policy provides a general description of how the COMPANY processes and protects personal data. Detailed information about personal data processing and protection is outlined in contracts and internal regulations.
- The COMPANY ensures the confidentiality of personal data within the framework of applicable regulations and has implemented appropriate technical and organizational measures to protect personal data from unauthorized access, unlawful processing or disclosure, accidental loss, alteration, or destruction.
- The COMPANY may use data processors for personal data processing. In such cases, the COMPANY takes necessary steps to ensure that such data processors process personal data in accordance with the COMPANY’s instructions and applicable regulations and demands appropriate security measures.
- The COMPANY’s cookie policy is available on the COMPANY’s website under the “Cookie Policy” section.
Categories of Personal Data
- Personal data is collected both from the data subject and external sources, such as databases and registers available to the COMPANY. The categories of personal data that the COMPANY predominantly, but not exclusively, collects and processes are:
5.1. Identification data – first name, last name, personal identification number, date of birth;
5.2. Company contact information – address, phone number, email address;
5.3. Professional data (position, etc.) provided by the data subject, e.g., in their email signature;
5.4. Special categories of personal data;
5.5. Data obtained and/or created in the course of fulfilling obligations stipulated by regulations;
5.6. Satisfaction data – the data subject’s satisfaction with cooperation;
5.7. Data necessary for invoicing in Latvia and abroad according to regulations;
5.8. Data subject’s IP address information;
5.9. Other personal data depending on the type of service provided to the data subject.
Purposes and Legal Basis for Personal Data Processing
- The COMPANY processes personal data for the following purposes:
6.1. To ensure high-quality, timely, and convenient service to the Client during the validity of contractual relations with the COMPANY;
6.2. To manage Client relations (including remote relations), ensure the conclusion and performance of contracts, and implement related processes;
6.3. To verify Client creditworthiness to offer new and innovative products and services;
6.4. To handle Client complaints and provide support (including technical support) related to provided services;
6.5. For effective cash flow management, including Client payment and debt management;
6.6. To inform the Client about other products and services of the COMPANY’s group companies;
6.7. To promote industry development and offer new services to Clients;
6.8. To organize and maintain the COMPANY’s internal processes, document management, and other internal policies (e.g., contract and document archiving) in the necessary and sufficient volume.
6.9. The COMPANY is entitled to process data for the purposes listed below, as well as other purposes, with the data subject’s voluntary and explicit consent:
– Checking the Client’s personal data against debt history databases before concluding a contract to assess the Client’s ability to fulfill contract obligations; during the contract’s validity, such checks are necessary to offer the Client new and innovative products and services;
– Promoting the COMPANY’s image in the market by sending pleasant greetings, granting bonuses, conducting surveys for improving existing products and services, and creating new products.
- Legal Basis for Personal Data Processing:
7.1. Contract conclusion and performance – to conclude a contract based on the data subject’s request and ensure its performance;
7.2. Compliance with legal obligations – to fulfill obligations stipulated by regulations applicable to the COMPANY;
7.3. Based on the data subject’s consent;
7.4. Legitimate interests – to implement the COMPANY’s legitimate interests arising from obligations between the COMPANY and the data subject, or from the contract or law;
7.5. Providing and/or fulfilling services according to the data subject’s or Client’s price inquiry, order specification, web order, and/or other agreements;
- The COMPANY’s legitimate interests include:
8.1. Verifying the Client’s identity before concluding a contract;
8.2. Ensuring the performance of contractual obligations;
8.3. Retaining Client applications and submissions, including notes made verbally, over the phone, and via the website;
8.4. Conducting Client surveys on the COMPANY’s activities;
8.5. Ensuring and improving service quality;
8.6. Seeking protection of legal rights through law enforcement agencies.
Personal Data Protection
- The COMPANY protects personal data by utilizing contemporary technology options, considering existing privacy risks, and employing reasonably available organizational, financial, and technical resources, including implementing the following security measures and solutions:
9.1. Data encryption during transmission (SSL encryption);
9.2. Firewalls;
9.3. Intrusion protection and detection programs;
9.4. Other protective measures according to current technology development possibilities.
Recipients of Personal Data
- Personal data may be disclosed to the following recipients:
10.1. Companies within the COMPANY’s group to provide services to the Client;
10.2. Partners or agents involved in providing products and services ordered or used by the Client;
10.3. Debt collection agencies, credit bureaus, debt history database holders, or other debt recovery organizations;
10.4. Assignees – to ensure effective cash flow management, the COMPANY has the right to assign claims against the debtor or debtors.
10.5. Law enforcement agencies, courts, or other state and municipal authorities, if required by regulations or in response to a relevant authority’s information request;
10.6. Emergency services, if an emergency call is made to 112, including e-Zvans, including the data subject’s approximate location.
Geographical Area of Personal Data Processing
- Personal data is processed within the European Union / European Economic Area (EU/EEA). Personal data is processed at Valguma iela 4A-2, Riga, LV-1048.
- Personal data is processed Valguma ielā 4A-2, Rīga, LV-1048.
Retention Period
- Personal data is processed for as long as necessary to achieve the purposes of processing. The retention period is justified by the COMPANY’s legitimate interests, applicable regulations, or as long as the COMPANY’s Client’s consent for the relevant personal data processing is in effect, if there is no other legal basis for processing personal data.
- After the conditions mentioned in point 13 of this Privacy Policy end, personal data will be deleted.
Data Subject Rights
- To receive information prescribed by regulations about the processing of their personal data by the COMPANY.
- Under regulations, to request access to their personal data from the COMPANY, to supplement, correct, delete, or restrict its processing, to object to the processing of their personal data, including objections to processing based on the COMPANY’s legitimate interests, as well as the right to data portability and withdrawal of consent for the processing of personal data.
- To file a complaint about personal data processing with the Data State Inspectorate (www.dvi.gov.lv) if they believe that personal data processing violates their rights and interests according to regulations.
The COMPANY has the right to make changes or additions to this Privacy Policy by publishing the updated version of the Privacy Policy in the “Privacy Policy” section of the COMPANY’s website.