Privacy Policy

In implementing 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 and repealing Directive 95/46/EC (“General Data Protection Regulation”), we ensure that the processing of your personal data carried out on the website www.e-komercija.lv (“Website”) is clear, transparent and fair, and that your privacy and the security of your personal data are respected.

In this privacy policy you will find information about what personal data we collect and how we process it. We encourage you to read the terms of this privacy policy carefully before you provide us with any of your personal data.

In this privacy policy you can find the following information:

• Controller of your personal data
• Collection, processing, storage of personal data
• Legal basis for processing personal data
• Types of processing, categories of data and duration of processing
• Purposes for processing personal data
• Recipients of personal data
• Duration of storage of personal data
• Your rights
• Final provisions

1. Controller of your personal data

1.1. The controller of your personal data, which determines the purposes of collection, processing and storage of personal data on the Website, is SIA “eComStrive”, reg. 40003807192, legal address: “Briedēni”, Vestienas pagasts, Madonas novads, LV-4855.

1.2. We comply with the principles of data processing as set out in the legislation and are able to confirm that personal data is processed in accordance with the legislation in force.

2. Collection, processing, storage of personal data

2.1. Personal data means any information relating to an identified or identifiable natural person. Processing means any operation relating to personal data, such as obtaining, recording, transforming, using, consulting, erasing or destroying it.

2.2. We collect, process and store personally identifiable information primarily through the Website and email.

2.3. We obtain your personal data from you. You have provided your personal data directly, for example, by signing up for a consultation or other services provided by us, by signing up for free materials developed by us, by signing up for educational information(newsletter ), by submitting feedback, questions or complaints.

2.4. We only request your personal data that we objectively and reasonably need in order to provide you with services, provide you with requested materials, respond to your request or carry out other activities with your data.

2.5. If we need to obtain further information or investigate the circumstances in order to deal with your request or complaint effectively and impartially, we may link the data contained in your request to data already available to us or lawfully collected in the course of dealing with your request.
The categories and types of personal data we collect and process are set out in Section 4 of this Privacy Policy.

2.6. You are responsible for ensuring that the personal data you submit is correct, accurate and complete. Knowingly providing false information is considered a violation of our privacy policy. You are obliged to notify us immediately of any changes to the personal data provided.

2.7. Providing your personal data is voluntary, however, we inform you that if you do not accept all or part of this privacy policy, we regret that we will not be able to provide you with the opportunity to use all or any of the services we offer.

2.8. We are not liable for any damages suffered by you or third parties as a result of incorrectly submitted personal data.

2.9. If necessary, we have the right to check the accuracy of the data submitted using publicly accessible registers.

2.10. When processing and storing personal data, we implement organisational and technical measures to ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure or any other unlawful processing.

3. Legal basis for processing personal data

3.1. Your personal data is processed on the basis of the following subparagraphs of Article 6(1) of the General Data Protection Regulation:

• Article 6(1)(a): ‘thedata subject has given his or her consent to the processing of personal data concerning him or her for one or more specified purposes‘ (consent given by you).
• Article 6(1)(b): ‘processing is necessary for the performance of a contract to which the data subject is a party or for the performance, at the request of the data subject, of pre-contractual measures‘ (performance of a contract to which you are a party or pre-contractual measures).
• Article 6(1)(f): “processing is necessary for the pursuit of the legitimate interests of the controller or of a third party, except where the interests or fundamental rights and freedoms of the data subject which require the protection of personal data override such interests, in particular where the data subject is a child” (our legitimate interests).

3.2. In order to perform certain services offered on the Website, we require your personal data, which you provide by giving your consent by accepting the terms of this Privacy Policy. If you do not consent, we will not be able to contact you to arrange advice or services or to provide you with the materials and/or information requested on the Website.

3.3. Our legitimate interests on the basis of which we process certain of your personal data are the development, promotion and quality assurance of our services, ensuring compliance with our internal rules, and the protection of our legitimate interests in the event of a dispute or the defence of our legitimate interests in court.

4. Types of processing, categories of data and duration of data retention

Type of data processing	Categories and types of data	Duration of data storage
Providing advice	Your identification data: name, surname. Your contact details: telephone number, e-mail address. Additional information: name of the company represented, website address. Information on receiving advice: preferred date for receiving advice, the service you are interested in. Additional information: notes related to your application, if any.	As long as at least one of the following criteria exists: – there is a legal obligation to store the data for a certain period of time in accordance with laws and regulations; – it is necessary to pursue our legitimate interests; – it is necessary to comply with the obligations assumed.
Free material transfer	Your identification data: name, surname. Your contact details: telephone number, e-mail address. Additional information: name of the company represented.	Until you withdraw your consent to such processing of your personal data. You have the right to withdraw your consent at any time by sending a notice to info@e-komercija.lv.
Educational information	Your identification data: name. Your contact details: email address.	Until you withdraw your consent to such processing of your personal data. You have the right to withdraw your consent at any time by sending a notice to info@e-komercija.lv.
Examination of feedback and suggestions	Your identification data: name, surname. Your contact details: telephone number, e-mail address. Additional information: the content of your feedback or suggestion, recording the description of the feedback or suggestion, your request or opinion. Other documents or information (e.g. photographs) you have provided related to the feedback or suggestion.	Until such time as you withdraw your consent to such processing of your personal data. You have the right to withdraw your consent at any time by sending a notice to info@e-komercija.lv.
Dealing with questions and uncertainties	Your identification data: name, surname. Your contact details: telephone number, e-mail address. Additional information: the content of your question or concern, a description of the question or concern, your request. Other documents or information (e.g. photographs) you have provided related to the question or uncertainty.	While issues and/or uncertainties are being resolved and for 12 months after.
Handling complaints and resolving disputes	Your identification data: name, surname. Your contact details: telephone number, email address. Additional information: the content of your claim, which records a description of the claim or your opinion. Other documents or information (e.g. photographs) you have provided relating to the claim.	For as long as the claim exists and for 12 months after it is resolved.
Market research and statistics	Type of service, type of free material, number and content of complaints and feedback received – in encrypted form (anonymised data).	Anonymised data may be stored for an unlimited period of time.
Information security	Any personal data you provide that may help prevent fraud, defamation or other illegal activity, misuse of our services that may harm us or damage our reputation.	Until the security threat is addressed and the problem is solved.
Protection of legitimate interests	Any personal data you provide that may be or are necessary for the purpose (subject to the fundamental principles of data protection, in particular the principle of data minimisation).	For as long as the dispute or proceedings are pending, and for the purposes of any appeal, for the duration of the appeal.

5. Purposes of the processing of personal data

In order for us to process claims that you submit using forms on the Website or send to our customer service email, we need to process certain of your personal data. We collect and process your personal data in the following cases:

5.1. If you are applying for a consultation: you can apply for a consultation on the website by providing your personal data, which allows us to contact you and agree on the most suitable date and time for contacting you, as well as the topic or service you are interested in. The information you provide allows the specialist to prepare for the consultation by familiarising himself with the company you represent and studying your website.

5.2. If you apply for our services: you can apply for our services on the Website by providing your personal data, which allows us to contact you to clarify the information necessary for the quality and full performance of the services.

5.3. If you opt-in to receive our tailor-made materials: you can opt-in to receive tailor-made free materials on the Website by providing us with your personal data that allows us to send you the materials you choose. Subscribing to receive the tailored materials requires you to be added to our mailing list for educational information (see section 5.4 “Subscribing to receive educational information”).

5.4. If you subscribe to receive educational information(newsletter): you can subscribe to receive educational information by e-mail on the Website by providing your personal data in such a way that we can send you the relevant information in the form of an e-mail. Educational information will be sent to the e-mail address you have provided no more than 1 (one) time per month.

5.5. If you submit feedback or suggestions: you can submit feedback or suggestions on the Website by filling in the contact form in the contact section of the Website and providing your personal data which allows us to respond to your feedback if you request it or if the content of your message so requires, to address you and to respond to your message if necessary.

5.6. If you submit questions or concerns: you can submit a question or concern on the Website by filling in the contact form in the contact section of the Website and providing your personal data in a way that allows us to respond to your question, to address you and to respond to your message, if necessary.

5.7. Claims handling and dispute resolution: we process your personal data in the event that we need to handle a claim or resolve a dispute arising out of our services or your requests on the Website. We will also process your personal data in order to protect our rights in the event of disputes, to assess the dispute situation, collect evidence, file claims, defend our interests before state or local authorities or the courts, and to pursue our other legitimate interests in connection with the foregoing.

5.8. For market research: we process data about the information you provide for reporting and statistics to monitor, evaluate, improve and expand the online services and materials we offer. We analyse data such as how often you request a consultation on the Website, how many complaints we have received from you, how many free materials you have applied for, etc. However, we will not process your name, contact details or any other directly identifiable information that can directly point to you as a specific person. Such processing will be carried out on an anonymous basis.

5.9. We may also process your personal data to prevent fraud, defamation or other unlawful activity, misuse of our services which may harm us or damage our reputation.

5.10. To protect our legitimate interests: in addition to the above purposes, we may process your personal data to protect our legitimate interests. In the event of claims, demands or claims made against us, we may process any of your personal data necessary for the protection of our legitimate interests, unless your interests as a data subject or the fundamental rights and freedoms which require the protection of personal data override our legitimate interests.

6. Recipients of personal data

6.1. In order to fulfil our obligations to you, your personal data may be made available to other parties who provide services to us such as server maintenance, email delivery, file transfer, marketing, systems development and maintenance.

6.2. These service providers may only process your personal data in accordance with our instructions and in compliance with data protection rules and requirements.

6.3. In order to comply with our legal obligation, as well as to pursue our legal interests and defend our rights, we are entitled to provide your personal data to law enforcement authorities and other state or local authorities upon their request in accordance with the law. In order to protect our legitimate interests, your personal data may be transferred to legal service providers, such as a law firm.

6.4. Your personal data is not transferred to or processed in a country outside the European Economic Area.

7. Duration of storage of personal data

7.1. Your Personal Data will only be kept for as long as necessary for the purposes and in accordance with the criteria set out above (see Section 4).

7.2. We store and process your personal data for as long as at least one of the following criteria applies:

• Personal data is necessary for the purposes for which it was received.
• While we and/or you may exercise your legitimate interests in accordance with the procedures set out in external laws and regulations, such as by lodging an objection or bringing or pursuing legal action.
• As long as there is a legal obligation to keep the data, such as under the Accounting Law.
• As long as your consent to the processing of your personal data is valid, unless there is another lawful basis for processing your personal data.

7.3. Upon termination of the circumstances referred to in the preceding paragraph, the retention period of your personal data shall also terminate and all relevant personal data shall be permanently erased from the computer systems and electronic documents that contained the relevant personal data, or such documents shall be anonymised.

7.4. In the event of legal action, your personal data may be stored until the end of the legal proceedings, including any appeal periods.

8. Your rights

In accordance with the General Data Protection Regulation and the legislation of the Republic of Latvia, you have the following rights in relation to the collection, processing and storage of your personal data:

8.1. You have the right to obtain our confirmation as to whether we process your personal data, as well as the right to see the personal data we process about you and information about the purposes of the processing, categories of data processed, categories of data recipients, the period of processing, the sources of the data, automated decision-making, including profiling, as well as its meaning and consequences for you.

8.2. You have the right to access your personal data, receive information about its processing and request a copy of your personal data in electronic format.

8.3. You have the right to transfer your personal data to another controller (data portability). This right only applies to data that you have provided to us on the basis of consent and where processing is carried out automatically. To exercise your right to data portability, you can make a request to customer service by sending an email to info@e-komercija.lv.

8.4. You have the right to request the rectification of incorrect, inaccurate or incomplete personal data If the data you provided at the time of registration has changed or you see that the information we process about you is inaccurate or incorrect, you have the right to request that this information be changed, updated or rectified. To exercise your right to rectification, you can make a request to Customer Service by sending an email to info@e-komercija.lv.

8.5. You have the right to request the erasure of your personal data, except where required by law to retain the data. In certain circumstances (e.g. where personal data are unlawfully processed, the lawful basis for processing ceases to exist, personal data are no longer necessary in relation to the purposes for which they were collected) You have the right to ask us to erase your personal data. However, this does not apply in cases where we are required by law to retain the data. To exercise your right to erasure, you can make a request to Customer Service by sending an email to info@e-komercija.lv.

8.6. You have the right to withdraw your prior consent to the processing of your personal data Where we process your personal data on the basis of your consent, you have the right to withdraw your consent to the processing of your personal data at any time. For example, you can withdraw your consent to receive educational information, offers and newsletters at any time. Withdrawal of these consents will not restrict you from continuing to use the Website and services, but it will mean that we will not be able to provide and you will not be able to receive information, offers and news that are relevant to you. You may correct (withdraw or re-give) your consent by submitting your duly updated registration information on the consent given, by contacting our customer service, by sending your application to the email address info@e-komercija.lv.
Once your consent is withdrawn, we will stop processing data based on consent and, in the cases specified in this Privacy Policy, we will delete or anonymise the data. However, in any event, we may retain evidence of your consent for a longer period if this is necessary to enable us to defend our legitimate interests against claims, demands or claims made against us.

8.7. You have the right to restrict the processing of your data. You can request that we temporarily stop processing all your personal data altogether. In certain circumstances (e.g. where personal data is being processed unlawfully, you contest the accuracy of the data, you object to the processing for the purposes of our legitimate interests) You have the right to restrict the processing of your personal data. However, please note that due to the restriction of processing and for the period of the restriction, we may not be able to provide services to you.

8.8. You have the right to contact the Data Inspectorate. Please be informed that under the General Data Protection Regulation you have the right to lodge a complaint with the Data Inspectorate in case of unjustified or unlawful processing of your personal data.

In order to exercise your rights described in this Privacy Policy, as well as to make other requests in relation to the processing of your personal data, you may submit a request by sending an e-mail to the following e-mail address: info@e-komercija.lv. The request must specify that the request relates to the processing of your personal data and should be as specific and clear as possible.

9. Final Provisions

The Data Controller shall have the right to make changes or additions to this Privacy Policy at any time and without prior notice. Amendments shall take effect upon their publication on the website www.e-komercija.lv. We therefore encourage you to review this Privacy Policy periodically to ensure that you are aware of any changes and to read it carefully whenever you are asked to confirm that you have read this Privacy Policy by taking any action on the Website.