1. Data of the Controller
AS “Putnu fabrika Ķekava”,
Registration No.: 50003007411
Registered address: “Putnu fabrika Ķekava”, Ķekava, Ķekavas pagasts, Ķekavas novads, LV-2123, Latvia
Contact for communication regarding protection of personal data: firstname.lastname@example.org
2. General description of personal data processing we undertake
Whenever processing personal data, we ensure compliance with the 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), the Law on Personal Data Processing and requirements of other regulatory acts applicable in Latvia.
Personal data – any information regarding an identified/identifiable natural entity (Data Subject).
Processing of personal data – any handling of personal data, such as their collecting, registration, arrangement, structuring, storage, access, modification, deletion, disclosure, transfer, restrictions, and other actions.
You provide your personal data to us on a voluntary basis. If, however, you do not provide certain information we may be unable to achieve some of the goals described in this Policy.
We understand that you highly value your personal data, and we shall process them in compliance with the confidentiality requirements and take care of security of your personal data at our disposal.
3. Purposes and legal grounds of personal data processing
Purposes of personal data processing are related to the company functions. Basically, we collect personal data to meet contractual obligations or to meet legal duties binding upon us and to pursue our legitimate interests. If this is the case, collecting of certain information is required to achieve specific purposes, and therefore non-provision of such information can affect the entering into business relations, performance of a contract or security of the company. In case of data that are not necessarily required yet their collecting can help to improve our service or make beneficial proposals to you, the voluntary nature of data provision shall be indicated upon the collecting of data.
We process personal data for the following purposes:
- Personnel recruitment and management
- Provision of effective business management process
- Drafting, entering into and administration of contract
- Business planning and analytics
- Marketing activities (competitions, lotteries, opinion polls)
- Provision of security, elimination of threat to property interest (CCTV, access control). We process your personal data in order to prevent, control and identify criminal offences against property and assets (theft, vandalism, etc.) and to protect vital personal interests.
Personal data processing is based on the following legal grounds or their combination:
- As a data subject, you have consented to the processing of your personal data for one or several purposes.
- Processing is required for the performance of the contract in which data subject is a contracting party, or for taking steps at the data subject’s request prior to the entering into the contract.
- Processing is required to meet a legal obligation binding upon us.
- Processing is required to protect vital interests of the data subject or other natural entity
- Processing is required to pursue our legitimate interests.
4. Personal data we process
Information contained in your CV: name, surname, personal number, residence address, work and study/education experience, knowledge and use of languages, other knowledge/costs, interests/hobbies, telephone number, e-mail address, photo or other identification information as well as information collected from your reference sources, provided that you have expressly consented to the contacting of such persons. If you are invited to a job interview, the information provided, tests completed and other test material collected during the job interview shall be treated as your personal data.
Information required for cooperation, entering into partnership agreements: name, surname, contact information (email, telephone number, etc.) of the business partner; other information prescribed by legal acts.
Participants of marketing activities
Information required for identification of person and communication for collecting prizes (name, surname, contact data: e-mail, telephone number); photos, video records and other personal data required according to the lottery rules.
Visitors of the company
Information required for identification of person and maintenance of the access control (name, surname, name of represented company) as well as video recorded during your visit including your images and other personal data from locations with CCTV.
Information provided by you in e-mails, applications and letters addressed or calls made to us.
Visitors of shopping areas of the company
Video recorded during your visit including your images and other personal data from locations with CCTV.
Visitors of the company websites
Use of IP addresses
We do not store your IP addresses. They are only available to third party tracing tools, such as Google Analytics. Further information about Google Analytics is available at: https://support.google.com/analytics/answer/2763052
5. Location of personal data processing
We take the benefits of modern technologies in the processing of personal data, taking into consideration the existing privacy risks and the organizational, financial and technical resources reasonably available to us.
We do not transfer data to any countries outside the European Union or the European Economic Area.
We do not use your personal data for automated decision-making.
6. Recipients of personal data
We take appropriate steps to ensure processing of your personal data in compliance with the applicable legal acts and to ensure that no third parties can access to your personal data without appropriate legal grounds to process your personal data.
Your personal data can be accessed as appropriate by:
- Our employees or expressly authorized persons for the purpose of performance of their job duties;
- Providers of personal data processing according to the provided services only to the required extent, such as auditors, finance management and legal advisors, the entity responsible for development / technical maintenance of database, other persons involved in the provision of our services;
- Public and municipal authorities on the occasions listed in legal acts, such as law enforcement authorities, municipalities, tax administration, certified enforcement officers;
- Third parties, subject to thorough assessment of whether or not there are appropriate legal grounds for transfer of such data, such as debt collectors, judicial authorities, extra-judicial dispute settlement authorities, bankruptcy/insolvency administrators, third parties responsible for register keeping (such as Population Register, Register of Debtors, other registers).
7. How long we store personal data
Your personal data shall be stored as long as their storage ir necessary for the respective personal data processing purposes, and in accordance with the requirements of the applicable legal acts.
We consider the period of storage of personal data with due regard to requirements of the applicable legal acts and performance aspects of contractual obligations as well as your instructions (in case of consent, for example) and our legitimate interests. We shall delete or destroy your personal data as soon as they are no more necessary for the given purposes.
Please see the most common periods of personal data storage below:
- We store personal data required for performance of contractual obligations until completion of the contract and expiration of other storage periods;
- We store personal data required to meet the requirements of legal acts during the periods prescribed by the respective regulatory acts; for example, the Law “On Accounting” stipulates that supporting documents shall be stored as long as they are necessary to identify the starting point of each commercial transaction and to trace the progress thereof, subject to the minimum of 5 years;
- The data necessary to demonstrate performance of our obligations shall be stored during the overall lapse period in accordance with the lapse periods prescribed in respect of claims by regulatory acts – 10 years in the Civil Law, 3 years in the Commercial Law, and other periods, taking also into consideration the periods prescribed by the Civil Procedure Law for filing of claims.
8. Rights of data subjects in relation to the processing of personal data
Renewal of personal data
If the personal data provided to us change, for example, change of name, surname, communication address, telephone number or e-mail address, please contact us and provide the actual data so that we are able to achieve the respective purposes of personal data processing.
Your right to access and correct your personal data
According to the provisions of the General Data Protection Regulation you have the right to request access to your personal data at our disposal and to claim their correction, deleting, restriction of processing, or to object against processing of your data, as well as the right to portability of data on the occasions and according to the procedure stipulated in the General Data Protection Regulation.
Our company respects your right to access and control your personal data; therefore, a reply to your request shall be issued within the periods prescribed by regulatory acts (normally within one month unless longer period is necessary to prepare a reply in case of special request) and we shall correct or delete your personal data accordingly insofar possible.
Information about your personal data in our possession can be obtained or other rights of a data subject can be exercised in one of the following ways:
- By filing a corresponding application and identifying yourself in person in our offices at: “Putnu fabrika Ķekava”, Ķekava, Ķekavas pagasts, Ķekavas novads, LV-2123, on weekdays from 9:00-16:00;
- By e-mailing a corresponding application signed with secure electronic signature to our e-mail address: email@example.com.
Once your application is received we shall review the content thereof and the possibility to identify you and, depending on the situation, we reserve the right to ask additional identification to ensure security of your data and their disclosure to an authorized person.
Withdrawal of consent
Where processing of your personal data is based on your consent, you have the right to withdraw your consent at any time, and your personal data we process on the basis of such consent shall not be processed for the given purpose any more. Please note, however, that withdrawal of consent shall not affect the processing of personal data necessary to meet the requirements of regulatory acts or based on contract or our legitimate interests, or other grounds prescribed by regulatory acts for lawful data processing.
You can also object to the processing of your personal data based on legitimate interests or used for marketing purposes (such as sending of commercial notifications or participation in lotteries unless the processing of such data is specifically required by regulatory acts).
In case of any questions or objections related to the processing of your personal data by our company please first contact us.
If you still believe we have not been able to resolve the issue and you believe we continue infringing your right to the protection of personal data, you have the right to file a claim with the Data State Inspectorate. Template applications to the Data State Inspectorate and other related information is available on the website of the Data State Inspectorate (www.dvi.gov.lv).