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Privacy Policy

Personal Data Processing Statement for Visitors and Customers, Partners, Vendors, and their Contacts

The purpose of this statement is to ensure transparency in the processing of personal data that we have carried out, to provide information to you about the processing of personal data that we have made, its purposes and the legal basis, and to provide you with information about your rights and how they can be used.

This is the current version of the Personal Data Processing Statement, which becomes effective on 25 May 2018. We have the right to amend and to supplement this statement as necessary.

1. Controller of the processing of personal data

The controller of the processing of personal data is SIA “Skonto Plan Ltd” (hereinafter referred to as the Company), Registration No: 40003079615, registered office: Rūpniecības Street 6, Tukums, LV-3101, Latvia, Contact details: Telephone No +371 63165100, email address: skontoplan@skontoplan.lv

2. Purpose and legal basis for the processing of personal data

We shall ensure fair and lawful processing of personal data by processing your personal data only for specific, pre-defined purposes and with appropriate legal basis. We are processing your personal data for the following purposes:

2.1. For the conclusion and execution of a contract

In order to conclude and to execute certain types of contracts (on the execution of a project, on the provision of goods or services, cooperation agreements, delivery contracts), we need to process the following personal data: the customer’s, cooperation partner’s or supplier’s identification data (e.g. name, personal identity number); contact information for communication (e.g. job position, e-mail, telephone number, address); information required to make payments (for example, account number). In the course of conclusion and execution of the contract, we shall also process other types of information provided to us by our 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 main legal bases for the processing of these data are:

  • processing is necessary in order to take steps prior to entering into a contract or forthe 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 law “On Accounting”;
  • 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).

2.2. 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 main legal basis for the processing of these data is:

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

2.3. 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 at Rūpniecības Street 6, Tukums, Latvia. 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 theterritory (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).

2.4. Promoting the Company profile

Within the scope of this purpose, the Company organizes events for its 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 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 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).
3. 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, 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, 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. If data are not required on a mandatory basis, but providing the same could help to improve our cooperation, we will point out that the provision of data is voluntary before data is collected.

4. 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.
5. 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) countries.

6. Is your personal data used to make automated decisions?

Your personal data is not used to make automated decisions.

7. How does the period is determined to store your personal data?

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, for example, in the Laws on Accounting requires that the supporting documents have to be stored until the date when those are necessary to establish the beginning of each economic transaction and to track its progress, but for at least 5 years;
2) in order to ensure the ability to prove the fulfilment of one’s obligations or to require fulfilment of the other party's obligations, for 3 or 10 years in accordance 2) with the type of transaction and the claim limitation period specified in the regulatory enactments.
We will store video records for 2 months in order to provide evidence in the event of an incident being  found and to detect potential criminal offences.
We'll store the data processed as part of marketing activities for 2 years after the appropriate event and erase those data after the period of 2 years.

8. Your rights

In accordance with the provisions of the General Data Protection Regulation, you are entitled to have access to your personal data being at our disposal, to request their rectification, erasure, restriction of processing, to object to the processing of your data, as well as the right to data portability in the cases and under procedures set out in the General Data Protection Regulation.
You may also object to the processing of your personal data if the processing of personal data is based on legitimate interests.
We respect these your rights to access and to control your personal data, so if you receive your request, we will respond to it within the time limits laid down in the regulatory enactments and, if possible, rectify or erase your personal data accordingly.
You may obtain information about your personal data we keep or exercise other rights of your data subject in one of the following ways:
1) by submitting an appropriate application in person and identifying yourself at our office according to address: SIA “Skonto Plan Ltd”, Rūpniecības Street 6, Tukums, LV-3101, Latvia (or Jūrkalnes Street 15/25, 3 rd floor, Rīga, LV-1046, Latvia), every working day from 8:00 a.m. to 5:00 p.m.;
2) by submitting an appropriate application, sending it to us by post to the following address: SIA “Skonto Plan Ltd”, Rūpniecības Street 6, Tukums, LV-3101, Latvia;
3) by submitting an appropriate application, sending it to our e-mail: datu.aizsardziba@skontoplan.lv, by signing the application with a secure electronic signature.
Upon receipt of your submission, we will evaluate the content and the possibility of identifying you, and, depending on the situation, we reserve the possibility of asking you to further identify yourself in order to ensure the security and disclosure of your data to the person concerned.

9. 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. If you consider that your rights in the field of personal data protection have been infringed, you are entitled to lodge a complaint with the State Data Inspectorate.

1 - 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)