1. Terms used in the Privacy Policy
1.1. The company is SIA Pleroma.
1.2. VDAR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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).
1.3. Personal data – any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as his name, identification number, location data, online identifier or one or more physical, physiological, genetic, factors of spiritual, economic, cultural or social identity.
1.4. Processing of Personal Data – any activity or set of activities performed with Personal Data or Personal Data Sets, with or without automated means, such as data collection, registration, organization, structuring, storage, adaptation or modification, retrieval, viewing, use, disclosure, sending, distributing or otherwise making available, harmonizing or combining, restricting, deleting or destroying them.
1.5. Controller – a natural or legal person who alone or jointly with others determines the purposes and means of personal data processing.
1.6. Processor – a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.
1.7. Customer – a legal or natural person who, in person or remotely, uses the services offered by the Company.
1.8. Cooperation Partner – a legal or natural person who provides its services to the Company and who does not process the Personal Data held by the Company on behalf of the Company.
1.9. Data subject – directly or indirectly identified or identifiable natural person, including all SIA Pleroma Customers, Cooperation Partners, and their designated contact persons or authorized persons, as well as all potential and existing Employees of the Company with whom an employment relationship has been established, concluded employment or company agreement.
2. General provisions
2.1. This Privacy Policy (hereinafter – the Privacy Policy) is the Company’s rules designed to provide information on the purposes of the Company’s processing of Personal Data, legal basis, scope, protection, processing, and retention period, sources of Personal Data, recipients of Personal Data, and The rights of the data subject during the acquisition and processing of personal data.
2.2. The Privacy Policy applies to ensuring the protection of privacy and Personal Data with respect to:
2.2.1. natural persons, namely, the Company’s Customers, Processors, Employees, as well as third parties, who are indicated as contact persons or authorized persons during the provision of services or cooperation offered by the Company;
2.2.2. legal persons, if their name contains data of natural persons or according to the information provided by them it is possible to directly or indirectly identify a natural person.
2.3. The Privacy Policy applies to the processing of Personal Data regardless of the form and / or environment in which the Data Subject provides Personal Data (in writing, by telephone, on a website, in paper format or by e-mail, etc.) and in which Company systems or forms it is processed. .
2.4. Law applicable to the processing of the Company’s Personal Data:
2.4.1. VDAR;
2.4.2. Civil Law of the Republic of Latvia;
2.4.3. Advertising law;
2.4.4. Personal Data Processing Law;
2.4.5. Commercial law;
2.4.6. Labor law;
2.4.7. Labor Protection Law;
2.4.8. Law “On Accounting”;
2.4.9. Cabinet of Ministers 21.10.2003. regulations no. 585 “Regulations on Accounting and Organization”.
3. Information about the Manager
3.1. The manager is the Company: SIA “Pleroma”, unified registration No. 52103110351, legal address: Meža iela 55, Babīte, Mārupes novads, LV-2101, phone: +371 26519197, e-mail address: jolanta@pleromaway.com.
3.2. For questions related to the processing of Personal Data by the Company, please contact the Company’s contact person for Personal Data Processing: Jolanta Garda, phone: +371 26519197, e-mail address: jolanta@pleromaway.com. Using this contact information, Data the entity may submit a request for the exercise of its rights in accordance with Section 12.2 of the Privacy Policy. subparagraph.
4. Legal basis for personal data processing
4.1. The Company processes Personal Data on the basis of the following legal bases referred to in Article 6 of the GTC:
4.1.1. for concluding and executing a contract – for the Company to provide the business advising services requested by the Client, performing service sales transactions, to draw up, conclude and ensure a proper contract, including employment contract, company contract with Employees, execution or amendment of service contracts with Clients after concluding contracts, as well as termination of the relevant contractual obligations;
4.1.2. for the fulfillment of legal obligations specified in external regulatory enactments, so that the Company, in accordance with the binding and effective regulatory enactments of the Republic of Latvia and the EU, fulfills the legal obligations to itself, the Data Subject, state and municipal institutions, as well as third parties meet the requirements for the provision of services, determine the amount of the Employee’s salaries, additional remuneration and allowances, social contributions and taxes and be able to pay them, book and inform the responsible authorities, record and could provide the Employee with legally due leave or other days of absence, to ensure appropriate and safe working conditions and the environment, to terminate the legal employment relationship in accordance with the procedures prescribed by law;
4.1.3. For the implementation of the Company’s legitimate interests in order to implement the Company’s legitimate interests arising from the obligations between the Company and the Data Subject, including:
4.1.3.1. to ensure and improve the quality of the service requested by the Customer;
4.1.3.2. to ensure efficient financial and business accounting and analytics, as well as efficient Company management processes;
4.1.3.3. prevent unjustified financial risks;
4.1.3.4. to prevent fraud and theft;
4.1.3.5. to implement the Company’s direct and digital marketing strategies, analysis and accounting of results;
4.1.3.6. to verify the identity of the Data Subject before concluding the agreement;
4.1.3.7. to ensure the fulfillment of the obligations of the concluded agreement;
4.1.3.8. apply to state administration, operational activities and judicial institutions for protection of the Company’s legal interests.
5. Purposes of personal data processing and categories of processed Personal Data
5.1. The Company may hold and process the following Personal Data of the Data Subject and other information provided by the Data Subject, which may be considered as Personal Data in cases where it is possible to directly or indirectly identify the Data Subject and are used for the following purposes:
5.1.1. for concluding, executing or amending an agreement with the Data Subject, ie the Customer or the Cooperation Partner, after concluding the agreement, issuing invoices, as well as communicating with the Data Subject during the commencement and execution of the service or cooperation:
5.1.1.1. Name and surname of the Customer, Cooperation Partner or their contact person or authorized person;
5.1.1.2. Customer’s, Cooperation Partner’s or authorized person’s personal identification code;
5.1.1.3. E-mail address of the Customer, Cooperation Partner or their contact person or authorized person;
5.1.1.4. Telephone number of the Customer, Cooperation Partner or their contact person or authorized person;
5.1.1.5. Declared or actual address of residence of the Customer, Cooperation Partner or their contact person or authorized person;
5.1.1.6. Name of the Client or Cooperation Partner, which is a legal entity;
5.1.1.7. Registration number of the Client or Cooperation Partner, which is a legal entity;
5.1.1.8. Legal address of the Client or the Cooperation Partner, which is a legal entity;
5.1.1.9. Name and surname of the Customer or Cooperation Partner, who is a legal entity, representative or authorized person;
5.1.1.10. Position of the Client or the Cooperation Partner, which is a legal entity, representative or authorized person;
5.1.1.11. Telephone number of the Customer’s or Cooperation Partner, who is a legal entity, representative or authorized person;
5.1.1.12. E-mail address of the Customer or Cooperation Partner, who is a legal entity, representative or authorized person;
5.1.1.13. Written signature of the Customer or the Cooperation Partner or their representative or authorized person, indicated on the concluded agreements, their additions or amendments;
5.1.2. for the commencement of legal employment relations, namely, for the identification of an employee, development, conclusion and proof of the fact of conclusion of an employment or company contract, submission of information to the State Revenue Service or other public administration institutions in the cases specified in external regulatory enactments:
5.1.2.1. Name and surname of the employee;
5.1.2.2. Employee personal identification code;
5.1.2.3. Actual or declared address of residence of the employee;
5.1.2.4. Employee’s position in the Company and specialty according to the Classification of Professions;
5.1.2.5. Date of commencement of the employee’s employment relationship;
5.1.2.6. The amount of the employee’s salary;
5.1.2.7. Employee’s bank details to which the salary will be paid;
5.1.2.8. Written signature of the employee, which is indicated on the concluded agreement and other internal documents of the Company;
5.1.2.9. information regarding the Employee’s dependents or the Employee’s disability, for the purpose of determining tax relief;
5.1.3. for the maintenance of legal employment relations, ensuring the conditions necessary for the performance of work, implementation of the Company’s legitimate interests, performance of the duties specified in the Company’s external regulatory enactments as an employer and in the agreement concluded with the Employee, in addition to 5.1.2. the data referred to in subparagraph:
5.1.3.1. information regarding the employee’s accumulated, withdrawn and remaining vacation period;
5.1.3.2. information regarding the health condition of the Employee or the health condition of the family members, the fact of the birth of the child and the number of children in the family statutory absences, including incapacity for work, childcare and paternity leave, additional leave, use and to receive benefits.
6. Processing of special categories of personal data
6.1. In order to ensure compliance with the legal requirements and the fulfillment of the Company’s legal obligations as an employer, the Company may process the following special categories of Personal Data:
6.1.1. information regarding the health condition of the Employee or the health condition of the family members, the fact of the birth of the child and the number of children in the family, the absences provided by law, including incapacity for work, parental and paternity leave, additional leave, benefits and benefits.
7. Sources of personal data acquisition
7.1. The Personal Data of the Data Subject held by the Company is obtained from the following sources on the basis of the legal bases of data processing referred to in Paragraph 4:
7.1.1. Personal data submitted by the Data Subject in person or remotely, including through the Company’s website www.pleromaway.com or the “Pleromaway” Facebook page;
7.1.2. Personal data submitted by the Customer or the Cooperation Partner regarding its representative, authorized person or contact person appointed during the provision of the service or cooperation;
7.1.3. Personal Data submitted by the Processor or its authorized person for the conclusion and performance of the agreement with the Processor;
7.1.4. information provided by third parties, if such receipt is provided for by regulatory enactments.
8. Processing of personal data in the Company
8.1. Personal data is processed fairly, lawfully and in a way that is transparent to the Data Subject, using the organizational, financial and technical resources reasonably available to the Company.
8.2. Personal data are collected for specified, explicit and legitimate purposes and not further processed for purposes other than those for which they were originally intended or incompatible with those purposes.
8.3. Personal data are stored in such a way that the Data Subject can be identified from them for no longer than is necessary for the purposes for which the data were obtained or processed. The terms of storage of the Company’s Personal Data are specified in Clause 11 of the Privacy Policy.
8.4. Personal data are obtained in accordance with the principle of minimization of data processing, which means that the data are adequate, relevant and include only what is necessary for the purposes of their processing.
8.5. The Company ensures the accuracy of the Personal Data and, if necessary, the Personal Data is updated according to the current information or deleted.
8.6. Personal data is processed in such a way as to ensure adequate security of the Personal Data, namely protection against unauthorized or illegal processing, accidental loss, destruction or damage.
8.7. In order to ensure the fulfillment of obligations to the Data Subject, the Company is entitled to attract and authorize external service providers to perform certain activities on behalf of the Company. If, in performing these tasks, the Company’s authorized persons process the Data Subject’s data held by the Company, the performers of the respective task shall be considered as Processors of Personal Data held by the Company and the Company has the right to transfer to the Processors the Personal Data activities.
8.7.1. In cases where the Company authorizes the Processors to perform a certain task, both the Company and the Processors ensure the protection of Personal Data processing in accordance with the requirements of the GDR, as well as do not use Personal Data for purposes other than fulfilling the established obligations to the Data Subject.
9. Protection of personal data
9.1. The Company protects the Personal Data of the Data Subject using the possibilities of modern technologies, taking into account the existing privacy risks and the organizational, financial and technical resources reasonably available to the Company, including by using the following security measures:
10.1.1. provides Personal Data stored in IT systems with protection against unauthorized access, password protecting the internal systems, electronic mail and databases used by the Company;
10.1.2. provides limited access to the Company’s office premises only to Data Subjects employed by the Company;
10.1.3. use firewalls and antivirus programs;
10.1.4. ensure that the persons handling the Personal Data managed by the Company are properly trained and have received appropriate and clear instructions on the processing of the data to be performed, including the security instructions included in the Privacy Policy;
10.1.5. ensures that Personal Data is not made publicly available or disclosed to third parties without permission.
11. Terms of personal data storage
11.1. The Company processes the Personal Data in its possession as long as the following conditions are met:
11.1.1. while the process of execution of the service provided by the Company is in progress;
11.1.2. as long as the concluded contractual obligations with the Data Subject are valid;
11.1.3. as long as the Personal Data is necessary for the purpose for which it was received;
11.1.4. for as long as necessary to ensure the realization of the legitimate interests of the Company or the Data Subject, for example, to enable the Company or the Data Subject to file objections or bring an action in court, while the defendant – to defend his rights;
11.1.5. as long as one of the parties has a legal obligation to store the data, for example in accordance with the Civil Law, the Commercial Law or the Law “On Accounting”.
11.2. When none of the 11.1. is no longer applicable, the Personal Data is deleted.
11.3. Paper documents are kept in accordance with the deadlines specified in regulatory enactments, but not longer than 5 years, as well as in certain cases to ensure the Company’s legitimate interests, such as contractual obligations, debt collection, in case of potential litigation, limitation period.
12. Rights of the Data Subject and access to his / her Personal Data
12.1. The Data Subject has the right to receive information on what Personal Data is under the Company’s management in connection with the processing of the Data Subject’s Personal Data and to request access to, rectification, supplementation or deletion of its Personal Data, restrict data processing and object to it, including Processing of personal data, which is performed on the basis of the Company’s legitimate interests, as well as to exercise the right to data portability, insofar as the Company is technically able to provide it. The rights of the data subject are exercised to the extent that it does not contradict the obligations of the Company specified in regulatory enactments.
12.2. The Data Subject may submit a request for the exercise of his / her rights by sending a completed form on the website www.pleromaway.com on the exercise of the Data Subject’s rights to the Company’s contact person for personal data processing issues to the e-mail address: jolanta@pleromaway.com.
12.3. Upon receipt of a request to exercise the rights of the Data Subject, the Company verifies the identity of the Data Subject, evaluates the request and executes it in accordance with regulatory enactments.
12.4. The Company shall send the response to the Data Subject’s e-mail address within 30 days from the moment when the Company’s contact person for Personal Data Processing has received the Data Subject’s request, or by sending it by post, in the form of a registered letter. If there is a need to clarify the information or carry out a more detailed study before replying, the reply may take longer than 30 days, depending on the content of the request, but not longer than 60 days.
12.5. In cases when Personal Data is processed on the basis of external regulatory enactments, on a contractual basis, or in order to implement the Company’s legitimate interests, the personal data deletion request may not be executed, of which the Data Subject is informed within 30 days from the Company’s contact person. received a request for erasure. The answer is provided with a clear, unambiguous justification as to why the deletion of Personal Data is not possible. On the other hand, in case of receiving a substantiated request for deletion of Personal Data, appropriate deletion of Personal Data is ensured within 30 days from the receipt of the Data Subject’s request.
12.6. Disputes related to the processing of Personal Data shall be resolved through negotiations between the Data Subject and the Company. If the Data Subject considers that its processing of Personal Data violates the rights and interests of a person in accordance with applicable laws and regulations, the Data Subject has the right to file a complaint with the Company’s contact person for Personal Data Processing by submitting a completed Complaints about Personal data processing form performed by the Company, or by contacting the State Data Inspectorate of the Republic of Latvia, address: Blaumaņa Street 11 / 13-11, Riga, LV-1011, Latvia, e-mail address: info@dvi.gov.lv.
13. Other provisions
13.1. The Company is constantly developing its operations and improving its services, as well as maintaining cooperation with Cooperation Partners, therefore, the Privacy Policy can be changed or supplemented at any time.
13.2. The current version of the Privacy Policy is always available on the Company’s website at www.pleromaway.com. At the same time, the current version of the Privacy Policy, as well as previous versions, are available by contacting the Company’s contact person for Personal Data Processing.
13.3. Your purchase of a product or service or ticket to an event may or may not provide for any refund. Each specific product, service, event or course will specify its own refund policy.
