PRIVACY POLICY OF KOMEKS SIA

On the basis of Regulation No 2016/679 on the Protection of Personal Data.

Processing of Personal Data

  • KOMEKS SIA collects, processes, stores, copies, erases and protects the personal data of customers on the basis of Regulation No 2016/679 on the Protection of Personal Data, as well as other normative acts that are in force in the Republic of Latvia.
  • In accordance with existing laws related to the data processing system for individuals, KOMEKS SIA observes the following principles:
    • KOMEKS SIA ensures lawful and honest processing of personal data;
    • The processing of personal data received is carried out for specific purposes;
    • The received personal data are adequate and appropriate;
    • The received personal data are precise;
    • The data are not stored longer than necessary and are erased when the goal has been achieved;
    • KOMEKS SIA observes the rights of individuals when processing personal data;
    • KOMEKS SIA ensures that the personal data are stored safely;
    • KOMEKS SIA does not share personal data received with other companies, always observing secure and adequate protection on the basis of and in line with existing laws in Latvia, as well as Regulation No. 2016/679 on the Protection of Personal Data.

Privacy Policy

  • The privacy policy applies to the processing of each customer’s personal data, as well as to the services that are provided to the customer. The policy provides information about how KOMEKS SIA collects, processes, stores, copies, erases and protects the customer’s personal data. KOMEKS SIA ensures the lawful and honest processing of personal data.

Categories of Personal Data Processing

  • Categories of personal data depend on the services and products used by the customer. KOMEKS SIA has the right to process the following categories of personal data:
    • Data which the customer submits to KOMEKS SIA;
    • Name, surname, personal identity number or date of birth;
    • Correspondence address, telephone number and E-mail address;
    • Bank data;
    • Video surveillance recordings and images;
    • Communications data. Information from e-mails or letters related to the customer’s communication with the company;
    • Cookies – data on the visits of the website of KOMEKS SIA.
  • Should the customer wish to ban the use of cookies, it can be done in browser settings, but in that case access to the site may be limited:
    • Dates, times and time spent on the Internet.

Grounds for the Processing of Personal Data

  • Agreement from the customer. The customer, as the subject of personal data, provides agreement (subject’s agreement) to the collection and processing of personal data for specific purposes, with said agreement being based on free will and a personal decision that can be made or withdrawn at any moment, thus allowing KOMEKS SIA to process personal data.  Where agreement is withdrawn, that shall in no way affect the lawfulness of the processing or the quality of received services that are based on agreement before the withdrawal.
  • The legitimate interests of KOMEKS SIA that ensure the offer of high-quality services. KOMEKS SIA reserves the right to process personal customer data to the extent that is objectively necessary and sufficient to ensure timely, high-quality and comfortable services, as well as to establish and support internal processes at KOMEKS SIA. 
  • Meeting the legal obligations of KOMEKS SIA. KOMEKS SIA has the right to process personal customer data to satisfy legal requirements and to provide answers to lawful requests for information from state and local government agencies.
  • The conclusion and implementation of the agreement. KOMEKS SIA collects and processes certain data that are obtained before the agreement is concluded or during the term of the agreement so as to provide high-quality services to the customer.
  • Implementing public interests or implementation of official authority. KOMEKS SIA has the right to process personal data. In such cases the foundation for the processing of personal data is included in and described by normative acts.
  • When handling a customer’s personal data, KOMEKS SIA may conduct profiling to award bonuses, as well as to send automated individual offers that are offered only for business purposes and will create no legal consequences for the customer.

Reasons for the Processing of Personal Data

  • To conclude and implement the agreement with the customer.
  • To evaluate the ability of the customer to satisfy contractual obligations.
  • To ensure effective management of cashflows, including customer payments and administration of debts.
  • To provide technical support in relation to services that are offered.
  • To provide video surveillance and to protect KOMEKS SIA’s legitimate interests (ensuring the safety of its property).
  • To facilitate the development of the sector and make new service offers.
  • To process statistical data and engage in market analysis.

Obtaining Personal Data

  • KOMEKS SIA obtains personal data when the customer:
    • Purchases and uses products and services from KOMEKS SIA;
    • Takes part in competitions, lotteries or surveys;
    • Visits or browses KOMEKS SIA’s websites;
    • Is filmed with video surveillance equipment.
  • KOMEKS SIA and its authorised representatives have the right to process personal customer data that are received from third parties (e.g., a leasing company) if the customer has agreed to this, and this is done on the basis of Regulation No. 2016/679 on the Protection of Personal Data.
  • KOMEKS SIA and its authorised representatives have the right to process personal customer data that are received from the customer, doing so on the basis of Regulation No. 2016/679 on the Protection of Personal Data.

The Amount of Time for Keeping Personal Data

  • KOMEKS SIA has the right to process and keep personal data until:
    • The customer has withdrawn the right to process his or her data;
    • There is a time period necessary for the implementation and protection of KOMEKS SIA’s legitimate interests;
    • The time period for keeping personal data is indicated in normative acts;
    • Contractual obligations between the customer and KOMEKS SIA expire;
    • The goals of using personal data are achieved, as specified at the time when the goals were received.

Sharing of Personal Data

  • KOMEKS SIA provides customer personal data only at the necessary and sufficient level in accordance with legal requirements and taking into account the objective circumstances of the specific situation.
  • Where necessary, KOMEKS SIA transfers personal data to authorised representatives of KOMEKS SIA, doing so on the basis of Regulation No. 2016/679, and/or to partners, agents or service providers involved in ensuring and improving the quality of goods or services ordered or used by the customer.
  • KOMEKS SIA has the right to transfer customer data to law enforcement institutions and other state or local government institutions if required to do so by law or after the request for information from the relevant institution.

Protection of Personal Data

  • KOMEKS SIA uses modern technologies and takes into account technical and organisational requirements to protect the personal data of customer from unauthorised access, as well as accidental loss, destruction or disclosure of the data.
  • KOMEKS SIA carefully examines all authorised persons, partners, agents, service providers and company employees who process personal customer data, also evaluating the use of appropriate security steps and storage of personal data in accordance with legal requirements.
  • KOMEKS SIA bears no responsibility for any unauthorised access to personal data and/or the loss of personal data if that does not depend on KOMEKS SIA (e.g., the customer’s fault and/or negligence).

Rights of the Customer

  • The customer has the right to withdraw the right to receive commercial announcements at any time, as well as to object to the profiling of his or her data.
  • This withdrawal does not influence the lawfulness of the processing of personal data and/or the quality of received services, as based on the agreement before the withdrawal.
  • The customer has the right to amend all personal data about himself or herself that are at KOMEKS SIA disposal.
  • The customer has the right to demand the erasing or limiting of the processing of personal data that is no longer necessary in accordance with the reasons why it was collected and processed after the request was submitted (the “right to be forgotten”).
  • The customer has the right to obtain information about individuals or legal entities that have received information about the customer.
  • The customer has the right to receive or transfer his or her personal data to another data supervisor (“transferability of data”). This right includes only those data which the customer has provided to KOMEKS SIA on the basis of his or her approval or agreement and if the processing is automated. Written requests must be submitted to receive the aforementioned rights.