1. Document purpose and application
1.1. The purpose of the present document is to provide information to a natural person (data subject) about the procedure by which the limited liability company SIA "BSMS" carries out processing of personal data.
1.2.1. To the Clients (including former Clients) and their representatives, cooperation partners and their representatives, as well as third parties who receive from, or transfer to the limited liability company SIA "BSMS" any information (for example, contact persons of legal entities, etc.);
1.2.3. To the users of Internet resources and mobile applications maintained by the limited liability company SIA "BSMS".
2. Abbreviations and terms
2.1. The present document utilises the following set of terms:
2.2. Terms not defined in this document are used in accordance with the General Data Protection Regulation, other regulatory enactments regulating the field of personal data protection and the field of trust and electronic identification services.
3. General provisions
3.1. The company SIA "BSMS" considers the protection of personal data to be critically important and takes care that personal data is collected and processed in accordance with the laws and regulations in force in the Republic of Latvia, the General Data Protection Regulation and other applicable legislation in the field of privacy and data processing.
3.2. The company SIA "BSMS" is aware of the importance of a person's right to privacy and has implemented technical and legal measures to control and protect personal data in accordance with the available technological, financial and organizational capabilities. The company SIA "BSMS" has evaluated and determined appropriate physical, technical, logical and organizational measures in order to reduce and protect security risks in order to ensure the security, integrity and privacy of personal data.
3.4. The controller of personal data is the limited liability company SIA "BSMS", unified company registration number LV40003471367, legal address Delu iela 4, Riga, LV-1004, Latvia.
4. Purposes of personal data processing
4.1. The company SIA "BSMS" processes the Client's personal data for the following purposes:
4.1.1. In order to ensure the provision of services:
18.104.22.168. for client relationship management, ensuring the conclusion and execution of contracts;
22.214.171.124. in order to provide services, prevent incidents and provide technical support;
126.96.36.199. for payment administration, including debt recovery and levying;
188.8.131.52. for maintenance and improvement of Internet resources maintained by the company SIA "BSMS";
4.1.2. for the establishment and maintenance of internal processes in order to ensure the circulation of documents and other internal processes to the extent necessary and sufficient therefor;
4.1.3. for the provision of information to public administration institutions and subjects of operational activities in the cases, and to the extent, specified in external regulatory enactments;
4.1.4. In order to ensure the development of services:
184.108.40.206. in order to create new products and make offers for them;
220.127.116.11. for market analysis and business model development.
5. Legal bases for the processing of personal data
5.1. The company SIA "BSMS" processes personal data on the basis of the following legal justifications and foundations:
5.11. for concluding and executing the agreement – in order to enter into the agreement upon the Client's application and ensure its execution;
5.1.2. for the fulfillment of regulatory enactments – in order to fulfill the obligation specified in the external regulatory enactment of the company SIA "BSMS";
5.1.3. in the legal (legitimate) interests – in order to realize the legal (legitimate ) interests of the company SIA "BSMS" and the Client or the concluded agreement, or the legal (legitimate) interests of SIA "BSMS" arising from the law;
5.1.4. confirmation (approval) of the data subject.
5.2. The legal (legitimate) interests of the company SIA "BSMS" are as follows:
5.2.1. to carry out entrepreneurial activity;
5.2.2. to provide services within the internet medium;
5.2.4. to verify the Client's identity before concluding the contract or starting to provide the service;
5.2.5. to ensure the fulfillment of contractual obligations;
5.2.6. to design and develop goods and services;
5.2.7. to send reports on the progress of the performance of the contract and events relevant to the performance of the contract;
5.2.8. to ensure the maintenance and development of electronic communications networks;
5.2.9. to monitor the operation of services in order to detect technical problems, as well as illegal activities, and to eliminate them;
5.2.10. to apply to state administration and operational institutions and establishments, as well as to a court for the protection of our legal interests.
5.3. The Client may consent to the processing of personal data in the application forms of the company SIA "BSMS" services, maintained Internet resources, as well as by agreeing to participate in SIA "BSMS" client events.
5.4. The Client has the right to revoke the consent to the processing of data at any time in the same way as it was given, in which case further data processing based on the previously given consent for the specific purpose will not be performed in the future.
5.5. Withdrawal of consent does not affect data processing performed at the time when the Client's consent was valid.
5.6. Withdrawal of consent may not suspend the processing of personal data carried out on other legal grounds, or which must continue to be carried out in accordance with the applicable laws and regulations.
6. Transfer of client data
6.1. The Client's personal data is not transferred to third parties, except in cases when the transfer of data is necessary in order to ensure the performance of the provided service (regardless of whether the service is provided on the basis of a contract or regulatory enactment), in order to ensure activity of the company SIA "BSMS", or a legal justification exists for the transfer of data, or it is provided by external regulatory enactments or in the Client's explicit and unambiguous consent which has been received.
6.2. The company SIA "BSMS" may use approved personal data processors (cooperation partners that provide services to SIA "BSMS") in order to ensure the performance of the provided services. In such cases, the company SIA "BSMS" shall take the necessary measures to ensure that such personal data processors process personal data in accordance with the instructions of the company SIA "BSMS" and in accordance with the applicable regulatory enactments, and require the implementation of appropriate security measures.
6.5. SIA "BSMS" does not transfer and does not make available the Client's personal data to recipients from third countries or international organizations. The transfer and processing of personal data outside the territory of the European Union and the European Economic Area may take place if there is a legal basis for doing so, namely to fulfil a legal obligation, to enter into, or perform a contract, or with the client's consent, and provided that appropriate safeguards are in place.
7. Duration of personal data storage
7.1. The Client's data is stored as long as the Client uses the services of the company SIA "BSMS", or until the Client does withdraw his/her consent, if the Client's personal data is processed on the basis thereof. Longer storage time of personal data is allowed in order to meet the requirements of regulatory enactments regarding the minimum term of storage of documents or information or to protect the legitimate interests of the company SIA "BSMS".
7.2. After the end of the storage period of documents or information, the Client's data is deleted, made inaccessible (archived) or unidentifiable, so that they can no longer be identified with a specific Client.
8. Commercial notifications
8.1. Communication regarding commercial announcements about the services of the company SIA "BSMS" and other announcements not related to the provision of direct services (for example, notifications to Clients) shall be performed by the company SIA "BSMS" in accordance with external regulatory enactments or on the basis of the Client's consent.
8.2. The Client may give consent to receive commercial notifications in the service application forms of the company SIA "BSMS" and in the Internet resources maintained by the company SIA "BSMS".
8.3. The Client's consent to receive commercial communications is valid until the moment its is revoked (also after the termination of the service agreement).
8.4. The Client may at any time opt out of further receipt of commercial communications by using the automated option provided in the commercial notification to opt out of receiving further notifications by authenticating in the portal or in writing in accordance with the procedure specified in paragraph 12.1.
8.5. The company SIA "BSMS" stops sending commercial notifications as soon as the received Client's request for cancellation is processed.
8.6. By expressing his/her opinion in surveys and leaving his/her contact information (e-mail address, telephone number), the Client agrees that SIA "BSMS" may contact him/her in connection with the assessment provided by the Client.
9. Client's rights
9.1. The Client shall be entitled to request confirmation from the company SIA "BSMS" in respect to whether the company SIA "BSMS" processes the Client's personal data and in such cases, to request access to personal data or to request the issuance of information about such personal data, if direct access is not possible.
9.2. In case the Client considers that the information in possession of the company SIA "BSMS" is incorrect or incomplete, the Client shall be entitled to request its correction, as well as to submit the correct data necessary for the provision of the service. If necessary, the company SIA "BSMS" has the right to request a document proving changes in the Client's personal data, and the Client must submit such a document.
9.3. The Client shall be entitled to object to processing of such personal data, which is processed by the company SIA "BSMS", on the basis of the legitimate interests of the company SIA "BSMS". However, the company SIA "BSMS" shall continue to process the Client's personal data even if the Client has objected to such processing, provided if the company SIA "BSMS" has a legal basis for the processing of the mentioned data.
9.4. The Client shall be entitled to request the company SIA "BSMS" to delete the Client's personal data, however, this does not apply to cases when the storage of the Client's personal data is necessary in order to ensure compliance with the requirements of regulatory enactments. When exercising the Client's right to erase personal data, th company SIA "BSMS" shall perform only such actions permitted by regulatory enactments or the legitimate interests of the company SIA "BSMS", and to the extent therein, and as far as it will be technically possible.
9.5. The Client shall be entitled to receive or transfer his/her personal data to another data controller. This right includes only the data submitted by the Client to the company SIA "BSMS" on the basis of his/her consent or agreement, as well as if the processing is performed automatically.
9.6. In order to exercise the Client's rights, the Client must submit a written application to the company SIA "BSMS". In case the Client is not satisfied with the received response, the Client has the right to apply to the Data State Inspectorate [Datu valsts inspekcija], if the Client considers that the processing of personal data violates his/her rights and interests in accordance with the applicable laws and regulations.
10. Contact data
10.1. The Client may contact the company SIA "BSMS" in connection with issues regarding the processing of personal data in the following way:
10.1.1. electronically by signing the application with a secure electronic signature and sending it to an e-mail address.
10.2. Upon receipt of the Client's request for the exercise of his/her rights, the company SIA "BSMS" verifies the Client's identity, evaluates the request and executes it in accordance with regulatory enactments.
11.3. If the Client has not submitted to the company SIA "BSMS" a written notice of termination of the agreement or use of a specific service by the effective date of such amendments, it shall be considered that the Client has agreed to these amendments and they are applicable in the legal relationship between the company SIA "BSMS" and the Client.
12. Final provisions