Purpose of personal data processing policy
The purpose of personal data processing policy is to provide individuals with information on the purpose, scope, protection and processing time of the processing personal data during the data acquisition and processing of the personal data of the data subject.
Personal data manager and contact information
Personal data processing manager is SIA TrafoNet (hereinafter – TrafoNet), registration No. 40103240022, legal adress at Sēļu street 10, Mārupe, LV-2167, phone +371 20209087, e-mail: firstname.lastname@example.org.
Scope of application of the document
- Individuals – customers, employees and other users of the services (including potential, former and existing), as well as third parties who receive or transmit any information (including contact persons, payers etc.) to the individual (cutomer) in connection with the provision of services etc.)
- Visitors to Internet websites maintained by TrafoNet (hereinafter – Clients)
TrafoNet takes care of Customer privacy and personal data protection, respecting Customer’s right to the lawfulness of personal data processing under applicable law – Personal Data Protection Act, Regulation 2016/679 of the European Parliament and of the Council of 27th of April 2016 on the protection of individuals with regard to the processing of persona data and the free movement of such data (Regulation) and other applicable laws on privacy and data processing.
For specific types of data processing (such as cookie processing, etc.), additional, specific rules may be set for purposes that the Customer is notified of when providing relevant data to TrafoNet.
Purposes of processing personal data
- Identification of clients and preparation of offer;
- preparing, concluding, supplementing, switching and breaking a contract;
- delivery of goods and performance of contractual obligations;
- promoting, promoting and distributing services for commercial purposes;
- handling and processing of objections;
- Customer satisfaction measurement, retention, loyalty;
- billing administration;
- creditworthiness assessment, credit monitoring;
- debt recovery and recovery;
- Maintaining and improving websites.
- accounting, planning and statistics;
- ensuring data quality and measuring efficiency;
- conducting customer surveys.
TrafoNet processes personal data for the purpose of providing information to public administrations and operative entities in the cases and to the extent prescribed by external regulatory enactments, as well as for other specific purposes for which the Customer is informed at the moment when he provides relevant data to TrafoNet.
Legal basis for processing personal data
TrafoNet processes Customer’s personal data based on the following legal bases:
• conclusion and performance of the contract – to conclude the contract and ensure its performance;
• for compliance with regulatory enactments – in order to fulfill TrafoNet’s binding external regulatory obligations;
• in accordance with the Customer’s data subject’s consent;
• legitimate (legitimate) interests – to exercise the legitimate (legitimate) interests of TrafoNet arising out of the obligations existing between TrafoNet and the Customer or under a contract or law.
The legitimate interests of TrafoNet are:
• conduct business;
• to verify the Customer’s identity before entering into a contract or during customer service – by telephone, electronically, in person;
• Ensure fulfillment of contractual obligations;
• Eliminate unwarranted financial risks for your business (incl. Credit risk assessment before selling goods and performing a contract);
• To retain Customer’s applications and applications for the purchase of goods made verbally by calling the telephone number provided by the company, by writing to the company’s e-mail and website;
• Analyze the operation of TrafoNet websites and websites, develop and implement improvements;
• Perform actions to retain Clients;
• develop and develop goods and services;
• Promote your merchandise through commercial communications;
• send other reports on the progress of the contract and events relevant to the performance of the contract;
• inform about changes in the price list;
• Inform Clients about the latest developments in the industry;
• Prevent fraud;
• Provide corporate governance, financial and business accounting and analytics;
• Provide effective corporate governance processes;
• Product sales and delivery efficiency;
• administer payments;
• administer timely payments;
• to address state administration and operational institutions and courts to protect their legal interests;
Data processing rules from the controller to another data controller
These data processing rules apply only to the processing of personal data resulting from contracts for services provided by another legal entity to TrafoNet.
Both Parties act as an independent data controller.
The Parties shall take appropriate technical and organizational measures to ensure the security of the processing of personal data.
The Parties shall promptly, but not later than within 2 (two) working days, inform the other Party of the data subject’s request if it relates to or affects the processing of personal data by the other Party (eg request to limit data processing) or affects personal data (eg request for rectification). The Parties shall cooperate in good faith with each other (for example by exchanging information on the processing of personal data) in order to meet reasonable requests from data subjects as well as to ensure the accuracy of the data throughout the processing.
Processing of personal data
TrafoNet processes Customer Data using modern technology capabilities, taking into account existing privacy risks and TrafoNet’s reasonably available organizational, financial, and technical resources.
Protection of personal data
TrafoNet protects Customer data using modern technology capabilities, taking into account existing privacy risks and TrafoNet’s reasonably available organizational, financial, and technical resources.
Categories of recipients of personal data
TrafoNet does not disclose to third parties the Customer’s personal data or any information obtained during the term of the Agreement, including information about transactions performed, except:
• if the third party concerned is required to provide the data within the framework of a contract to perform a function required by the contract or delegated by law (eg to a bank in settlement or to provide a service);
• delivery of invoices to the Customer;
• mailing to Customers about changes in the content of the contract or the price list;
• in accordance with the Customer’s explicit and unambiguous consent;
• to persons specified in the external regulatory enactments at their reasoned request, in accordance with the procedures and to the extent prescribed by external regulatory enactments;
• TrafoNet for the protection of legitimate interests, for example in cases of legal or other state institutions against a person who has violated TrafoNet’s legitimate interests.
Access to personal data of third-country entities
TrafoNet provides the procedures specified in regulatory enactments for ensuring the level of processing and protection of personal data equivalent to that provided by the Regulation.
Duration of personal data storage
TrafoNet stores and processes Customer’s personal data while at least one of the following criteria exists:
• only as long as the agreement with the Customer is in effect;
• while TrafoNet or the Customer may exercise its legitimate interests (eg, to file an objection or bring an action or bring an action in court), in accordance with the procedures prescribed by external regulatory enactments;
• while a party has a legal obligation to keep the data;
• as long as the Customer’s consent to the appropriate processing of personal data is in force, unless there is another legitimate basis for the processing of the data.
After the above circumstances expire, the Customer’s personal data will be deleted.
Access to personal data and other Customer’s rights
The Customer is entitled to receive the information specified in regulatory enactments related to the processing of his data.
The Client also has the right to request TrafoNet access to their personal data in accordance with regulatory enactments, as well as to request TrafoNet to replenish, correct or delete it, or to limit processing to the Customer, or to object to the processing (including the processing of personal data based on the legitimate (legitimate) interests of TrafoNet) and the right to data portability. This right shall be exercised insofar as the processing of data does not result from the obligations of TrafoNet imposed on it by the laws and regulations in force and which are made in the public interest.
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