Privacy Policy
Your personal data protection is of utmost importance to us.
We would like to inform you that we will request the submission of your personal data and store it electronically. We will retain and process your data in accordance with the applicable national data protection laws and the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council 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), hereinafter referred to as the GDPR.
Data Controller
The responsible data controller (responsible person) within the meaning of the aforementioned provisions is:
SIA “Korte.lv”
Registration No.: LV40103251623
VAT No.: 40103251623
Registered Address: Vaidavas 7-43, Riga, LV1084
Office Address: Zemeņu 2, Salaspils, LV2169
(hereinafter referred to as “KORTE”)KORTE’s Data Protection Officer:
Lorens Balodis
Email: lorens@korte.lv
I. General Provisions
1. Definitions Used in the Document
To ensure the clarity of our data protection declaration (Privacy Policy), we provide information on the basic concepts used in the GDPR:
Personal Data
Personal data is any information that relates to an identified or identifiable natural person (hereinafter referred to as the Data Subject). An identifiable natural person is one who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, identification number, location data, online identifier,or to one or more factors such as name, email address, phone number, delivery address, and device/browser identifiers that are relevant to the use of the configurator or order process on our website.”
Data Subject
Any identified or identifiable natural person whose personal data is processed by the controller.
Profiling
Profiling is any form of automated processing of personal data that involves the use of personal data to evaluate certain personal aspects related to a natural person, particularly to analyze or predict aspects concerning that natural person’s interactions with the website, which may include general interests or preferences inferred indirectly through cookie-based tools. However, no direct profiling or performance prediction is carried out by KORTE.
Processing
Processing refers to any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Consent of the Data Subject
Consent is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes, whereby the data subject, through a statement or a clear affirmative action, signifies their agreement to the processing of their personal data.
Payment Service Provider
Payment service providers such as PayPal, Klarna, and Stripe (including Apple Pay, Google Pay, and credit/debit card processing) are used to process payments made in accordance with agreements entered into between the data subject and the controller.”
2. Methods and Scope of Data Collection
When accessing our website or retrieving files stored on it, data may be collected through various user actions, including placing an order, subscribing to a newsletter, entering an email address, creating a user account, or using the configurator tool. This is done only to the extent necessary to ensure the functionality of the website, its content, and services. Additionally, personal data is collected and used solely with the appropriate consent of the data subject. An exception to this condition is permitted only in cases where prior consent cannot be obtained for objective reasons, and the processing of data is allowed by law.
a. Legal Basis for Processing Personal Data
To the extent that personal data processing is carried out for the performance of a contract with us, the legal basis is Article 6(1)(b) of the GDPR. This also applies to processing activities that are necessary for the implementation of pre-contractual measures.
If personal data processing is based on the data subject’s consent, the legal basis is Article 6(1)(a) of the GDPR.
Where personal data processing is necessary to comply with a legal obligation to which our company is subject, the legal basis is Article 6(1)(c) of the GDPR.
If processing is necessary to protect the vital interests of the data subject or another natural person, the legal basis is Article 6(1)(d) of the GDPR.
If processing is necessary for the purposes of legitimate interests pursued by our company or a third party, and if the data subject’s interests, fundamental rights, and freedoms are not overriding those legitimate interests, the legal basis is Article 6(1)(f) of the GDPR.
b. Legal Basis for Retaining Personal Data
The personal data we collect will be promptly deleted as soon as the legal basis for its retention has ceased.
Retention is carried out in accordance with applicable laws and regulations, such as Latvian Accounting Law (Grāmatvedības likums), VAT legislation, or contractual obligations requiring data to be kept for a specific period.
Additionally, data will be deleted when the retention period specified in the aforementioned regulations expires, unless further retention is necessary for the purposes of contract conclusion or performance.
II. Website Provision
1. Log Files
a. Description and Scope of Data Processing
When you access our website, the following data is recorded:
- Type/version of the browser used
- Operating system used
- Referrer URL (the previously visited website) and the pages viewed on our website
- IP address
- Date and time of the server request
- Internet service provider
b. Legal Basis for Data Processing
The legal basis for the retention of data and log files is Article 6(1)(f) of the GDPR.
c. Purpose of Data Processing
The storage in log files ensures the proper functioning of our website and serves to optimize and secure our systems. Data is not evaluated for marketing purposes.
d. Retention Period
The data we store will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. Typically, this occurs no later than seven days. In rare cases, retention beyond this period may occur; however, in such cases, user IP addresses are anonymized so that further identification of the client data is no longer possible.
e. Objections and Data Removal
The collection of the aforementioned data is necessary for ensuring the secure and stable technical operation of the website and is not used for marketing or profiling purposes. Due to its technical necessity, users do not have an option to object to this specific processing under Article 21(1) of the GDPR.
2. Cookies
a. Description and Scope of Data Processing
Our website uses cookies. Cookies are text files stored on the visitor’s computer system when they visit our website. Cookies contain a string of characters that allows the identification of the visitor’s browser when they revisit our website. We use technically necessary cookies to make our website more user-friendly, efficient, and secure. Cookies, for example, store and transmit the following data:
- Names of items added to the shopping cart
- Login details
- Language settings
We ensure that data obtained in this way is pseudonymized, making it impossible to further identify the individual visitor. Additionally, this data is not stored together with other personal data. You can configure your browser to inform you about cookie placement, which allows you to individually decide whether to accept cookies or to reject them in specific cases or entirely. If cookies are rejected, the functionality of our website may be limited.
In addition to the above, we also use cookies that allow us to analyze our website visitors’ browsing habits (so-called analytics cookies). Analytics cookies store and transmit, for example, the following data:
- Page visit sessions
- Use of website functions
- Language settings
When accessing our website, users are informed about the use of cookies and their consent is obtained for the processing of personal data collected through cookies.
b. Legal Basis for Data Processing
The legal basis for processing personal data using strictly necessary cookies is Article 6(1)(f) of the GDPR, as it serves our legitimate interest in ensuring basic site functionality.
The legal basis for processing personal data using cookies for analytical or tracking purposes is Article 6(1)(a) of the GDPR, provided that the user has given explicit consent via the cookie banner.
c. Purpose of Data Processing
Technically necessary cookies facilitate the use of websites. Some website or online store functions cannot be offered without the use of cookies. To achieve this, it is necessary to recognize the browser even after changing web pages. Data collected through technically necessary cookies is not used to create user profiles.
Analytics cookies are used to improve the quality of our websites and their content. By using analytics cookies, we can determine how the website is used, allowing us to continuously optimize our offerings.
d. Retention Period, Objections, and Data Removal
Cookies are stored on the user’s computer, and users have full control over the use of cookies. By changing the settings in their internet browser, users can deactivate or limit the transmission of cookies. Cookies already stored can be deleted at any time, either manually or automatically.
If cookies are deactivated for our website, it is possible that not all website functions will be fully available.
3. Informational Newsletters and Product-Related Emails
a. Description and Scope of Data Processing
Users on our website have the option to subscribe to our informational newsletter. This feature is only active if KORTE.design is actively sending newsletters. In cases where newsletters are not distributed, no related data processing occurs and subscriptions will not be stored or triggered. When registering, the data requested in the registration form is transmitted to us.
During the registration process, the following additional data is also collected:
- The IP address of the registering person’s computer
- Date and time of registration
Consent is obtained during the registration process using a so-called single opt-in procedure.
If customers have purchased goods or services from us and have provided their email address, it may also be used for sending the newsletter. In this case, the newsletter will be used solely to send direct advertising about similar goods or services we offer.
In relation to the processing of data necessary for sending the newsletter, data is shared with third parties (email service providers). This data will be used solely for the purpose of sending the newsletter.
b. Legal Basis for Data Processing
“The legal basis for processing data after a user registers to receive the informational newsletter is Article 6(1)(a) of the GDPR, provided that the user has given their consent. Newsletter subscriptions are managed via a single opt-in process, and email addresses are stored securely through our email delivery platform solely for the purpose of distributing content to subscribers. We do not send promotional or product-related emails based on past purchases without consent. No fallback legal basis under the Law on Prohibition of Unfair Commercial Practices is applied.
c. Purpose of Data Processing
The collection of users’ email addresses is used for sending informational newsletters. The collection of other personal data during the registration process serves solely to prevent misuse of the service or the provided email address.
d. Retention Period
Data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. Therefore, the user’s email address is retained for as long as the newsletter subscription is active.
e. Objections and Data Removal
Users can unsubscribe from the newsletter at any time. For this purpose, each newsletter contains an appropriate link for cancellation.
4. Tracking of Informational Newsletters
a. Description and Scope of Data Processing
Our informational newsletters include tracking pixels — small graphics embedded in emails to help us analyze open and click rates. This is done only with prior consent to receive our emails and is used solely to improve our email content. No data is shared with third parties.Consent for this purpose will be obtained during the registration process using a so-called single opt-in procedure.
b. Purpose of Data Processing
Tracking of informational newsletters is used to statistically evaluate the success or failure of online marketing campaigns. This allows us to determine whether and when an email is opened and which links within the email are clicked. Tracking is only performed if the user has provided prior consent during the registration process using a so-called single opt-in procedure. No tracking data is shared with third parties.
c. Retention Period
Data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected, but no later than one year.
d. Objections and Data Removal
Affected users can unsubscribe from the newsletter at any time, thereby ceasing to receive updates. Each newsletter contains an appropriate link for unsubscription.
5. Registration During the Ordering Process
a. Description and Scope of Data Processing
Users have the option to register on our website. During registration, the data requested in the input mask is transmitted to and stored by us. Personal data may be shared with third parties, such as delivery service providers or manufacturing companies, if necessary for the fulfillment of the contract. These third parties use the transferred data solely for internal purposes and to achieve objectives related to our contract.
b. Purpose of Data Processing
User registration is required for the performance of contracts with users or for the implementation of pre-contractual measures. Registration is also necessary to provide certain content and services on our website.
c. Retention Period
Data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. This applies to data collected during the registration process if registration on our site is canceled or modified. The same applies to data collected during registration for the purpose of fulfilling a contract or implementing pre-contractual measures if the data is no longer necessary for the performance of the contract. Even after the conclusion of the contract, it may be necessary to retain the contract partner’s personal data to ensure compliance with contractual obligations or to meet legal requirements.
d. Objections and Data Removal
Users have the option to cancel their registration at any time. They can also modify or request the modification of stored data at any time.
The procedures for canceling registration can be obtained from the responsible person indicated in the introduction of this policy.
If the data is required for contract performance or for pre-contractual measures, early deletion of the data is only possible if the contractual obligations or legal requirements do not preclude the deletion of the data.
6. Payment Service Provider: PayPal
a. Data Processing Description and Scope
If the user chooses a payment service provider during the order process, user data is automatically transmitted to the selected provider. By selecting a payment method, the user consents to the transfer of personal data necessary for processing the payment.
Our online store supports payments via the following service providers:
- PayPal (Europe) S.à r.l. & Cie S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg
- Klarna Bank AB, Sveavägen 46, 111 34 Stockholm, Sweden
- Stripe Payments Europe, Ltd., The One Building, 1 Grand Canal Street Lower, Dublin, Ireland (includes Apple Pay, Google Pay, and card transactions)
The data transmitted includes name, surname, address, email address, IP address, phone number, and order-related information necessary to fulfill the transaction.
Each provider processes the data in accordance with their privacy policy:
- PayPal: PayPal Privacy Policy
- Klarna: Klarna Privacy Policy
- Stripe: Stripe Privacy Policy
b. Legal Basis for Data Processing
If the use of the payment service provider serves the performance of a contract to which the user is a party, the legal basis for data processing is Article 6(1)(b) of the GDPR.
If the user has given their consent, the legal basis for data processing is also Article 6(1)(a) of the GDPR.
c. Purpose of Data Processing
Data is transmitted for payment processing, to prevent misuse, and for identity verification and account balance checks.
d. Objections and Data Removal
The user can withdraw their consent to PayPal at any time. However, withdrawal of data essential for processing the payment is not possible.
7. Contact Form and Email
a. Description and Scope of Data Processing
Visitors to our site are provided with a dedicated contact form for quick electronic communication. Data entered in the form is sent to us and stored. Additionally, the user’s IP address, as well as the date and time of submission, are saved at the time of submission.
Users can also contact us via the provided email address. In this case, personal data sent along with the email will be stored.
Data will not be shared with third parties and will only be used for processing the request.
b. Legal Basis for Data Processing
If the user has given their consent, the legal basis for data processing is Article 6(1)(a) of the GDPR.
For data processing during email communication, the legal basis is Article 6(1)(f) of the GDPR. If the purpose of the email communication is to conclude a contract, the additional legal basis for processing is Article 6(1)(b) of the GDPR.
c. Purpose of Data Processing
The processing of personal data serves solely for handling communication data. When contacting us via email, it constitutes a legitimate interest in processing data.
Additional personal data processed during the submission process is used to prevent misuse of the contact form and to ensure the security of our information technology systems.
d. Data Retention Period
Data will be deleted once it is no longer needed for the purpose for which it was collected. Personal data from the contact form and those sent via email will be deleted once the communication with the user is concluded. Communication is deemed concluded when it is clearly evident that the matter has been resolved.
All additional personal data obtained during the submission process will be deleted no later than one year after collection.
e. Objections and Data Removal
The user may withdraw their consent to personal data processing at any time. To do so, the user can contact the responsible person at KORTE using the contact options provided on the site. If the user contacts us via email, they have the right to object to the storage of their personal data at any time. In such cases, communication cannot continue.
The user may cancel their registration at any time and can modify or request the modification of stored data at any time.
8. Google Analytics
a. Description and Scope of Data Processing
This website uses the web analytics service Google Analytics provided by Google Inc., located at 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA. Google Analytics utilizes data analysis cookies. The information generated by these cookies regarding the use of this website is generally transmitted to Google servers in the USA and stored there.We have extended the Google Analytics code with the function “gat._anonymizeIp();” to ensure that users’ IP addresses are anonymized before being transmitted to Google servers. This means that only a truncated IP address is processed, and full IPs are never stored or accessible during analytics processing, which helps ensure compliance with GDPR requirements for personal data minimization. This code anonymizes your IP address before transmission by shortening it within the European Union member states or other countries that have signed the agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to Google servers in the USA and shortened there. On behalf of the website operator, Google will use this information to evaluate how you use the website, compile reports on website activity, and provide further services related to website and internet use. The IP address transmitted by your browser through Google Analytics will not be merged with other Google data.
b. Legal Basis for Data Processing
The legal basis for processing users’ personal data is Article 6(1)(f) of the GDPR.
c. Purpose of Data Processing
Processing of users’ personal data allows us to analyze users’ browsing behavior on our website. By evaluating the obtained data, we can gather information on the use of various components of our website, which helps us improve the site and its usability. This processing also serves our legitimate interests under Article 6(1)(f) of the GDPR. Since the IP address is anonymized, users’ data protection interests are sufficiently protected.
d. Retention period
The retention period for Google Analytics data is defined by Google and can vary depending on configuration. By default, user and event data associated with cookies, user identifiers, or advertising identifiers is retained for 14 months. This period may be adjusted within Google Analytics settings by the data controller. Further information is available at Google Analytics Terms or Google Privacy Policy.
e. Objections and Right to Erasure
Cookies are stored on the user’s computer and are transmitted by the user. Therefore, users have the ability to fully control the use of cookies. By changing the settings in your web browser, you can deactivate or restrict the transmission of cookies. Cookies that are already stored can be deleted at any time, and this can also be done automatically. If cookies are deactivated for our website, it is possible that you may not be able to use all functions of the website.
By downloading and installing the browser add-on available at https://tools.google.com/dlpage/gaoptout?hl=en, you can also prevent the data generated by cookies related to website use (including your IP address) from being sent to Google and processed by Google.
When using mobile devices, you can opt out by clicking the “Disable Google Analytics” link.
9. Google Remarketing
a. Description and Scope of Data Processing
This website uses the Google Remarketing service provided by Google Inc., located at 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA. This service allows us to display advertisements to users based on their interests. For this purpose, cookies are used to recognize visitors to our site when they later visit websites that are also part of the Google advertising network. Google collects personal data about the visitor, such as the visitor’s IP address or browsing behavior. Google Inc. uses the data collected in this way to tailor advertisements displayed to the user.
b. Legal Basis for Data Processing
The legal basis for processing personal data using cookies is Article 6(1)(f) of the GDPR. If the user has given their consent for data analysis purposes, the legal basis for processing personal data using cookies is also Article 6(1)(a) of the GDPR.
c. Purpose of Data Processing
Cookies for data analysis are used to optimize the advertisements displayed to the user.
d. Retention Period
Information about the retention period can be obtained from the service provider or at https://policies.google.com/privacy?hl=en.
e. Objections and Right to Erasure
Cookies are stored on the user’s computer and are transmitted by the user. Therefore, users also have the option to fully control the use of cookies. By changing the settings in your web browser, you can deactivate or limit the transmission of cookies. Cookies that are already stored can be deleted at any time, and this can also be done automatically. If cookies are deactivated for our site, you may not be able to use all of its features.
Additionally, individuals have the right to object to Google advertisements based on interest analysis. To do this, the individual must follow the link www.google.com/settings/ads in any web browser they use and adjust the necessary settings.
Further information and Google’s applicable privacy policy can be found at https://www.google.com/intl/en/policies/privacy/.
10. Google AdWords
a. Description and Scope of Data Processing
We have integrated Google AdWords on our website. The service provider is Google Inc., located at 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.
Through Google AdWords, we are able to advertise our website by displaying targeted advertising material on third-party websites and in Google search results, as well as by showing other companies’ ads on our site. When a user clicks on a Google AdWords advertisement, communication cookies are stored on the user’s computer. These cookies are not used to identify the user but are used to track the subpages of our website that have been accessed and to determine whether a transaction has been completed or cancelled. Personal data is stored by Google in the USA. Google may pass this information to third parties.
b. Legal Basis for Data Processing
The legal basis for processing personal data using cookies is Article 6(1)(f) of the GDPR. If the user has given consent for data analysis purposes, the legal basis for processing personal data using cookies is also Article 6(1)(a) of the GDPR.
c. Purpose of Data Processing
Google AdWords enables us to display internet advertisements in Google search results and across the Google advertising network. For this purpose, we predefine keywords so that when users enter these keywords into the search engine, our prepared advertising material appears in the Google search results. In the Google advertising network, ads are distributed across relevant websites using an automated algorithm based on the predefined keywords. This helps us optimize our advertisements.
d. Retention Period
Information regarding the retention period can be obtained from the service provider or at https://policies.google.com/privacy?hl=en.
e. Objections and Right to Erasure
Cookies are stored on the user’s computer and are managed by the user. Consequently, users have the option to fully control the use of cookies. By modifying the settings in their web browser, users can deactivate or restrict the transmission of cookies. Cookies that are already stored can be deleted at any time, and this can also be done automatically. If cookies are disabled for our site, you may not be able to use all of its features. Additionally, individuals have the right to object to Google advertisements based on interest analysis. To do this, the individual should visit www.google.com/settings/ads in any web browser they use and adjust the necessary settings.
Further information and Google’s applicable privacy policy can be found at https://www.google.com/intl/en/policies/privacy/.
11. Two-Click Solution for Social Media Plugin Integration
Our website does not directly integrate social media plugins, so the creation of third-party profiles is not possible. To share our offerings via Pinterest, Instagram, Facebook, Twitter, Google+, TikTok, or LinkedIn, we use the so-called two-click solution.
If you choose to share a post by clicking the respective button, your data will only be transmitted to the relevant social media service provider after a second click on the button.
We recommend that you familiarize yourself with the data protection regulations of the social media service you wish to use beforehand. This will inform you about the purpose and scope of data collection, further processing, and usage, as well as your rights and options for protecting your privacy.
You can find the data protection regulations here:
- Facebook: https://www.facebook.com/about/privacy/
- Twitter: https://twitter.com/privacy
- Google+: https://www.google.com/intl/en/policies/
- Instagram: https://www.instagram.com/about/legal/privacy/
- Pinterest: https://about.pinterest.com/privacy-policy
- TikTok: https://www.tiktok.com/legal/privacy-policy
- LinkedIn: https://www.linkedin.com/legal/privacy-policy
12. Two-Click Solution for YouTube Integration
Our website integrates YouTube components. YouTube is an internet video platform that allows video creators to upload videos for free, while other users can view, rate, and comment on these videos at no cost. YouTube hosts a wide range of video content, including films, unedited TV broadcasts, music videos, trailers, and user-generated content.
The service provider is YouTube, LLC, located at 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc., located at 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.
Our website does not directly embed YouTube videos, which prevents the creation of third-party profiles. To view our videos, users must first click on the preview image. Videos can only be watched after logging in. Data is transmitted only at this point.
For more information on the collection, processing, and use of personal data by YouTube and Google, please refer to YouTube’s Privacy Policy available at https://www.google.com/intl/lv/policies/privacy/.
III Rights of Data Subjects
1. Right to Information
Any person affected by the processing of personal data may request confirmation from the data controller regarding whether their personal data is being processed.
If processing is confirmed, you may request the data controller to provide the following information:
- The purposes of the processing;
- The categories of personal data being processed;
- The recipients or categories of recipients to whom the personal data has been or will be disclosed;
- The planned duration of data retention concerning you, or, if specific information cannot be provided, the criteria used to determine the retention period;
- The rights to rectification or erasure of your personal data, the right to restrict processing, or the right to object to such processing;
- The right to lodge a complaint with a supervisory authority;
- Whether automated individual decision-making, including profiling as referred to in Article 22(1) and (4), is carried out;
- Whether your personal data is transferred to a third country or international organization;
- Whether your personal data is processed for scientific, historical, or statistical research purposes in accordance with Article 89 of the GDPR.
Clarification from KORTE:
We do not conduct automated decision-making or profiling.
We do not transfer personal data to any third countries or international organizations outside the European Economic Area (EEA).
We do not process data for scientific, historical, or statistical research purposes. Therefore, the above provisions do not apply.
2. Right to Rectification
Data subjects have the right to request the data controller to rectify and/or complete their personal data if it is inaccurate or incomplete. The responsible party must promptly make the necessary corrections.
3. Right to Restrict Processing
Data subjects may request the restriction of their personal data processing under the following conditions:
- If the accuracy of the personal data is contested for a period enabling the data controller to verify its accuracy.
- The processing is unlawful, but the data subject opposes the deletion of the personal data and instead requests the restriction of its use.
- The data controller no longer needs the personal data for processing purposes, but the data subject requires it for the establishment, exercise, or defense of legal claims.
- If the data subject has objected to the processing under Article 21(1) of the GDPR and it has not yet been determined whether the legitimate grounds of the data controller override those of the data subject.
When processing is restricted, the personal data may only be processed, except for storage, with the data subject’s consent, for the purpose of establishing, exercising, or defending legal claims, or to protect the rights of another natural or legal person, or for substantial public interest of the Union or of a Member State.
If processing is restricted based on any of the above conditions, the data controller must inform the data subject before lifting the restriction.
4. Right to Erasure
a. Obligation to Delete
A data subject may request the data controller to erase their personal data without undue delay, and the data controller is required to comply with this request without undue delay if one of the following conditions applies:
- The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
- The data subject has withdrawn their consent on which the processing is based under Article 6(1)(a) or Article 9(2)(a) of the GDPR, and there is no other legal basis for processing the data.
- The data subject objects to the processing under Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing under Article 21(2).
- The personal data has been unlawfully processed.
- The erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law, such as the Latvian Accounting Law (Grāmatvedības likums), tax regulations, or other data retention requirements that override the right to erasure.
- The personal data was collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
b. Information to Third Parties
If the data controller has made the personal data public and is obliged to erase it under Article 17(1) of the GDPR, the data controller shall take reasonable steps, including technical measures, considering available technology and the cost of implementation, to inform other data controllers processing the personal data that the data subject requests the erasure of any links to, or copies or replications of, those personal data.
c. Exceptions
The right to erasure does not apply to the extent that processing is necessary:
- For exercising the right to freedom of expression and information;
- For compliance with a legal obligation requiring processing under Union or Member State law, such as the Latvian Accounting Law (Grāmatvedības likums), national tax regulations, or data retention laws governing business records, to which the data controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller;
- For the establishment, exercise, or defense of legal claims.
5. Right to Notification
When a data subject has notified the data controller of the exercise of their rights to rectification, erasure, or restriction of processing, the data controller is obligated to inform all recipients to whom the relevant personal data has been disclosed about such rectification, erasure, or restriction, unless this proves impossible or involves disproportionate effort. The data subject has the right to receive information from the data controller about these recipients.
6. Right to Data Portability
Data subjects have the right to receive their personal data from the data controller in a structured, commonly used, and machine-readable format. Additionally, they have the right to have their personal data transferred to another data controller by the original data controller, without hindrance from the original data controller, under the following conditions:
- The processing is based on consent in accordance with Article 6(1)(a) or Article 9(2)(a) of the GDPR, or on a contract in accordance with Article 6(1)(b) of the GDPR.
- The processing is carried out using automated procedures.
In exercising this right, data subjects also have the right to request that their personal data be directly transferred from one data controller to another, where technically feasible. This must not adversely affect the rights and freedoms of others.
The right to data portability does not apply to the processing of personal data necessary for performing a task carried out in the public interest or in the exercise of official authority vested in the data controller.
7. Right to Object
Data subjects have the right to object at any time to the processing of their personal data based on Article 6(1)(e) or (f) of the GDPR, on grounds relating to their particular situation. This includes the right to object to profiling based on these provisions.
The data controller must cease processing the relevant personal data unless they can demonstrate compelling and legitimate reasons for the processing that override the data subject’s interests, rights, and freedoms, or if the processing is necessary for the establishment, exercise, or defense of legal claims.
If personal data is processed for direct marketing purposes, data subjects have the right to object at any time to the processing of their personal data for such marketing, including profiling to the extent that it is related to direct marketing.
When data subjects object to processing for direct marketing purposes, their personal data must no longer be processed for these purposes.
Without prejudice to the provisions of Directive 2002/58/EC, data subjects can exercise their right to object in the context of information society services using automated procedures that involve technical specifications.
8. Right to Withdraw Consent
Data subjects have the right to withdraw their consent at any time in accordance with data protection laws. The withdrawal of consent does not affect the lawfulness of any processing carried out based on the consent before its withdrawal.
9. Right to Lodge a Complaint with a Supervisory Authority
Without prejudice to any other administrative or judicial remedies, where a data subject considers that their personal data has been processed in violation of the GDPR, they have the right to lodge a complaint with a supervisory authority. In Latvia, the relevant authority is the Data State Inspectorate (Datu valsts inspekcija — DVI), which can be reached at https://www.dvi.gov.lv/. This complaint may be submitted, in particular, to the supervisory authority in the Member State where the data subject resides, works, or where the alleged infringement has occurred.
The supervisory authority to which the complaint has been lodged will inform the complainant of the status of the complaint and the outcome of its investigation, including the possibility of pursuing a legal remedy as provided under Article 78 of the GDPR.
Effective Date
This Privacy Policy is effective as of April 22, 2025.