Controller and Its Contact Details
Scope of Application of the Document
Purposes for the Processing of Personal Data
Legal Basis for the Processing of Personal Data
Processing of Personal Data
Protection of Personal Data
Categories of Recipients of Personal Data
Access of Third-Country Subjects to Personal Data
Duration of Storage of Personal Data
Access to Personal Data and Other Rights of the Client
Client’s Consent to Data Processing and the Right to Withdraw It
Communication with the Client
Web Traffic and Processing of Cookies
- The personal data controller is SIA Lattelecom (hereinafter - Lattelecom), unified registration No. 40003052786, legal address: Riga, Dzirnavu iela 105, LV-1011.
- Personal data are any information about an identified or identifiable natural person. The definitions and explanations of personal data, as well as the categories of data are specified here.
- natural persons – clients, subscribers and other users of Lattelecom services (including potential, former and existing ones), as well as third parties who receive or pass on any information (including contact persons, payers, etc.) to Lattelecom in relation to the provision of services to a natural person (a subscriber, a client, a user);
- visitors of Lattelecom’s stores, offices and other premises, including ones subject to video surveillance;
- visitors of the Lattelecom’s website and mobile applications, and persons calling to the Lattelecom’s contact centre (hereinafter — the Clients).
- Lattelecom takes care of the Clients’ privacy and the protection of personal data, observes the Clients’ rights to the lawfulness of personal data processing in accordance with the applicable legal acts — Regulation (EU) of the European Parliament and of the Council No. 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (Regulation), and other applicable legal acts in the field of privacy and data processing.
- For specific types (e.g., cookie processing, etc.), environment, purposes of data processing, additional, specific regulations may be determined for the purposes of which the Client will be informed upon providing the relevant data to Lattelecom.
- Lattelecom processes personal data for the following purposes:
- Provision of services and selling of goods:
- identification of a client;
- preparation and signing of an agreement; proving the fact of signing;
- supply of goods as well as installation and provision of services (fulfilment of contractual obligations);
- ensuring the functionality of / maintenance of services;
- fulfilment of guarantee obligations;
- improvement of goods and services, development of new goods and services;
- promotion of use, advertising and distribution of the service;
- provision of services to clients;
- examination and processing of applications and objections;
- retention of clients, improvement of loyalty, satisfaction measurements;
- administration of payments;
- assessment of creditworthiness, supervision of loans;
- collection and recovery of debts;
- maintenance of websites and mobile applications, improvement of functioning.
- Business planning and analysis:
- statistics and business analysis;
- planning and accounting;
- effectiveness measurement;
- ensuring the quality of data;
- performance of market and public opinion surveys;
- preparation of reports;
- performance of client surveys;
- within the framework of risk management activities.
- Ensuring the security of information, information systems and the company.
- Providing information to state administration institutions and subjects of operational activities in the cases and to the extent specified in external laws and regulations.
- Other specific purposes for which the Client is informed upon providing the relevant data to Lattelecom.
- Lattelecom processes the Client’s personal data based on the following legal grounds:
- conclusion and execution of a contract - to enter into a contract following the Client’s application and to ensure its execution;
- execution of laws and regulations - to fulfil an obligation specified in external laws and regulations binding to Lattelecom;
- in accordance with the consent of the Client - the data subject;
- in legitimate interests - to pursue the legitimate interests of Lattelecom arising out of existing obligations or a contract entered into by and between Lattelecom and the Client, or arising out of law;
- ensuring the vital interests of the data subject or another natural person - to ensure the physical and property security of Lattelecom’s employees, Clients and visitors.
- The legitimate interests of Lattelecom are:
- to carry out commercial activities;
- to provide electronic communications services;
- to verify the Client's identity prior to entering into a contract;
- to ensure the fulfilment of contractual obligations;
- to eliminate unjustified financial risks for its business operations (incl. carrying out the assessment of credit risk before the selling of goods and services as well as during the execution of the contract);
- to store the Client’s applications and submissions for the purchase of goods and the provision of services, other applications and submissions, notes on them, including ones made in writing or orally, by contacting call centres, on websites and on the self-service portal;
- to conduct negotiations with the Client on the provision and maintenance of service operations, settlements, to carry out the control of customer service quality;
- to conduct negotiations with the Client to organise the fulfilment of obligations under the service agreement;
- to conduct negotiations with the Client, during which an oral agreement will be entered into, for proving the fact of entering into the agreement;
- to analyse the performance of Lattelecom’s homepage, websites and mobile applications, to develop and implement their improvements;
- to administer the Client’s account on Lattelecom’s homepages, websites and mobile applications;
- to carry out activities for the retention of Clients;
- to segment the client database for more efficient provision of services;
- to develop and improve goods and services;
- to advertise its goods and services;
- to send other reports on the progress of execution of the contract and events relevant to the execution of the contract, and to conduct Client surveys on goods and services and their experience of use (NPS);
- to ensure the maintenance and development of electronic communications networks;
- to maintain and develop communication network;
- to monitor the operation of the communications network, in order to establish technical issues, as well as unlawful activities and to prevent these;
- to prevent fraud;
- to ensure corporate management, financial and business accounting and analysis;
- to ensure the effective governance of the company;
- to ensure the efficiency of the supply of services and the sale and delivery of goods;
- to ensure and improve the quality of services;
- to administer payments;
- to administer outstanding payments;
- to apply to state administration institutions and institutions of operational activities and court for the protection of its legal interests;
- to inform the public about its activities.
- Lattelecom processes Client’s data using the options provided by modern technologies, taking into account the existing privacy risks and organisational, financial, and technical resources that are reasonably available to Lattelecom.
- Lattelecom may perform the adoption of automated decisions with regard to the Client. The Client is informed about these Lattelecom’s activities individually in accordance with laws and regulations. The Client may object to the adoption of automated decisions in accordance with legal acts, yet understanding that in separate cases this can restrict the Client’s right to use individual possibilities potentially available thereto (for example, to receive commercial offers).
- The adoption of automated decisions, which results in legal consequences for the Client (for example, approval or rejection of the Client’s application), can be carried out only in the process of entering into, or execution of, the contract between Lattelecom and the Client, based on the Client’s unambiguous consent or in the cases stipulated in external laws and regulations.
- For the high-quality and fast execution of the contractual obligations arising out of the contract entered into with the Client, Lattelecom may authorise Lattelecom group companies, its cooperation partners to perform individual deliveries of goods and activities for the provision of services, such as service deployment works, billing, and the like. If, in carrying out these tasks, Lattelecom group companies or co-operation partners process the Client’s personal data at the disposal of Lattelecom, the relevant Lattelecom group companies or co-operation partners are considered to be data Lattelecom’s processing operators (processors) and Lattelecom is entitled to transfer the Client’s personal data to Lattelecom group companies and co-operation partners for the performance of these activities to the extent necessary to carry out these activities.
- Co-operation partners of Lattelecom and Lattelecom group companies (in the status of a processor of personal data) will ensure the fulfilment of the requirements for personal data processing and protection in line with the requirements of Lattelecom and other legal acts, and will not use personal data for other purposes, except for the fulfilment of the contractual obligations arising out of the contract entered into with the Client on behalf of Lattelecom.
- Lattelecom protects Client’s data using the options provided by modern technologies, taking into account the existing privacy risks and organisational, financial, and technical resources that are reasonably available to Lattelecom, including using the following security measures:
- Data encryption by transmitting data (SSL encryption);
- Intrusion prevention and detection programmes;
- Other protective measures in line with the possibilities provided by current technical developments.
- Lattelecom does not disclose to third parties any Client’s personal data or any information obtained during the provision of services and the validity period of the contract, inter alia, information regarding received electronic communications, content or other services, except the following:
- if data have to be transferred to the third party within the framework of the concluded contract to perform any function necessary for the execution of the contract or any function delegated by law (e.g., to a bank within a settlement or for the provision of services, for example, within the framework of the trade of the electricity service, Lattelecom carries out data exchange with the operator of the distribution network, whereof the Client is informed in the respective service contract);
- in accordance with the Client’s explicit and unambiguous consent;
- to persons stipulated in the external laws and regulations upon their reasonable request, in accordance with the procedure and volume specified in the external laws and regulations;
- in the cases stipulated in the external laws and regulations to protect the legitimate interests of Lattelecom, e.g., by appealing to a court or other state institutions against a person who has violated these legitimate interests of Lattelecom.
- In some cases, subject to statutory requirements, Lattelecom’s personal data is accessed in third countries (i.e., countries outside the European Union and the European Economic Area) by developers or service providers (within the meaning of the Regulation – transmission to third countries) in the status of the data controller (operator).
- In such cases, Lattelecom provides for statutory required procedures to ensure the level of personal data processing and protection equivalent to the level set forth by the Regulation.
- Lattelecom stores and processes the Client’s personal data as long as at least one of the following criteria exists:
- as long as the contract signed with the Client is in force (inter alia, records of negotiations, within the framework of which an oral agreement is concluded / a service application is submitted);
- data are necessary for the purposes for which they were collected;
- as long as Lattelecom or the Client can exercise their legitimate interests in line with the procedure specified in the external laws and regulations (for example, to submit objections or to bring an action in court);
- as long as any of the parties has a legal obligation to store data (for example, in accordance with the Accounting Law, the company must store issued invoices for 5 years, etc.);
- while the Client’s consent to the respective personal data processing is valid, if there are no other legal grounds for data processing.
After the date on which the conditions referred to in this clause cease, the personal data of the Client are deleted. Auditing records are stored for at least one year following the day of their making in accordance with the provisions of laws and regulations.
- The record of negotiations with the Client on the provision of functioning of services, their maintenance, settlements, based on the legitimate interests of Lattelecom, are stored for six (6) months following the date of recording of negotiations, whereafter they are deleted.
- The Client has the right to receive information specified in laws and regulations regarding the processing of his/her data. The majority of the Client’s information is already published on the self-service portal mans.lattelecom.lv and Lattelecom’s websites and applications which are used by the Client to receive Lattelecom’s services and where the Client can check the accuracy of his/her data and, if necessary, to administer them, inter alia, to amend them.
- In accordance with the laws and regulations, the Client also has the right to request from Lattelecom access to his/her personal data, as well as to request from Lattelecom the supplementation, correction or deletion thereof, or to restrict the processing with respect to the Client, or the right to object against the processing (including against processing of personal data carried out on the basis of the legitimate interests of Lattelecom, as well as the right to data portability. These rights are exercisable in so far the processing does not arise out of the obligations of Lattelecom imposed thereon by the applicable laws and regulations and which are carried out in the public interest.
- The Client may submit a request for the exercise of his rights:
- in writing in person in Lattelecom stores* or at the legal address, producing the personal identification document;
- in electronic form by signing it with a secure electronic signature;
- by authorising on the self-service portal mans.lattelecom.lv.
- Upon receiving the Client’s request for the exercise of its rights, Lattelecom verifies the Client’s identity, evaluates the request and executes it in accordance with laws and regulations.
- Lattelecom sends a reply to the Client by post to his/her specified contact address in a registered letter or on the self-service portal mans.lattelecom.lv, or taking into account the type of receiving replies, specified by the Client.
- Lattelecom ensures the fulfilment of data processing and protection requirements in accordance with laws and regulations and, in the case of the Client’s objections, performs useful actions to resolve the objection. However, if this fails, the Client has the right to contact the Supervisory Authority – the Data State Inspectorate.
- The Client may give his/her consent to the processing of personal data, the legal basis for which is consent (for example, analysis of data on the habits of using services, individually prepared programme, etc.), by authorising on the self-service portal mans.lattelecom.lv, in Lattelecom service application forms, Lattelecom service portals/applications, Lattelecom’s and other websites (for example, news subscription forms), calling to the single hotline of Lattelecom’s contact centre at 117 or in person in Lattelecom stores*.
- The Client has the right to withdraw his/her consent to the data processing at any time in the same manner as it was provided, that is — by authorising on the self-service portal mans.lattelecom.lv, by calling to the Lattelecom’s contact centre at 117 or in person in Lattelecom stores*, and in this case, the further processing of data, which is based on the previously given consent, will not be carried for a particular purpose.
- The withdrawal of consent does not affect the processing performed at the time when the Client’s consent was valid.
- The withdrawal of consent cannot stop the processing of data carried out on the basis of other legal grounds.
- Lattelecom communicates with the Client using the contact details provided by the Client (telephone number, e-mail address, mailing address, on the self-service portal mans.lattelecom.lv and in other self-service accounts, as well as using application notifications).
- Communication regarding the fulfilment of obligations arising out of a service contract is carried out by Lattelecom on the grounds of a signed contract (e.g., co-ordination of delivery time or repairing damage, information on invoices, planned work, communication failures, changes in services, etc.).
- Lattelecom carries out commercial communication regarding Lattelecom and/or third-party services and other communications not related to the provision of directly contracted services (such as client surveys) in accordance with external laws and regulations or with the consent of the Client.
- Lattelecom may carry out communication, inter alia, commercial communication, also by using the automatic call equipment.
- The Client may give his/her consent to the receipt of commercial communications of Lattelecom and/or its co-operation partners by authorising on the self-service portal mans.lattelecom.lv, in Lattelecom’s service application forms, Lattelecom’s service portals/applications, Lattelecom’s and other websites (for example, news subscription forms).
- Client’s consent to receive commercial communications is valid until its withdrawal (also after the termination of the service contract). The Client may at any time refuse to receive further commercial communications in any of the following ways:
- by making the relevant note in his/her user profile on the Lattelecom’s self-service portal mans.lattelecom.lv;
- by calling the Lattelecom’s contact centre at 177;
- in person in Lattelecom stores*;
- by changing the notification settings on devices;
- by using the automated option provided in the commercial communication to unsubscribe from further communications by clicking on the unsubscribe link at the end of the relevant commercial communication (e-mail).
- Lattelecom stops sending commercial communication as soon as the Client’s request is processed. The processing of a request depends on technological possibilities, and may take up to seven days.
- When expressing his/her opinion in the surveys and leaving his/her contact details (e-mail, telephone), the Client agrees that Lattelecom can communicate with him/her in relation to the assessment provided by the Client, using the contact details provided by the Client.
- Lattelecom’s websites may contain links to third-party websites which have their own user and personal data protection regulations, and Lattelecom bears no responsibility thereof.
* Information available in Latvian
|Effective from 23.05.2018.|
|Effective from 01.12.2017 to 23.05.2018.|