1. Introduction

The limited liability company Ledakcijas.lv (hereinafter - we or Ledakcijas) is a commercial company registered in the Republic of Latvia, which deals in the trade of consumer non-food products. At the moment we have stores in Riga. In addition to that, within the framework of cooperation agreements concluded with leasing companies, we, as a cooperation partner, offer to conclude leasing transactions for the purchase of goods.

2. What is personal data and how we process it

Personal data is any information relating to an identified or identifiable natural person (data subject). Personal data includes any type of information by which a person can be directly or indirectly identified, such as the name, surname, personal identification number, residential address or actual location of the said person, physical, physiological, genetic, mental, economic, cultural or social characteristics of that person. identity factors, and other similar information that characterizes the relevant person and allows him to be directly or indirectly identified.

With regard to your personal data, we are the data controller who determines the purposes and means of processing personal data, except for the execution of leasing transactions, where we, in accordance with the contract concluded with the leasing company, act as a personal data processor.

3. Purpose of personal data processing

We process personal data for the following purposes:

Registration of permanent members.
Membership in our shopping club gives its members the opportunity to purchase goods at a discount, to use special offers, as well as to use the special offers of our cooperation partners. To register as a club member and receive a membership card, we ask you to provide your name, surname and phone number. We need this data to identify and contact club members. Membership in the club is not possible without submitting these data. By completing the registration form, the club member can apply to receive commercial notifications. If the Club Member has agreed to receive commercial communications, we will send them using the communication method specified by the Club Member.

Sale of goods.
For this purpose, we collect personal data only if the goods are purchased through the online store, or the payment for the goods is made by bank transfer or the receipt of the goods is made on the basis of a power of attorney, or the customer pays for the purchase in cash for an amount exceeding EUR 1500.00. In this case, we process personal data to identify the customer and prepare the payment document (if payment is made by bank transfer); to submit a declaration to the State Revenue Service (in case of cash payment), or to identify a person who is authorized to receive goods on behalf of another person. Personal data is also processed in other cases related to the sale of goods - for example, if the buyer approaches us with a claim about the non-conformity of the goods, referring to the Law on the Protection of Consumer Rights; for settlement administration, including debt recovery and recovery (if the product is purchased with post-payment), consideration and processing of customer claims, and in similar cases.

Supply of goods.
If the customer wants to receive the product delivery service, we ask for the customer's first name, last name, delivery address and phone number. If we choose to deliver the product through the services of a third party, we transfer this data to the service provider.

The purpose of processing the personal data of the Lottery participants is to organize and implement the Lottery in accordance with the Lottery rules, identify the Lottery participants, determine and award the Lottery winners, and provide information about the Lottery. The basis for processing the personal data of the Lottery participants is the Lottery participant's consent to participate in the Lottery. Namely, consent to participation in the Lottery is simultaneously considered consent to the processing of one's personal data in the manner and to the extent specified in this appendix. Without consent to the processing of your personal data, participation in the Lottery is not possible.

Video surveillance.
Video surveillance is used to ensure security and supervision in our premises and territory, as well as for the purpose of protecting our property and that of our customers. Video surveillance recordings are stored for a maximum of 30 days. After the expiration of this term, we delete these recordings, except in the case that the video surveillance recordings have not previously been requested by competent state or local government institutions, or no criminal offenses have been detected. In this case, the storage duration of video recordings is determined as necessary.

Upon receiving a relevant request, we provide information to state administrative authorities and subjects of operational activity in the cases and to the extent specified in the regulatory acts.

Leasing transactions.
In this area, we act as a personal data processor in accordance with the cooperation agreement concluded between us and the leasing company. We process personal data on behalf of the relevant leasing company, this processing being carried out strictly in accordance with the concluded cooperation agreement and according to the instructions of the controller of personal data, ie the leasing company.

Staff selection.
We process the data of persons who have expressed their desire to apply for vacant positions in our company. The data obtained during the employee selection process are used only to assess the applicant's suitability for the position (qualification, experience, etc.). We do not request data that does not relate to the performance of the intended work or is not related to the applicant's suitability for the position. We also do not request information that is not necessary for the evaluation of suitability for the position, and we also observe the restrictions set by the Labor Law regarding information requests. We obtain references from previous workplaces only under the condition that the applicant has previously given written consent. Applicants' personal data is processed in accordance with the terms and conditions stipulated in this policy.

Other cases.
We process personal data in previously unspecified, special cases, informing the data subject about the purpose of data processing at the time of data acquisition. For example, from time to time we hold surveys, customer days, and similar events, as part of which personal data may be processed. Personal data processing is also carried out in exceptional cases to protect the vital interests of the data subject or a third party.

4. Legality of personal data processing

We process personal data exclusively for legitimate purposes, i.e. if at least one of the following justifications can be found:

· the processing of personal data is necessary for the execution of a contract, the contracting party of which is the data subject, or, if the data subject is the contact person, representative, attorney, or similar of the contracting party, or for taking measures at the request of the data subject before concluding the contract;

processing is necessary for the legitimate interests of us or a third party, except when the interests of the data subject or the fundamental rights and fundamental freedoms that require the protection of personal data are more important than such interests of ours, especially if the data subject is a child;

· the data subject has given consent to the processing of his personal data for one or more specific purposes;

· the processing is necessary to fulfill a legal obligation applicable to us;

· processing is necessary to protect the vital interests of the data subject or another natural person.

5. Processing of special categories of personal data

Special categories of personal data are data revealing a person's racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, and genetic data, biometric data for the unique identification of a natural person, health data or data about a natural person's sex life or sexual orientation.

As a data controller, we do not process the data of special categories of our customers. The only exception can be made only if the processing is necessary to protect the client's vital interests (for example, due to the sudden deterioration of the client's health, it is necessary to call an ambulance, and in similar emergency situations).

In the cases provided for in the Labor Law and other regulatory acts, we process the data of special categories of applicants for vacant jobs in our company. For example, we have the right to require the applicant to undergo a health examination to ensure his suitability for the intended job.

Regarding the execution of leasing transactions, we, as a personal data processor, process certain special categories of personal data in the interest and task of the leasing company as a data controller. For example, in connection with the amount of income, information on received pensions and benefits may be requested, which, in turn, may directly or indirectly indicate the state of health of the data subject.

6. Website visits and cookie processing

The ledakcijas.lv website uses cookies. Cookies are small alphanumeric files that we store in your browser or on your device's hard drive. There are different types of cookies that we use for different purposes; but in general, cookies help us distinguish you from other website users. Thus, we can make it easier for you to use the website and improve your website. You can block the use of cookies at any time by activating the settings of your browser that allow you to refuse the use of some or all cookies. However, if you block the use of cookies, part of the website may be unavailable or may not function sufficiently.

Our website may contain links to websites of third parties. These third parties have their own privacy policies that are not affiliated with us in any way. Ledakcijas.lv SIA bears no responsibility for the terms of use of this website and its privacy policy.

7. Notices

We send commercial notices about the services offered by ledaktsii.lv and other types of notices and reminders to our clients only if it is permitted by law or if the client's explicit consent has been received.

Customers have the right to opt out of receiving notifications and reminders at any time by sending an opt-out notification to the e-mail address info@ledakcijas.lv

8. Recipients of personal data

We use services provided by third parties to help us conduct and administer our business. These are third parties such as credit institutions in connection with the settlements to be made; our information technology and database maintainers and their administration service providers; cloud computing service providers; providers of legal services, accounting and auditing services; debt collection companies; providers of document copying, scanning and destruction services; third parties through whom we send commercial and other communications and information; a security company that has access to CCTV footage; third parties who provide prizes in our contests and sweepstakes; third parties who conduct customer surveys on our behalf and compile the results of these surveys. In each specific case, we submit to the data processor only the amount of your data that is necessary for the relevant purpose and task. The data are processed only for this purpose and task, they are protected in accordance with the requirements of the Regulation and other valid regulatory acts. After reaching the goal or completing the task, your data is permanently deleted, with an audit record of the fact of deletion being kept.

In addition to what is specified, we transfer your data to persons provided for in external regulatory acts in the manner and to the extent provided by the relevant regulatory act (for example, to the State Revenue Service, law enforcement authorities, courts, etc.). We can also transfer your data to third parties in the cases provided for by regulatory acts for the protection of our legitimate interests (for example, applying to court for debt collection, etc.)

9. Duration of personal data storage

We store your data no longer than is necessary for the purpose of processing it. Data is stored for as long as:

· the agreement reached or the contract concluded between us is valid, and as long as one of the parties to the agreement or contract can realize its legitimate interests (for example, submit claims and applications, file a lawsuit, etc.);

· data processing is necessary for us to fulfill our legal obligations;

· data processing is necessary to protect your or a third party's vital interests;

· Your consent to the relevant processing of personal data is valid, if there is no other legal basis for processing personal data.

After the above circumstances cease, your personal data is permanently deleted.

10. Data security

We take a responsible approach to the security of your personal data. Ledakcijes.lv has taken the necessary measures to ensure adequate protection of personal data. We use a variety of personal data security technologies and procedures to protect your personal data from unlawful access, use or disclosure. However, please note that no data transmission over the Internet can be guaranteed to be absolutely secure. We ask you to independently evaluate the risks related to the confidentiality of information in each individual case, which you will have to undertake if you decide to transfer any information containing personal data to us via the Internet.

11. Your rights

The regulation provides a series of rights that you can exercise at any time by contacting us. We undertake to provide you with the opportunity to use these rights and fulfill the obligations of the controller or processor of personal data provided for in the Regulation and other regulatory acts.

You have the right to receive confirmation from us as to whether or not your data is being processed and, if processed, to access your data and receive the following information about it: purposes of data processing; categories of personal data; recipients of personal data; the duration of storage of personal data or the criteria by which the duration of storage is determined.

You have the right to ask us to correct your data if it is inaccurate.

You have the right to request the erasure of your data, and we will comply with this request without delay if at least one of the following conditions exists:

· the data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;

· You withdraw your consent to data processing, and if there is no other legal basis for its processing;

· if data processing is based on our or a third party's legitimate interests, there is no more important legitimate basis for the processing;

· You object to the processing of your data for direct marketing purposes;

· if the data has been processed illegally;

· to ensure the fulfillment of a legal obligation imposed on us by regulatory acts;

· if your data was collected in connection with the offering of information society services.

You have the right to request that we restrict the processing of your data. We will fulfill this request without delay if at least one of the following conditions exists:

· if you dispute the accuracy of the data - for the time during which we can check the accuracy of your data;

· if the processing is illegal, but you object to the deletion of data and request the restriction of data use instead;

· we no longer need your data, but you need it to bring, exercise or defend legal claims;

· You have objected to the processing of your data based on our or a third party's legitimate interests, until it has been verified that our legitimate reasons are not more important than your legitimate reasons.

You have the right, based on reasons related to your particular situation, to object at any time to the processing of your personal data based on our or a third party's legitimate interests. In this case, we will no longer process your data, except if we indicate compelling legitimate reasons for processing that are more important than the interests, rights and freedoms of the data subject, or to establish, exercise or defend legal claims.

As indicated above, you have the right to request the restriction of your data processing and to object to data processing. However, please note that if we are not entitled to perform the relevant action as a result of the exercise of this right, this may make it impossible or limit your ability to achieve the desired result. Therefore, before making a decision to limit or object to the processing of your personal data, please contact us in order to clarify all the questions that interest you and eliminate any confusion, and make a balanced decision.

If you believe that your personal data is being processed unlawfully, without grounds, or that its processing otherwise violates the requirements of the Regulation or other regulatory acts, or you have any doubts or questions about the processing of your personal data, please do not hesitate and contact us with a relevant application, submission or complaint. We will provide answers to all the questions that interest you and will correct the mistakes made, if there are any.

If you believe that your personal data is being processed unlawfully, unreasonably, or that its processing otherwise violates the requirements of the Regulation or other regulatory acts, you have the right to file a complaint with the State Data Inspectorate.

12. How to contact us

You can contact us:

· in writing, sending correspondence to the legal address of "EverEco SIA" Cesvaines iela 15a, Riga, LV-1073;

electronically, using the e-mail info@ledakcijas.lv


EverEco Ltd


15A Cesvaines Street,

Riga LV-1073, 1st floor

VAT Reg. No.: LV40103688747

Bank: AS Citadele banka

IBAN account no.: account LV06PARX0016588810002


Phone: +371 200 22 881

E-mail: info@ledakcijas.lv

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