Privacy Policy

SIA “LIC GOTUS”

PRIVACY POLICY

“LIC GOTUS” SIA privacy policy Last updated: [24.04.2024.]

1.General terms

1.1.We, SIA LIC GOTUS, Reg. No. 40003305341, legal address: Ulbrokas iela 42G, Riga, LV-1021 (hereinafter LicGotus) provide trade services that meet modern standards. It is important for us not only the convenience of customers and the opportunities provided by the services of our store, but also the protection of the privacy of individuals. We invest resources in our daily activities and ensure that personal data is protected in our daily activities.

1.2.The purpose of this policy is to inform and provide an explanation of how the company LicGotus takes care of and protects the personal data that comes into its possession, that is, to help understand in what way and for what purposes the data is processed, as well as to introduce the rights and obligations of data subjects.

1.3.When processing personal data, We comply with the laws and regulations in force in the Republic of Latvia, the binding instructions and regulations issued by the responsible institutions, as well as follow the development of examples of good practice.

1.4.This Privacy Policy applies to every data subject whose personal data we process. Regarding issues, for example, which affect labor legal relations, equipment repair service, we have developed separately binding information, which can be consulted at the relevant stages.

1.5.This Privacy Policy does not apply to data processing activities carried out by other merchants, including if you visit another merchant’s website or use its service. In such cases, we invite you to familiarize yourself with the personal data security guarantees provided by the relevant merchant.

1.6.We have made this Privacy Policy as simple as possible, but please familiarize yourself with the following concepts first:
• Personal data – any information directly or indirectly attributable to a natural person.
• Anonymized data – information that can no longer be attributed to a natural person, as all personal identifying elements are excluded from the personal data set.
• Profiling – any type of automated processing of Personal Data, which manifests as the use of Personal Data in an aggregated or individualized form, for the purpose of evaluating certain personal aspects related to a natural person, such as service usage habits.
• Services – any kind of services and goods that We offer and provide online, remotely or in person.

2.How do we obtain Personal Data?

2.1.The information we obtain about a person depends on the content of the transaction, including the Service applied for or used. We also obtain such information as is provided to Us within the framework of any type of cooperation.
2.2.We can receive personal data in several ways, including:
• the data subject has provided Us with his Personal Data, i.e. when the data subject or his authorized person communicates or cooperates with Us, for example by concluding a contract, using Our Service, signing up to receive news, requesting information or submitting an application for consideration of a specific question or request, visiting Our store in person, communicating with Us in informational channels (for example, in connection with the e-store) or participating in surveys;
• data is generated by using Our Service, for example, visiting or using a website, visiting a store where a video recording is made.
• We may receive data from other sources, for example, if you have requested communication with Us from other service providers or cooperation partners, or if you participate in one of the events organized by Us, during which photos may be taken or a video recording may be made, for which previously provided information. We can also receive data from cooperation partners about authorized persons or contacts who work in a certain task.

2.3.In the provision of services related to, for example, deferred payment, i.e. credit evaluation is important. Debt assessment is an essential and integral part of cooperation. It provides an opportunity to take care of a person’s ability to fulfill their obligations and ensure adequate financial management.

3.What Personal Data We Collect?

3.1. Depending on the Service or cooperation used, the types of Personal Data may differ. In general, we divide the types of personal data into the following categories:
• Basic personal data. Personal identifying data, including contact and communication data, consent data, service and authorization data, settlement and debt collection data, personal visual data (photo, video, etc.), personal document data, etc.
• Broadcast content data. Transmitted content within the framework of certain services, correspondence, calls, video recording.

4.How We Use Personal Data?

4.1.We process Personal Data to provide Services, efficient service, cooperation and other business and social activities related to Our activity.
4.2. For personal data safety purposes, to avoid re-identification, we prefer anonymized data processing. However, the nature of the provided Service, cooperation or event often necessitates the processing of identifiable Personal Data.
• We carry out automated processing of Personal Data. Automated data processing makes it possible to promptly provide an answer that would otherwise have to be done manually and would take much longer.
• When evaluating a person’s creditworthiness in the case of the provision of individual Services or in cases where the client has requested deferred payment in order to ascertain the data subject’s ability to fulfill payment obligations, individual data processing may be carried out. In the event that We have doubts about the data subject’s ability to fulfill, for example, deferred payment obligations, the provision of certain Services may be partially or completely refused. However, the person always has the opportunity to provide Us with information that substantiates the person’s ability to fulfill the obligations of the selected transaction.
• We can carry out profiling in order to better understand the needs of the person and accordingly develop the Services most suitable to the wishes and interests of the person, we can take into account, for example, the previous cooperation with the person, including the duration, volume, content of the transactions, the payments made by the person, the provided wishes, needs and .etc. This gives an opportunity to create an approach to each situation individually, including assessing if there is a long-term cooperation with the person and it is necessary to reach a compromise in exceptional cases in order to solve some non-standard issue. By using profiling in the context of direct marketing, we can make relevant offers to the person, but we take into account the right of each data subject to ask to stop the processing of such data by withdrawing the given consent, or if it was done based on a legitimate interest, to express an objection to the processing of their data for such a purpose.

Profiling is carried out in accordance with the requirements of regulatory acts. The legal basis for such data processing can be both the consent given by a natural person and, in some cases, the legitimate interest, or another basis determined by regulatory acts.

3.3. In order to facilitate the development of the Services or to perform other types of evaluation, We may collect statistics. We process Personal Data only for specific and necessary purposes based on certain legal grounds, including legitimate interests of Licgotus, e.g.:
• For quality control of services and clarification of opinion. The purpose refers to the actions that need to be performed to ensure the quality of the service, to clarify the opinion about the quality of the service (for example, surveys, service call) etc. For example, when contacting Us via the inquiry phone, the customer is informed that the conversation may be recorded for quality assurance purposes. We carry out processing on the basis of law, contract (transaction) and legitimate interest.

• To solve the applied questions. The purpose refers to the mutual communication between the data subject and Us, including applications submitted by the person, submissions, or any contact (including by post, e-mail, etc.). We carry out the processing on the basis of the law and the contract (transaction), including the requested question.

• For providing services and ensuring performance of the contract. The purpose refers to the provision of services and the execution of concluded contracts (transactions). In order to ensure a better customer experience and more complete possibilities of using Our services, We can communicate with the customer (for example, make a service call). We perform the processing on the basis of the law and contract (transaction).

• Billing administration. The purpose refers to the activities carried out within the settlement with the person. We perform the processing on the basis of the law and contract (transaction).
• Conclusion/amendment of the contract. Purpose refers to new orders for an existing or new transaction, including services such as completing a purchase in an e-store, in-store, in any form of application. We carry out the processing on the basis of the law and the contract (transaction).

• Debt recovery. The purpose refers to activities related to debt recovery, including receiving, storing and processing the data necessary for debt recovery, as well as providing and placing information about the debt and the person, including personal data, in the databases of debtors and credit information (credit history) registered in the order specified in regulatory acts, as well as to save and transfer to third parties the information submitted, transmitted and sent to the merchant, including personal data, and information related to the transaction, in order to ensure the execution of the transaction, as well as in cases where the person has not properly fulfilled the terms of the transaction. We carry out processing on the basis of law, contract (transaction) and legitimate interest.

• Management of the offers of the merchant and third parties (cooperation partners). We respect the right of every customer to give, withdraw or change the possibilities of receiving information. In cases where the Customer has expressed a desire to receive information or provide an opinion on specific products or Services, Personal Data may be processed in order to provide the necessary information to the Customer. In such cases, the Client’s consent is always important. If the Customer’s consent refers to receiving information from a cooperation partner, for example, so that the manufacturer can contact the Customer and find out the Customer’s satisfaction with the products of the specific manufacturer’s brand, and in the case of repair, the quality of the repair of the equipment can be assessed, the Customer’s data, for example, name, surname, contact phone number and e- in the context of mail, with the consent given by the Customer, may be provided to a specific manufacturer. We carry out the processing on the basis of legitimate interest and the consent given by the Customer. Fraud prevention and/or credit risk assessment. The purpose refers to the protection of legal interests and the fulfillment of legal and contractual obligations. The purpose includes data processing, including before the conclusion of a transaction and during its execution, which may include actions related to information processing for fraud prevention and credit risk assessment. We carry out the processing on the basis of the law, contract (transaction), legitimate interest and in some cases on the basis of consent given by the data subject.

• Execution of binding regulatory acts. The purpose refers to the basis of personal data processing provided for in regulatory acts, for example in the field of accounting, taxes and fees, etc.
• Security of the merchant’s infrastructure, services, information, employees, customers and visitors, prevention of illegal or other threats, promotion of detection of criminal offenses in objects and the territory adjacent to them, including information systems. The purpose refers to measures that are carried out with physical and logical means of protection, including video surveillance, pass mode and other technical and organizational measures to ensure protection against threats caused by physical exposure and protection that is implemented with means of logical protection. We carry out processing on the basis of law, contract and legitimate interest.

• Organizational management of the merchant (including record keeping, processes, services, information systems, records of persons, ensuring succession of the merchant, realization of public relations and social responsibility). The purpose refers to measures for the integrated management of the company, including in accordance with national and internationally recognized principles of corporate governance, ensuring traceability, control, and improvement of internal processes. We process on the basis of law and legitimate interest.

• Accounting/ financial and tax management. The purpose refers to accounting, tax payment, settlements, etc. We carry out the processing on the basis of the law and the contract (transaction).

• Statistics and analytics of processes, services, information systems to identify correlations and trends in order to develop and improve them. The purpose refers to the processing of personal data at our disposal to evaluate the results of service sales in order to develop and improve services, processes, systems and to determine the company’s goals and development directions. We process on the basis of legitimate interest.

• Ensuring customer service within the “life cycle”, including improving satisfaction and loyalty. The purpose refers to the processing of personal data for the improvement of cooperation, promotion of loyalty and maintenance of satisfaction (loyalty call, service call to a person with the aim of improving the experience, clarification of wishes and needs, determination of personal satisfaction). We process on the basis of legitimate interest.

• Processing of personal data for internal administrative purposes within the Licgotus company. The purpose refers to the processing of personal data for the internal administrative purposes of group companies, for example, to prevent conflicts of interest and to prevent illegal transactions. We process on the basis of legitimate interest.
In any of the mentioned cases, we process Personal Data only to the extent that the specific processing purpose allows.

How We Protect Personal Data?

In order to protect the interests of natural persons, we continuously develop our security processes and measures. Such security measures include the protection of personnel, information and technical resources, IT infrastructure, internal and public networks, and the store and office building. As part of these measures, we ensure an appropriate level of information protection to prevent unauthorized access to Personal Data.

5.To whom may we provide Personal Data?

5.1.The exchange of personal data may be necessary in certain cases when it has a specific purpose, for example, We may need to provide Personal Data to the following categories of data recipients:
• Cooperation partners. Merchants with whom Licgotus has concluded cooperation agreements and there are mutual obligations (for example, accounting outsourcing providers, legal offices, product insurance). Likewise, for the provision of services (including face-to-face and remote sales sellers, equipment installers, equipment repair, etc.), for the provision of delivery (including printing of invoices, delivery of parcels and contracts, etc., including couriers, postal service providers, etc. .etc.), service quality control (including survey providers, etc.), security and protection (collaboration partners who provide support for the security and protection of LicGotus employees, customers, visitors, objects and infrastructure, as well as fraudulent, illegal or other LicGotus for the prevention of threats and infringements of the company’s interests, including security, legal assistance providers, etc.) and for ensuring management (cooperation partners for managing and ensuring the organizational, financial management and accounting processes of LicGotus, including auditors, auditors, event organizers, etc.), within the scope of the authority issued to the trustee.

• Institutions/companies engaged in debt recovery. Including debt recovery companies, credit information and credit assessment companies, bailiffs, administrators and other persons in the debt recovery process.

• Supervisory authorities. For example, market surveillance authorities, e.g. Consumer Rights Protection Center and law enforcement institutions (court, Sworn Bailiffs), including for the protection of Our legal rights, for example, to sue in court and rescue services in accordance with regulatory enactments.

• Third parties. For example, natural or legal persons, public authorities, agencies or bodies that are not data subjects, controllers or processors.

In addition to the above, there may be cases when we transfer Personal Data to another person in connection with the transfer of companies, any merger, acquisition, transfer of the provision of the Service to another merchant, etc.

5.2.We also process anonymized data that is not related to a specific natural person and does not allow the identification of the data subject. Such data may be used for other purposes and transferred to other persons. We ensure the confidentiality of Personal Data by taking security measures in accordance with the regulations.

6.How long we keep Personal Data?

6.1.6.1. We store personal data only for as long as necessary for a specific purpose, to fulfill obligations and comply with legal data processing requirements. For example, while LicGotus can implement the protection of its legal interests in accordance with the procedures set out in external regulatory acts (including filing objections and complaints or bringing a lawsuit before the statute of limitations for the performance of the obligation has expired), as long as one of the parties has a legal obligation to store data (for example, to store the service invoices for 5 years, as determined by the Law “On Accounting”), while the client’s consent to the relevant processing of personal data is valid, and the data obtained as a result of video surveillance is usually stored for 90 days. Accordingly, when these conditions expire (or when the term expires), the data is deleted.
6.2.Data of registered customers is stored for 2 (two) years after the end of service provision.
6.3.Restrictions do not apply directly to the storage of anonymized data, but we also store them only to the necessary extent and duration.

7.How We Use Cookies?

7.1.Similar to the websites of other companies, the LicGotus website may also use cookie technology.
7.2.Cookies allow us to adapt the website to the needs and convenience of the visitor (including based on statistical data collected in aggregate form, without directly identifying the customer. Also, cookies allow us to address the website visitor individually if the visitor has given his consent.
7.3. Unless otherwise provided by law, a person has the right to refuse further processing of their data at any time, but in this case, especially if the said data is technically essential, there is a possibility that we will not be able to provide the service and provide customer service to the same extent as before.

8.What are the rights and obligations of the subject of the data?

8.1. Subject of Data has the rights to:
• get acquainted with the information that We keep about him, as long as it does not contradict the regulatory enactments and does not unreasonably affect the rights of other persons.
• request access to your data, their correction or, if necessary, addition, deletion (the right to be forgotten), restriction of processing, or object to their processing in the cases specified in regulatory acts, as well as the right to data portability.

We inform you that in the case of data correction, deletion, restriction, termination or portability, partial or complete suspension of services/processes is possible in an irreversible manner. When choosing to receive information about himself remotely, for example by mail, e-mail, to another addressee or the like, the applicant is responsible for the safety of the chosen method of receipt and the actions of the persons acting on behalf of the applicant.

• request a copy of the personal data being processed if it adversely affects the rights and freedoms of other persons. It should be borne in mind that for any additional copies requested by the data subject, LicGotus may require a reasonable fee based on administrative costs.

• at any time easily withdraw the consents you have given yourself. Giving or withdrawing consent is a person’s free choice and does not impose any mandatory additional obligations. The customer can give his consent to data processing in the service application forms on the portal www.weberbaltic.com, in the banners placed on www.weberbaltic.com, in person at the Licgotus store or by writing to [email protected].
However, if the person decides to withdraw any of the given consents, it should be noted that the data processing related to the specific consent will no longer be provided and the previous options may no longer be available. For example, opting out of receiving current news will mean that news or other current affairs will no longer be delivered. It is important to remember that such withdrawal does not affect the lawfulness of the data processing carried out up to the withdrawal.

• object at any time and free of charge to the processing of your data by us for direct marketing purposes, insofar as it is related to such direct marketing, regardless of whether it is initial or subsequent processing.

• contact Us and market surveillance authorities regarding data processing issues. If you need support in receiving more information about this privacy policy, aspects of data processing or applicable data protection regulations, please contact Us so that we can carefully consider the question and provide an answer. In any case, a natural person always has the right to file a complaint with the Data State Inspectorate (data protection supervisory authority in Latvia).

9.1.2. We consider the submissions of our data subjects in connection with the mentioned rights free of charge. Consideration of the submission may be refused, or a proportionate fee may be applied for it, if they are submitted obviously unfounded or excessively, as well as in other cases provided for by regulatory acts. The application can be submitted in a store or company office or remotely, providing the opportunity to identify yourself as a specific personal data subject and verify the nature and justification of the submitted request.

8.2. The Subject of Data has an obligation to:

• provide Us with information about changes in the data provided within a reasonable period of time. It is important to us that the company has true and up-to-date information.

• provide additional information if necessary. As part of communication and cooperation, we may ask you to provide additional information to make sure that the communication or cooperation takes place with a certain natural person. This is necessary for the protection of the data of the specific person and other persons, so that it is clear that this person is the subject of Personal Data and that the information about this person disclosed in the framework of communication and/or cooperation is disclosed only to this specific person, without infringing the rights of other persons. For example, when a person wants to find out information about himself by sending Us a request. In this case, it is important for Us to make sure that this person has signed and submitted this request. Accordingly, we may ask you to provide additional identifying information. However, if the person has not provided additional information and/or We have doubts about the identity of the requester, then for the purposes of personal data protection (so that they are not disclosed to third parties), we can postpone the consideration of the request until we are sure that it was this person who requested the mentioned the news.

• familiarize yourself with this Privacy Policy before starting cooperation, as well as introduce it to every person who is related to this data subject and whose interests may thus be affected by the data processing processes of this person. This Privacy Policy is an integral part of the services we provide. We expect that the data provided to Us does not affect the interests of other persons. In cases where, in accordance with the relevant conditions, a person has the opportunity to grant access or jointly use his Services with another person, he is responsible for informing these persons about the data processing carried out within the specific process and the resulting obligations. In cases where the data directly concerns another person (in the case of a change of data subjects), the person is obliged to inform us about it without delay. Until full identification of persons, the data is attributed to the specific natural person as a data subject.

9.How to find out information about changes to this Privacy Policy?

Since we are constantly improving and developing our operation, there is a possibility that we will periodically amend and supplement this Privacy Policy. Therefore, we invite you to regularly familiarize yourself with the current version of the Privacy Policy. It is available on our communication channels, including on the website www.licgotus.lv and www.weberbaltic.com. When we make changes to this policy, we will notify you with a notice on our website. In case of significant changes, information may be provided through additional channels, for example, by means of a text message to the phone number or e-mail specified by the customer.

10.How to contact us?

If you have any questions or concerns regarding this Privacy Policy or the processing of Personal Data, please contact Us using the contact information below.

SIA “LIC GOTUS”,
• Our informative telephone nr. +371 67556949
• e-mail: [email protected]

11.How to contact the State Data Inspectorate

We ensure the fulfillment of data processing and protection requirements in accordance with the highest standards of regulatory acts, and in case of any objection, LicGotus will take all appropriate actions to find a solution. However, if this fails in the opinion of the data subject, the data subject has the right to apply to the Data State Inspectorate, Elijas iela 17, Riga, LV-1050. More information is available: on the website: www.dvi.gov.lv.
If this privacy policy has been translated into other languages, then the Latvian text is decisive in case of contradictions.