Privacy policy 

About the Privacy Policy

  1. The present Privacy Policy aims to inform you about how SIA IMK 365processes the personal data related to the persons specified below, for what purposes SIA IMK 365collects and processes personal data, what are the grounds for processing personal data, the term of processing personal data, what are the rights of data subjects in relation to this processing, as well as other information aimed at ensuring transparent and conscientious processing of personal data by SIA IMK 365.

Personal data is processed in accordance with applicable law – Regulation (EU) 2016/679 Of The European Parliament And Of The Council 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (“Regulation”), as well as other legal acts governing data processing and the right to privacy.

Which are the persons whose personal data is processed?

We process personal data related to the following persons (“You”, “Data Subject”):

  1. Legal representatives, proxies, subcontractors, associates, and employees of our suppliers and business partners (“Contractors“), as well as personal data of data subjects of legal representatives, proxies, subcontractors, associates, and employees which may become our business partners.
  2. Persons making inquiries, requests, and other messages to us by mail, e-mail, telephone, and other means of communication;

Contractors

The personal data that may be collected and processed by SIA IMK 365 within our relations with Contractors might be the following:

  • Identification data of Contractors, their legal representatives and proxies – full name, citizenship, , address, email address as well as identification data about the ultimate beneficial owners and representatives of the companies with which We are to enter into contractual relations;
  • Business contact details – address, contact phone, e-mail;
  • Other information related to the Contractors, their employees and representatives, provided or created in the context of our business relations and activities, including in negotiations and legal disputes.

Website visitors

  1. The Website uses cookies. Cookie is a small text file that is sent to Your computer or mobile device when You visit the Website and saved by the Website on the hard drive afterwards. Cookie act as a memory for the Website, allowing it to remember Your computer or mobile device the next time You visit. Cookies are used to increase the functionality of the Website and to make it easier to use.

    SIA IMK 365 does not collect or process personal data through cookies. Cookies used on the Website are of necessary nature and are essential for the Website’s proper operation.

    Cookies will be stored on the Your computer until they are expired or deleted. Some cookies are important for the operation of the Website, so the use of cookies may affect its functionality. The use of such cookies does not require the user’s consent. Such cookies include:

    • authentication cookies.
    • technical cookies required by certain IT systems.
    • security cookies, which are used to detect authentication abuses and are associated with functionality explicitly requested by the user for a limited and permanent period of time.
    • load balancing session cookies for the duration of a browser session.
  2. When you make requests, inquiries, and other communications to us, we may process your personal data, such as names and contact details, which you have provided to us voluntarily for the purposes of carrying out communication with you and to respond to your inquiry.

For what purpose does SIA IMK 365 process your Personal Data?

SIA IMK 365 processes personal data for the following purposes:

  1. Processing of personal data necessary for taking actions before concluding a contract, as well as for concluding, performing, and terminating a contract with Contractors
    • Identification of legal representatives, proxies, employees, and beneficial owners through publicly available channels, as well as when these data are provided by the Contractors of SIA IMK 365 before the conclusion of the contract;
    • Preparation of offers, contracts, and all other documents accompanying the contract, as well as any other documents created in the context of business relations with the business partners of the Company;
  2.  Processing of personal data needed for compliance with a legal obligation
    • Personal data necessary for compliance with a legal obligation of SIA IMK 365, including, but not limited to: (i) legal obligations established in the tax and accounting legislation, gambling legislation (as applicable), customs legislation etc., (ii) obligations provided for by regulations in terms of proper and legal bookkeeping, (iii) obligations for the provision of information to all state commissions and regulatory authorities, (iv) provision of information to courts and law enforcement institutions.
  3. Processing of personal data based on legitimate interest
    • Provision of data by you in our client/partner questionnaires, such as data about politically exposed persons;
    • Exercising and protecting the legal rights and interests of the Company.
  4. Processing of personal data based on consent

We process personal data based on consent in cases when you have provided that data voluntarily, for example for the purposes of carrying out communication with you and to respond to your inquiry that was received via our official channels.

То whom may SIA IMK 365 disclose your Personal Data?

SIA IMK 365 may use third parties to support certain contractual activities or with regard to the performance of a legal obligation. SIA IMK 365 does not provide personal data to third parties before the requirements for disclosure of personal data to third parties provided for in the applicable legislation are met.

We do not disclose Your personal data to third parties, except:

  • when such personal data processed to the extent necessary to achieve the purpose of provision of services to which You have agreed and within the process or services which third parties provides to the SIA IMK 365;
  • according to the clear and undeniable consent of Data Subject;
  • to persons provided for by regulatory enactments in the manner and amount established therein;
  • in cases provided for by regulatory enactments for the protection of legitimate interests.

The service providers that provide us with services that include the processing of Your personal data, belong to the following categories:

  • service providers and their subcontractors;
  • banks, financial auditors, legal advisers, security companies, and other service providers;
  • service providers which on assignment and on behalf of the Company maintain equipment, software, and hardware used to support the activities of SIA IMK 365, as well as hosting companies and sales agents, etc.;
  • state and municipal bodies, including, but not limited to, regulatory bodies, state commissions, institutions and agencies, tax department, law enforcement authorities and others, to which SIA IMK 365 should provide information that may contain personal data under the applicable legislation.
  • We guarantee and ensure that third parties process Your data in accordance with the agreement concluded between Us and such third party and requirements contained therein, as well as that We always cooperate only with reliable partners who ensure compliance with data protection laws and regulations.

What technical and organizational measures for data protection do we apply?

  1. SIA IMK 365 stores only that information, which is adequate, relevant and limited to what is necessary in relation to the above indicated processing purposes. Any information in excess is disregarded and deleted accordingly. Any information provided is subject to ongoing monitoring, kept up to date and retained in accordance with applicable law and with our policies and procedures.
  2. In accordance with applicable law, SIA IMK 365 implements all necessary technical and organizational measures to protect personal data from accidental loss and unauthorized access, use, alteration, or disclosure. The Company has adopted and ensured the implementation of internal policies and procedures designed to protect information from loss, misuse, and improper disclosure.
  3. In addition, SIA IMK 365 implements information security measures, including, but not limited to, access control, strict physical protection, and robust practices for collecting, storing, and processing information, such as encryption, pseudonymization, and anonymization of the collected personal data.

When do we delete your Personal Data? 

  1. SIA IMK 365 stores personal data within the statutory time limits, and if there are not explicitly defined statutory time limits, within the time limits set by the Company in order to achieve the purposes of the personal data processing listed above. The Company deletes personal data after the expiration of the statutory deadlines for their storage and/or achieving the purposes of data processing, but in any case, not before the final settlement of all our financial relations.
  2. SIA IMK 365 stores personal data until:
    • Data is necessary for the purpose for which it was obtained;
    • The Data Subject or the Controller can exercise their legitimate interests in the manner prescribed by regulatory enactments (for example, to file objections or to initiate legal proceedings);
    • There is a legal obligation to store personal data (for example, data related to payments for delivered services);
    • Data Subject’s consent to the corresponding processing of personal data is valid unless there is another legal basis for the processing.

Do we transfer personal data outside EU/EEA?

The transfer of personal data is secured by modern technical means. In principle, SIA IMK 365 does not transfer personal data to persons outside the EU / EEA. In the event that such transfer is necessary for the fulfilment of some of the above purposes, the transfer will be carried out in compliance with the requirements of applicable law and after the informing the Data Subject.

What are Your rights in relation to the protection of your Personal Data?

  1. In order to fulfil the obligations of SIA IMK 365 as a Data Controller, it is important for the Company to process and maintain your Personal Data accurate and up-to-date; if necessary, you may request an update of your Personal Data, correction, and/or supplementation, for which purpose you should send an application/request to the Company in compliance with the terms and conditions provided for in the legislation on Personal Data protection.
  2. You have certain rights related to the processing of your Personal Data provided in the GDPR, including:
    • Right to information and free and open access to your Personal Data, as well as the right to request a copy of your personal data stored or otherwise processed by SIA IMK 365;
    • The right to request correction of your personal data in case it is inaccurate, not up-to-date, or incomplete;
    • In the presence of the conditions set out in the GDPR or national law, you also have the right to request the deletion of your Personal Data or the restriction of their processing, as well as to exercise your right to the portability of your Personal Data (when applicable);
    • If you have any doubts that your Personal Data is not being processed lawfully by SIA IMK 365, you have the right to file a complaint to the competent data protection supervisory authority listed below in this Policy, or to seek the protection of your rights judicially.
  3. Please note that SIA IMK 365 does not use your Personal Data for profiling or automated decision making.
  4. The terms and conditions for exercising your rights related to the protection of Personal Data are regulated in detail in the Regulation. You may exercise your rights by making a written request to SIA IMK 365 on the contact details provided in this Policy in accordance with the requirements of applicable law. If necessary, SIA IMK 365 will provide you with full assistance in exercising the rights granted to you.
  5. All personal data requests mentioned in Article 12.2. of the Regulation shall be made in writing, signed by the data subject and submitted to legal.department@imk365.com  or the management address of the Company.
  6. The Company will respond to such requests by no later than 30 (thirty) calendar days (with the possibility to extend this period for particularly complex requests in accordance with applicable law), implement them if there are grounds for doing so or make a reasoned refusal if there are reasons for doing so, indicating the right of the data subject to follow.

Competent national supervisory authority for Personal Data Protection

Data State Inspectorate of Latvia

Address: Elijas street 17, Riga, LV-1050, Latvia

Phone number: +371 67223131

E-mail:  pasts@dvi.gov.lv Website: https://www.dvi.gov.lv/

Changes to the present Personal Data Protection Policy

This Data Protection Policy may be amended over time, and the changes made to it shall become effective promptly after being announced on the Company’s website.

This Policy is effective as of 24 February 2023