Personal Data Processing Policy
Valid as of January 1, 2022 (Revision 22/01)
1. Purpose and Application of the Present Policy
1.1. This policy for the processing of personal data of the customers (hereinafter referred to as the "Policy") describes the general procedure in which the SELLER, namely – Limited Liability Company (SIA) – packaging factory of the city of Jelgava (SIA "Jelgavas pakotājs rūpnīca Marss") processes the personal data of natural persons.
1.2. Personal data is any information pertaining to an identified or identifiable natural person. More information about personal data processed by "Krauzes" is given in Section 3 of the present Policy.
1.3. This Policy is applicable to ensure the protection of personal data of the indicated natural persons (hereinafter referred to as "Customers"):
1.3.1. The SELLER – SIA "Jelgavas pakotājs rūpnīca Marss" – applicable to Customers who use, have used or have expressed a wish to use the services provided by the SELLER SIA "Jelgavas pakotājs rūpnīca Marss", and/or who have bought or expressed their wish to buy goods from the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss"), or are otherwise related to the services provided and/or the goods sold by the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss"), including in relations with Customers established before the adoption of this Policy;
1.3.2. applicable to natural persons who visit the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") company facilities, including, related to natural persons who are under video surveillance;
1.3.3. applicable to natural persons who visit the home page (site) of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss"), namely, www.pako.lv and/or the site www.pakoshop.eu
1.4. the SELLER – SIA "Jelgavas pakotājs rūpnīca Marss" has developed and complies with this Policy in order to ensure the privacy and protection of personal data of the Customers during the legal processing of personal data. The Policy was developed in accordance with Regulation 2016/679 of the European Parliament and the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (General Data Protection Regulation), in accordance with the Personal Data Processing Law [Personas datu apstrādes likums] of the Republic of Latvia and other regulatory enactments applicable to personal data processing.
1.5. This Policy applies to data processing regardless of how the Customer provides personal data (on the SELLER's – SIA "Jelgavas pakotājs rūpnīca Marss" – home page, paper form or by the telephone) and in which of the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") company systems or in paper form the personal data mentioned are processed.
2. Controller of personal data processing and its contact information
2.1. The controller of personal data processing is SIA "Jelgavas pakotājs rūpnīca Marss", company registration No. 40003385065, legal address: Vidus iela 46, Jelgava, LV-3008, Latvia (hereinafter and above referred to as the SIA "Jelgavas pakotājs rūpnīca Marss").
2.2. In matters related to the processing of personal data, anyone can contact SIA "Jelgavas pakotājs rūpnīca Marss", by sending an e-mail to info@pako.lv or by turning to the office of SIA "Jelgavas pakotājs rūpnīca Marss" at the address Lacu iela 42k, Jelgava, LV-3008, Latvia (hereinafter referred to as the Office) (Office hours are every working day from 9.00 to 16.00).
3. Collection and categories of personal data
3.1. Personal data may be obtained from the Customer and/or, if necessary, also from other sources, such as publicly available information or third parties. The categories of personal data that the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") may collect and process are mainly the following:
Identification data: Name, surname, personal identification number, date of birth, identity document number/ID card number (if it is necessary to identify the person).
Contact information: Residential addresses, e-mail address, phone number.
Contact details: Data which are collected when the Customer visits the office and other sites of the SELLER – SIA "Jelgavas pakotājs rūpnīca Marss", where the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") provides services and/or sells goods, or during communication with the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") representatives, by means of postal correspondence, visual records, data.
Data of the contact person/authorized person Name, surname, e-mail address, telephone number of the customer's contact person/authorized person. Data related to service contracts of SIA "Jelgavas pakotājs rūpnīca Marss", concluded and voided contracts, performance or non-performance of the contract, applications, requests, complaints and other related information submitted in this regard.
Data related to the SELLER – purchase contracts Concluded and expired contracts, performance or
non-performance of the contract, applications, requests, complaints and other related information submitted in this regard.
Product purchase data: Product name, product code, date of purchase, delivery note and/or advance invoice number, product delivery/receipt method, price, payment method, delivery note information, payment order information.
Settlement/payment data: Credit institution account number, invoice information, including invoice number, date, payment date, amount.
Debt information: Principal debt amount, collateral claims, delay period, debt collection information.
Customer Consent Information: The mark (check-mark), date, time and method of obtaining the consent expressed by the Customer.
Actions performed on the website of the SIA "Jelgavas pakotājs rūpnīca Marss" Only the information that the Customer fills in (if required) in the section "Contact us", "Price request", "Register account"
Existence of insolvency status
3.2. For the avoidance of doubt, it should be explained that only those personal data necessary to achieve the goals specified in Section 4 of the Policy are collected and processed about the Customer. Only in very rare cases will all personal data indicated in Appendix No. 1 and/or personal data not mentioned in Clause 3.1 of the Policy be collected and processed about the Customer.
4. Aim of processing the personal data
The SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") processes the personal data for the following purposes:
4.1. For providing services and selling goods: in order for the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") to be able to identify the Customer; for it to prepare, conclude and execute the concluded contract or, at the request of the Customer, take the necessary measures before concluding the contract; to ensure delivery of goods and provision of services; in order to ensure the operation of services; ensure the relevance and correctness of data by checking and, if necessary, supplementing, correcting, deleting personal data; For customer service; for reviewing and processing reviews, complaints and other documents submitted by Customers; for settlement administration; for debt recovery and collection; For customer retention.
4.2. For the protection of the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") interests, or those of the Customer: in order to protect the interests of the Customer and/or the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss"); in order to provide evidence for commercial transactions and other commercial communications (storage of e-mails, storage of submitted documents, etc.); based on contract performance; to prevent, limit and investigate unfair or illegal use of the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") brand, services, goods, or intentional disruption in the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") legitimate interests; for internal training or service quality assurance; in order to ensure the safety of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") and that of the Customer, to protect the life and health of the Customer and/or his representatives, and other rights of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") or of the Customer (making visual recordings), based on the legitimate interests of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") to protect the Customers, SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") employees and site visitors.
4.3. For the establishment, exercise and defense of rights of claim: to establish, exercise, defend and transfer rights of claim based on the performance of a contract or to take measures at the Customer's request before concluding a contract or to fulfill a legal obligation, or in order to exercise the right of claim in legitimate interests of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss").
4.4. For the fulfillment of legal obligations: to comply with applicable laws and international agreements, as well as to verify identity based on the performance of a contract, or to take pre-contractual steps at the Customer's request or to fulfill a legal obligation, or to protect the legal interests of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") in the legitimate interests of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss"), to ensure prudent risk management and company management.
4.5. Provision of information to public institutions: to provide information to state administrative institutions and subjects of operational activity in the cases and to the extent specified in legal acts.
4.6. For other specific purposes, about which the Customer will be informed at the time when he/she provides the relevant data to the company SIA "Jelgavas pakotājs rūpnīca Marss".
5. Basis of processing the personal data
The SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") processes the Customer personal data based on the following legal basis:
5.1. on the basis of the contract, to which the Customer and the company SIA "Jelgavas pakotājs rūpnīca Marss" are parties to: during the process of concluding and executing the contract and at the request of the Customer also before concluding the contract.
5.2. on the basis of the Customer's consent.
5.3. On the basis of regulatory enactments: to fulfill the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") binding national and international regulatory enactments.
5.4. to ensure vital interests: to ensure the physical and property safety of physical persons (including, but not limited to, the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") Customers and employees).
5.5. In the legitimate interests of the SELLER – SIA "Jelgavas pakotājs rūpnīca Marss": in order to ensure compliance with and fulfillment of the obligations existing between the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") and the Customer or the legitimate interests of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") arising from the concluded contract or the law stipulations. The SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") has the following legitimate interests (but not limited to):
1) provide the following services: packaging design development, consultation, sample demonstration;
2) sell the following goods: packaging, including but not limited to: boxes, containers, packaging elements, packaging materials, etc.
3) carry out commercial activity;
4) save and store Customer applications and submissions for the purchase of goods and provision of services, other applications and submissions, notes about them;
5) verify the identity of the Customer before concluding the contract and maintain up-to-date/correct personal data of the Customer;
6) ensure the fulfillment of the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") and Customer's obligations;
7) prevent unreasonable financial risks for your business;
8) take action to retain an existing Customer;
9) design and develop goods and services;
10) inform about changes in the order of service provision and the price list;
11) ensure the maintenance and operation of the facilities of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss");
12) prevent the act of a criminal offence;
13) apply to state administration and operational institutions and establishments, as well as to a court for the protection of our legal interests;
14) provide corporate governance, financial and business accounting;
15) ensure effective company management processes;
16) ensure the efficiency of service provision, sale and delivery of goods;
17) ensure and improve the quality of services;
18) administer payments;
19) administer outstanding payments;
20) inform the public about their activities.
6. Procedure for processing of the personal data
6.1. The SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") processes the Customer's data using modern technologies, taking into account the existing risks regarding the privacy of natural persons, and the reasonably available technical, organizational and financial resources at the disposal of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss").
7. Receivers of personal data
7.1. Personal data of Customers processed by SIA "Jelgavas pakotājs rūpnīca Marss" is not disclosed to third parties, except in cases where:
1) the data must be transferred to the relevant third party within the framework of the contract concluded with the Customer in order to perform a function necessary for the performance of the contract or delegated by law (for example, to a credit institution within the framework of settlements or to ensure the performance of services, for example, the delivery of an ORDER);
2) The Customer has given clear and unambiguous consent;
3) personal data must be transferred to the persons provided for in the regulatory enactments upon their justified request, in accordance with the procedures and to the extent specified in the legal enactments;
4) personal data must be transferred in cases defined by legislation for the protection of the legitimate interests of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss"), for example, when contacting legal service providers, debt collection companies, mediators, courts or other state institutions against a person who has violated the legal interests of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss").
8. Protection of Personal Data
8.1. The SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") protects the Customer's personal data using modern technologies, taking into account the existing risks regarding the privacy of natural persons, as well as the reasonably available technical, organizational, financial resources of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss"), including using the following personal data protection security measures:
1) Locked spaces and denial of access to unauthorized persons;
2) Using of firewall programs;
3) Use of intrusion protection and detection programs;
4) employee training on correct handling of Personal Data in respect to the employees of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss");
5) Other protective measures according to technical and financial possibilities.
9. Duration of personal data storage
9.1. The SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") stores and processes the Customer's personal data as long as at least one of the following criteria is met:
1) while the contract concluded with the Customer is valid;
2) while the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") has a legal obligation to store the data;
3) as long as the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") or the Customer can realize their legitimate interests (for example, submit objections or bring or take a lawsuit to court) according to the procedures specified in the regulatory acts;
4) while the Customer's consent to the relevant personal data processing is valid, unless there is another legal basis for data processing.
9.2. After all the deadlines for processing the Customer's personal data mentioned in clause 10.1 of the Policy expire, the Customer's personal data are permanently deleted.
9.3. The term and procedure for storing video recordings is determined in clause 7.3 of the present Policy.
10. Customer's rights
10.1. The Customer has the right to receive the information specified in the applicable legal acts in connection with the processing of his/her personal data.
10.2. According to the legislation, the Customer also has the following rights:
10.2.1. request information about the collection of the Customer's personal data;
10.2.2. request access to person's personal data from the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss"), as well as request the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") to supplement, correct or delete the data;
10.2.3. request restriction of personal data processing;
10.2.4. object to the processing (including the processing of personal data based on the legal (legitimate) interests of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss"));
10.2.5. request to stop the processing of personal data;
10.2.6. request portability of personal data if technically possible.
10.2.7. The customer can submit a request for the exercise of his/her rights:
1) in writing in person at the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") office, presenting an identity document (passport or ID card);
2) by the electronic communication means, by sending an e-mail to the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") e-mail address INFO@PAKO.LV. The relevant request must be signed with a secure electronic signature, but such a requirement is not mandatory for the Customer if sufficient information is available to the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss"), to make sure that the received e-mail with the request is from the Customer (for example, the e-mail is mentioned as contact information in the contract with the Customer).
10.4. Upon receipt of the Customer's request for the exercise of his/her rights, the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") verifies the Customer's identity, evaluates the request and executes it in accordance with regulatory enactments.
10.5. The SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") sends the response to the request to the Customer by mail to the contact address specified by the Customer in a registered letter or signed with a secure electronic signature and sent to the Customer's e-mail (basically taking into account the method of receiving the response specified by the Customer).
10.6. The SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") ensures compliance with data processing and protection requirements in accordance with regulatory enactments. In the event that the Customer has raised objections against the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss"), the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") shall take the necessary actions to resolve the Customer's objection. However, if this fails, the Customer has the right to apply to the relevant supervisory authority (in the Republic of Latvia it is the State Data Inspectorate [Datu valsts inspekcija]).
11. The Customer's consent to data processing and the procedure for its withdrawal
11.1. The Customer can give consent to the processing of personal data in person to the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") or by sending it to the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") e-mail address: info@pako.lv. When sending consent to the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") e-mail address specified above, the consent must be signed with a secure electronic signature, but such a requirement is not mandatory for the Customer if sufficient information is available to the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss"), to make sure that the received e-mail with the consent is from the Customer (for example, the e-mail is mentioned as contact information in the contract with the Customer)..
11.2. The Customer gives his/her consent to the processing of personal data by filling in the relevant fields on the online websites www.pako.lv and/or www.pakoshop.eu
11.3. The customer has the right to withdraw the consent given to the processing of his personal data at any time in person at the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") office or by sending to the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") e-mail address: INFO@PAKO.LV. When sending consent's withdrawal to the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") e-mail address specified above, the consent's withdrawal must be signed with a secure electronic signature, but such a requirement is not mandatory for the Customer if sufficient information is available to the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss"), to make sure that the received e-mail with the consent's withdrawal is from the Customer (for example, the e-mail is mentioned as contact information in the contract with the Customer)..
11.4. The company SIA "Jelgavas pakotājs rūpnīca Marss", upon receiving the aforementioned withdrawal of the Customer's consent, will no longer carry out further processing of the Customer's personal data, which is based on such consent, for the specific purpose.
11.5. In the event that the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") processed personal data on the basis of the Customer's consent during the period until the Customer submitted the relevant withdrawal of consent (during the period of validity of the consent), then such withdrawal does not affect the legality of the personal data processing carried out before receiving the withdrawal.
11.6. For the avoidance of doubt, it should be explained that the Customer's withdrawal of consent to the processing of personal data cannot stop the processing of the Customer's personal data, which the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") carries out on the basis of other legal grounds (for example, on the basis of a concluded contract).
12. Validity and amendments to the Privacy Policy
12.1. This Policy is available in the Office of the SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") and on the website www.pako.lv and www.pakshop.eu
12.2. The SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") is entitled to unilaterally amend this Policy at any time by notifying the Customers of the relevant amendments on the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") website, by post, by e-mail or in another way at the SELLER's (SIA "Jelgavas pakotājs rūpnīca Marss") discretion. The SELLER (SIA "Jelgavas pakotājs rūpnīca Marss") shall notify about the amendments made no later than 2 (two) weeks before the date of entry into force of the respective amendments.
Revision 22/01