- Conclusion, execution of contractual obligations, correspondence and supervision
Within the framework of the performed commercial activity, the Company needs to process the personal data of its cooperation partners, their employees, contact persons and representatives, in order to ensure preparation, conclusion, high-quality fulfilment and management of the cooperation (purchase, supply, service, author’s or contractor’s and other kind) agreement to comply with the requirements of regulatory enactments, as well as to implement the obligations and lawful interests of the Company attributable to the agreement (for example, to make sure about the economic safety of the cooperation partner and whether there is no relation with any of employees of the Company).
E-mail correspondence of the Company is supervised and in certain cases calls may be recorded by calling to phone numbers of the Company. Data processing does not take place with a purpose to regularly control the communication processes, but the data obtained as a result of processing may be used if the Company has reasonable suspicions on unethical or illegal activities. In such a case personal data may be transferred to the authorised employees of the Company, legal service providers as well as law enforcement authorities.
The Company obtains personal data mostly from the Cooperation Partner, when it provides to the Company, for example, its data or the date of its employee, contractor or official, when entering into the agreement or later during the course of fulfilment of the agreement. The Company obtains personal data from the Register of Enterprises of the Republic of Latvia by checking the information about the board members of the partner of the Company, as well as from state, municipal and other legal entities that provide personal data to the Company in accordance with regulatory enactments. Besides, the Company in certain cases may retrieve personal data from the e-mail surveillance system and/or from records of phone calls
Processed data
About cooperation partner (natural person): name, surname, personal identity number, position, address, phone connection number, e-mail address, current account number, signature, amount to be paid and grounds;
About the representative/authorised person of the cooperation partner: name, surname, personal identity number (or date of birth), position, information justifying representation, signature;
About contact person and/or employee of the cooperation partner: name, surname, position, phone connection number, e-mail address;
Other personal data in certain cases: e-mail correspondence content, phone call content;
Additional personal data the processing of which arises from fulfilment of the contract, such as author’s contracts – information about speciality of the author, experience, material of the presentation, video and audio record of the presentation; purchase agreements – information about card drivers of cooperation partners (buyers) – vehicle number and passport data at the issue of the product, in order to identify and prove to whom the product is issued.
Legal basis
Conclusion and fulfilment of the agreement with data subject (Article 6(1)(b) of the Regulation), if the agreement is concluded with the cooperation partner who is a natural person;
Fulfilment of the legal obligation (Article 6(1)(c) of the Regulation), for example fulfilment of requirements of the Accounting Law with regard to preparation and storage of source documents;
Provision of legitimate interests of the controller (Article 6(1)(f) of the Regulation), the Company has legitimate interest to ensure conclusion, fulfilment of agreements and cooperation within the framework of any agreement; to maintain evidence for protection of its legal interests about the transaction taken place; to process data for more convenient organization of work by using agreement management system; before conclusion of the agreement to make sure on the economic safety of the cooperation partner and whether there is no relation with any employee of the Company; to prevent or detect unethical or illegal activity and ensure evidence for investigation of any such activity.
Transfer to processor and / or third parties
1) To a personal data processor, who ensures data processing in the agreement management system;
2) Supervisory and law enforcement authorities if a reasonable request has been received in the written form or if the Company has a reason to protect its legitimate interests by turning to the law enforcement authorities
Duration of storage
As long as the contact information is updated or as long the agreement is in force, or until the time, when certain obligations are fulfilled (for example, when receiving a confirmation from the buyer about receipt of product, the information about the driver, to whom the product was issued for transportation, is deleted). If persona data are included in the agreement, they will stored during the whole period of validity of the agreement, as well as in accordance with the existing periods of limitation for bringing of claims (3 to 10 years) after expiry of the validity period, in order to save evidence for protection of their legal interests about the cooperation taken place in case of any claims, as well as for fulfilment of accounting requirements. In order to prove unethical or illegal activity, the acquired information may be processed until the moment of execution of legal interest.
- For identification of the representatives and related persons of cooperation partners and examination of business partners
We process personal data for the purposes of identification, study and monitoring of cooperation partners, in order to eliminate involvement of the Company in money laundering, financing of terrorism and mass destruction, violation, avoidance of the Law on International Sanctions and National Sanctions of the Republic of Latvia or attempt to avoid fulfilment of sanctions, as well as in order to ensure going concern of the operations of the Company, effective and timely management of reputation risks (for example, by avoiding freezing of payments and funds due to the risks of Sanctions of Money Laundering and Terrorism and Proliferation Financing, which has been identified by the credit institution, where the Company makes and receives payments). Within the framework of such processing We obtain necessary information and documentation (questionnaires, declarations, statements), implement examination of cooperation partners and related persons (owner, beneficial owner, official, board member), as well as perform monitoring by using solutions provided by third parties.
Processed data
Name, surname, personal identity number (if there is no such – date, month, year of birth, number of the personal identification documents and date of issue, country and authority of issue); nationality; country of habitual residence;
the form in which the control is implemented over the capital company (1. through a status in the legal entity (if the BO is the direct owner or directly controls the legal entity) – as a shareholder or stockholder; 2. as a separate person, who controls (if the beneficial owner is an indirect owner or indirectly controls the capital company) – on the basis of the authorisation agreement, on the basis of property rights (for example, if the beneficial owner is the owner of the member or shareholder of the capital company – legal entity), through legal arrangement as a founder, through a legal arrangement as an authorised person, through a legal arrangement as a manager or on the basis of business relations; 3. other);
Information about the person, through whom the control is implemented (for a natural person name, surname, personal identity number, if the person does not have a personal identity number – date, month and year of birth), other information obtained from completed questionnaires, declarations, statements or information search and as a result of monitoring by using the services offered by third parties
Legal basis
Data processing carried out in the public interest (Article 6(1)(e) of the Regulation and when processing personal data of special categories – Article 9(2)(g) of the Regulation).
Provision of the legitimate interests of the controller (Article 6(1)(f) of the Regulation), the Company has legitimate interest to ensure going concern of its operation, effective and timely management of reputation risks (for example, by preventing freezing of payments and funds due to the risks of Sanctions or Money Laundering and Terrorism and Proliferation Financing that would be identified by the credit institution, where the Company makes and receives payments)
Transfer to processor and / or third parties
Supervisory and tax authorities, law enforcement authorities – for performance of their functions in necessary scope; Auditors, financial and legal advisors, as well as other service providers – if it is necessary within the framework of the provided services; companies of Olpha Group – within the framework of provision of mutual services; providers of information systems and data bases (for example, providers of commercial registers and sanction supervision platforms, search service providers)
Duration of storage
Personal data collected for the purpose of customer identification and study will be stored during the whole validity period of transactions, as well as 5 (five) years after termination of legal relations
- For identification, instruction of employees of cooperation partners (service providers) at the place of performance of work
In certain cases, when the service to be provided by the cooperation partner includes fulfilment of the work of certain type in the territory managed by the Company, We will need to process the personal data of the performer of work, within the framework of Our legitimate interests and ensuring fulfilment of requirements of regulatory enactments in the field of environment and labour protection – in order to perform introductory instructions in labour protection, instructions at the place of work, target instructions, fire fighting instructions, instructions on environment protection, as well as give instructions for performance of dangerous work (fire hazards, under power lines, working with human lifts, etc.).
Processed data
For introduction with instructions: name, surname, personal identity number, position, company name, signature on becoming acquainted with the instruction;
For performance of assignments on dangerous work: name, surname, work to be performed, position, company name, signature, time/period of performance of works, supervisory period
Legal basis
Performance of a legal duty (Article 6(1)(c)) and relevant Cabinet Regulations (No. 749 “Regulations Regarding Training in Labour Protection Matters”, No. 238 “Fire Safety Regulations” etc.);
Provision of legitimate interests of a controller (Article 6(1)(f) of the Regulation) – to ensure fulfilment of the standard 14 001 ISO, in order all performers of work would be informed about the environment policy, aspects.
Transfer to processor and / or third parties
SLI, SP, SFRS as well as other supervisory and law enforcement authorities, if a reasonable request in writing is received
Duration of storage
Information about becoming acquainted with instructions: 3 years;
Assignment data: 3 days after completion of works.