The controller of personal data processing is “Razosanas tehnologijas” LTD (SIA “Ražošanas tehnologijas”) (hereinafter referred to as RT), unified registration No. 40103229453, legal and office address: 144 Brivibas Street, Riga, LV-1012.
RT’s contact information on issues related to personal data processing is: [email protected]. Using this contact information or addressing the RT’s office at the legal address, one can ask a question about the processing of personal data. A request for the exercise of personal rights may be made in accordance with the procedures set out herein.
Personal data is any information about an identified or identifiable natural person – RT’s customers, cooperation partners or their employees, job candidates such as their name, surname, ID number, address of the place of residence, personal telephone number, personal e-mail, occupation, services received, billing information, telephone, electronic communications information and other information relating to a natural person.
natural persons – customers and other service users (including potential, former and current), as well as third parties, who receive or transfer to RT any information (including contact persons, payers, etc.) in connection with the provision of services to a natural person (customer, user);
visitors at RT’s office and other premises, including those for whom video surveillance is performed;
visitors of RT’s maintained homepage: www.greenok.lv and mobile application (hereinafter referred to as the Customers).
RT takes care of the Customers’ privacy and personal data protection, observes the Customers’ right to the lawfulness of personal data processing in accordance with the applicable legislation – the laws of the Republic of Latvia and subordinate legal acts, the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the Regulation) and other applicable legal acts in the field of privacy and data processing.
RT processes personal data for the following purposes:
1. For the provision of services and sale of goods:
- customer identification;
- preparation and entering into a contract;
- delivery of goods (fulfilment of contractual obligations);
- ensuring/maintaining the operation of services;
- improvement of goods and services, development of new goods and services;
- promotion of the use of the service;
- advertising and distribution of services i.e. for commercial purposes;
- customer service;
- examination and processing of claims;
- customer retention, loyalty building, satisfaction measurements;
- settlement administration;
- debt regaining and recovery;
- maintenance and improvement of operations of the homepages and mobile applications.
2. For business planning and analytics:
- statistics and business analysis;
- planning and accounting;
- measuring of efficiency;
- data quality assurance;
- performance of market and public opinion research;
- preparation of reports;
- conducting customer surveys;
- within the framework of risk management activities.
3. For the provision of information to public administration institutions and subjects of operational activities in the cases and to the extent specified in external regulatory enactments.
4. For other specific purposes about which the Customer is informed at the moment they provide the respective data to RT.
RTl processes the Customer’s personal data on the grounds of the following legal bases:
- for concluding and performing a contract – to enter into a contract upon the Customer’s application and ensure its performance;
- for the fulfilment of regulatory enactments – in order to fulfil an obligation specified in the external regulatory enactments binding on RT;
- in accordance with the consent of the Customer as the data subject;
- in the legal (legitimate) interests – to realize the legitimate (legal) interests of RT arising from the obligations existing between RT and the Customer or the concluded contract, or the law.
RT’s legal (legitimate) interests are:
- to carry out commercial activities;
- to offer quality and tested Humate GreenOK products;
- to verify the Customer’s identity before concluding a contract;
- to ensure the fulfilment of contractual obligations;
- to prevent unreasonable financial risks for their commercial activities (incl., perform credit risk assessment before the sale of goods and services and during the performance of the contract);
- to keep the Customer’s requests and applications regarding the purchase of goods and provision of services, other requests and applications, notes on them, including those made orally, by calling and on Internet websites;
- to analyse the operation of RT’s homepage, Internet websites and mobile applications, to develop and implement their improvements;
- to administer the Customer’s account on RT’s homepages, Internet websites and mobile applications;
- to perform actions for Customer retention;
- to segment the customer database for more efficient provision of services;
- to design and develop goods and services;
- to advertise own goods and services by sending commercial newsletters;
- to send other reports on the progress of the contract performance and events relevant to the performance of the contract, as well as to conduct Customer surveys on the goods and services and the experience of their use;
- to prevent fraud;
- to provide corporate governance, financial and business accounting and analytics;
- to ensure efficient company management processes;
- to ensure the efficiency of the provision of services and the sale and delivery of goods;
- to ensure and improve the quality of services;
- to administer payments;
- to administer outstanding payments;
- to apply to public administration and operational activities institutions and to the court for the protection of their legal interests;
- to inform the public about their activities.
RT processes the Customer’s data using modern technologies, taking into account the existing privacy risks and RT’s reasonably available organizational, financial and technical resources.
RT may make automated decisions regarding the Customer. The Customer is informed about such RT’s activities separately in accordance with the regulatory enactments. The Customer may object to automated decision making in accordance with the law, however, being aware that in certain cases this may restrict the Customer’s right to use certain opportunities potentially available to them (for example to receive commercial offers).
In order to ensure the quality and operative fulfilment of the obligations under the contract concluded with the Customer, RT may authorize RT group companies, their cooperation partners to perform certain activities in delivery of goods or provision of services, such as performance of delivery of goods, invoicing and the like. If in performing these tasks RT group companies or cooperation partners process the Customer’s personal data held by RT, the respective RT group companies or cooperation partners are considered to be RT data processors and RT has the right to transfer to RT group companies and cooperation partners data to the extent necessary for the performance of those activities.
RT cooperation partners and RT group companies (as personal data processor) will ensure compliance with personal data processing and protection requirements in accordance with RT’s requirements and legal acts, and will not use personal data for purposes other than fulfilling contractual obligations with the Customer on behalf of RT.
RT protects the Customer’s data using modern technologies, taking into account existing privacy risks and RT’s reasonably available organizational, financial and technical resources, including the following security measures:
- Pseudonymization of data;
- Intrusion protection and detection software;
- Other protection measures in accordance with current technical development possibilities.
RT does not disclose to third parties the Customer’s personal data or any information obtained during the provision of services and the validity of the contract, except for:
- if the data must be transferred to the relevant third party within the framework of the concluded contract in order to perform any function necessary for the performance of the contract or delegated by law (for example to the bank within the framework of settlement or delivery service),
- in accordance with the Customer’s explicit and unambiguous consent;
- to the persons provided for in external regulatory enactments upon their justified request, in accordance with the procedures and to the extent specified in external regulatory enactments;
- in the cases specified in external regulatory enactments for the protection of the legitimate interests of RT, for example, by applying to a court or other governmental institutions against a person, who has infringed the legitimate interests of RT.
RT’s personal data cannot be accessed by developers or service providers in third countries (i.e. countries outside the European Union and the European Economic Area) (within the meaning of the Regulation – transfer to third countries) as a data processor (operator).
RT stores and processes the Customer’s personal data as long as at least one of the following criteria exists:
- only as long as the contract concluded with the Customer is valid;
- as long as RT or the Customer may realize their legitimate interests in accordance with the procedures specified in external regulatory enactments (for example to submit objections or bring a claim to or maintain in court);
- as long as one of the parties has a legal obligation to retain the data;
- as long as the Customer’s consent to the relevant processing of personal data is valid, if there is no other legal basis for data processing.
When the above conditions expire, the Customer’s personal data are deleted.
The Customer has the right to receive the information specified in the regulatory enactments in connection with the processing of their data, to verify the accuracy of their data and to correct them.
In accordance with the regulatory enactments the Customer also has the right to request RT the access to their personal data, as well as to request RT to supplement, correct or delete them, or restrict processing in relation to the Customer, or the right to object to processing (including processing of personal data performed on the bases of the legal (legitimate) interests of RT), as well as the right to data portability. This right shall be exercised insofar as the processing of data does not result from the obligations of RT imposed on them by the regulatory enactments in force and which are performed in the public interest.
The Customer may submit a request for the exercise of their rights:
- in writing in person at the RT’s office, presenting an identity document;
- while in accordance with the procedures specified in external regulatory enactments, RT or the Customer may realize their legitimate interests (for example to submit objections or bring a claim to or maintain in court);
- in the form of electronic mail, signing with a secure electronic signature;
Upon receipt of the Customer’s request for the exercise of their rights, RT verifies the Customer’s identity, evaluates the request and executes it in accordance with the egulatory enactments.
RT shall send the response to the Customer by post to the contact address specified by them in a registered letter, taking into account, if possible, the method of receiving the response specified by the Customer.
RT ensures the fulfilment of data processing and protection requirements in accordance with the regulatory enactments and in case of the Customer’s objections performs useful actions to resolve the objection. However, if this fails, the Customer has the right to apply to the supervisory authority – the Data State Inspectorate.
The Customer may give consent to the processing of personal data, the legal basis of which is the consent, on RT’s service web portals/applications, RT’s and other Internet websites (for example loyalty programs and newsletter registration forms) or in person at the RT’s office/store.
The Customer has the right to withdraw the consent for data processing at any time in the same way as it was given or by sending a relevant notice to [email protected] and in that case further data processing based on the previously given consent for the specific purpose will not be performed in the future.
Withdrawal of the consent does not affect data processing performed at the time, when the Customer’s consent was valid.
Withdrawal of the consent may not suspend the processing of data on other legal grounds.
RT communicates with the Customer using the contact information provided by the Customer (phone number, e-mail address, postal address, as well as using text message notifications from the office).
Communication on the fulfilment of service contractual obligations is performed by RT on the basis of the concluded contract (for example, coordination of delivery of goods or performance of services, information on invoices, planned works, changes in services etc.).
Communication on commercial notifications about RT and/or third party services and other notifications not related to the direct provision of the agreed services (for example customer surveys) shall be performed by RT in accordance with the provisions of external regulatory enactments or in accordance with the Customer’s consent.
The Customer may provide the consent to the receipt of commercial notifications from RT and/or their cooperation partners on RT and other websites (for example, newsletter subscription forms).
The Customer’s consent to receive commercial notifications is valid until withdrawn (also after the termination of the service contract). The Customer may at any time refuse any further commercial notifications in one of the following ways:
- by sending an e-mail to [email protected];
- in person at the RT’s office;
- using the automated option provided in the commercial notification to opt out of receiving further notifications by clicking on the opt-out message at the end of the relevant commercial notification (e-mail).
RT terminates the sending of commercial notifications as soon as the Customer’s request to withdraw consent to commercial notifications is processed.
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Mandatory cookies are required for the user to freely visit and browse the website and use the features it offers, including obtaining information about the services and purchasing them. These cookies identify the user’s device, but they neither reveal the user’s identity, nor gather or collect information. Without these cookies the website will not be able to function properly, for example, to provide the user with the necessary information, to provide the requested services in the e-shop. These cookies are stored on the user’s device until the web browser is closed.
Functional cookies remember the settings and choices made by the user to make the site more user-friendly. These cookies are stored on the user’s device at all times.
Analytical cookies collect information about how the user uses the website, find the most frequently visited sections, including the content that the user selects, while browsing the website. The information is used for analytical purposes to find out what interests the users of the site, and be able to improve the functionality of the site, make it more user-friendly. Analytical cookies only identify the user’s device, but do not reveal the user’s identity. In some cases some of the analytical cookies are managed by third-party data processors (operators), such as Google Adwords, on behalf of the site owner in accordance with their instructions and only for the specified purposes.
Target (advertising) cookies are used to collect information about the websites visited by the user and to offer our or our partners’ services that are of particular interest to a particular user or to address offers that are of interest to the particular user. These cookies are usually placed by third parties, such as Google Adwords, with the permission of the website owner. Target cookies are stored permanently on the user’s terminal.
- ensure the functionality of the homepage;
- customize the functionality of the homepage to the user’s usage habits – including language, search queries, previously viewed content;
- obtain statistics on the number of visitors to the page, the time spent on the page etc.;
- user authentication;
- in case the user is a customer of RT services to display customized offers.
Unless otherwise stated, cookies are stored until the action for which they were collected is completed and afterwards are deleted.
Cookie information is not processed outside the European Union and the EEA.
It is possible to restrict and delete cookies in the security settings of any web browser. However, it should be noted that the use of mandatory and functional cookies cannot be waived since without them it is impossible to ensure the full use of the website and the homepage.
For the best user experience and proper functioning of the website, we recommend to store cookies.