I CONFIRM
Member of the board of SIA "DEUTSCH-LETTISCHE CONSULTINGAGENTUR".
Alexander Ulyanenko
Riga, February 2, 2024
1. Explanation of terms
Controller of personal data processing – SIA “Deutsch-Lettische Consultingagentur” (hereinafter referred to as Deutsch-Lettische Consultingagentur), reg . No.: 40103319598, legal address Riga, Rigondas gatve 3 – 6, LV-1067, websites: https://www.business-de.com, e-mail address: info@business-de.com
Data subject – a natural person who can be directly or indirectly identified.
Customer – any natural person (data subject) who uses, has used, or has expressed a desire to use any services provided by DEUTSCH-LETTISCHE CONSULTINGAGENTUR or is in any other way related to them or information about it has been provided to ensure the provision of the service.
Personal data – any information relating to an identified or identifiable natural person.
Data processing – any operation or set of operations performed with or without automated means on personal data or sets of personal data, such as data collection, registration, organization, structuring, storage, adaptation or transformation, retrieval, viewing, use, disclosure , by sending, distributing or otherwise making them available, as well as matching or combining, limiting, erasing or destroying the data.
Data processor – is a natural or legal person, public institution, agency or other body, which processes personal data on behalf of the controller.
Third party – a natural or legal person, public institution, agency or structure, which is not the data subject, manager, processor or person who is authorized to process personal data under the direct authority of the manager or processor.
Consent of the data subject - any freely given, specific, conscious and unambiguous indication of the wishes of the data subject, by which he gives his consent to the processing of his personal data in the form of a statement or a clearly affirmative action.
2. The purpose of the privacy policy
The purpose of this Policy is to provide information on how DEUTSCH-LETTISCHE CONSULTINGAGENTUR processes and protects personal data, ensuring that personal data is processed lawfully, in good faith and in a transparent manner for Data Subjects. This Policy applies to personal data, any processing of personal data and services provided to Customers.
3. Applicable regulatory acts
3.1 Regulation of the European Parliament and Council No. 2016/679 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);
3.2 Law on the processing of data of natural persons;
3.3 Other applicable laws and regulations in the field of privacy, personal data processing and services provided by DEUTSCH-LETTISCHE CONSULTINGAGENTUR.
4. Data processors
4.1. DEUTSCH-LETTISCHE CONSULTINGAGENTUR processes personal data to the extent and order as determined and permitted by the laws of the Republic of Latvia and the European Union. DEUTSCH-LETTISCHE CONSULTINGAGENTUR is also entitled to engage Personal Data Processors for the provision of its services in accordance with the regulatory framework. For more information on engaging with Personal Data Processors, contact the DEUTSCH-LETTISCHE CONSULTINGAGENTUR using the postal or e-mail address provided.
5. Personal data processed by DEUTSCH-LETTISCHE CONSULTINGAGENTUR
The categories of personal data processed by DEUTSCH-LETTISCHE CONSULTINGAGENTUR depend on the category of the data subject (employee, customer, business partner). In order to provide quality services to Customers, as well as to provide, maintain, protect and improve existing services, DEUTSCH-LETTISCHE CONSULTINGAGENTUR processes the following categories of personal data:
Categories of personal data
Examples
Identification data
name, surname, personal identification number, signature (including electronic one), identity document data (copy of passport or ID card), copy of proof of previous education, gender, level and type of previous education, personal photo, document certifying change of name or surname , choice of educational program
Personal contact information
Actual and declared address, phone number, email address, bank account number
Contract data
Customer contract number, customer registration date, status
Billing data
payment system account number, bank account number, invoice number, date, amount, invoice receipt method, payment date, debt amount, debt collection information
Obligation performance data
training history, billing data
Attendance data
data on each training participant about the classes attended
Training data
information about the progress of the trainees
Cookies
data on visits to the DEUTSCH-LETTISCHE CONSULTINGAGENTUR website
Photos and images
photographs for the production of educational program supporting documents, photographs from DEUTSCH-LETTISCHE CONSULTINGAGENTUR events, date of photo taking, personal photograph
Video data
Video from DEUTSCH-LETTISCHE CONSULTINGAGENTUR events, date of recording
Contact details
type, number, date, registrant, content, channel, delivery status of incoming/outgoing communication
The others
data that the Data Subjects themselves report to the DEUTSCH-LETTISCHE CONSULTINGAGENTUR
6. Legal basis for personal data processing
6.1. Conclusion and performance of the contract - in order for DEUTSCH-LETTISCHE CONSULTINGAGENTUR to be able to conclude and perform the contract with the Data Subject, it is necessary to process certain categories of personal data both before the conclusion of the contract and during the term of the already concluded contract. Applying for events announced by DEUTSCH-LETTISCHE CONSULTINGAGENTUR (training courses, seminars) or registration is considered as actions leading to the conclusion of the contract.
6.2. Fulfillment of a legal obligation – DEUTSCH-LETTISCHE CONSULTINGAGENTUR is obliged to process certain personal data in order to fulfill the requirements of regulatory acts, as well as to provide answers to legal requests for information from state and local government institutions, as well as for cooperation with state and local government institutions.
6.3. Legitimate interests of the Learning Center – in accordance with the interests of DEUTSCH-LETTISCHE CONSULTINGAGENTUR, which are based on the provision of quality services and timely support to the Client, DEUTSCH-LETTISCHE CONSULTINGAGENTUR has the right to process personal data to the extent that it is objectively necessary and sufficient for the purposes specified in this Policy. DEUTSCH-LETTISCHE CONSULTINGAGENTUR's legitimate (legitimate) interests include:
– perform economic activity;
– provide quality services;
– check the identity of the Client before concluding the contract;
– to ensure the fulfillment of contractual obligations;
– process Customer data by sending it to other DEUTSCH-LETTISCHE CONSULTINGAGENTUR cooperation partners to ensure quality service;
- save the Client's applications and submissions, including those made verbally, by calling the office, on the Internet websites;
– analyze the operation of the DEUTSCH-LETTISCHE CONSULTINGAGENTUR website, develop and implement its improvements;
– segment the Customer database for more efficient provision of services;
– develop and develop services;
- to carry out direct marketing, as a result of which new and/or individual DEUTSCH-LETTISCHE CONSULTINGAGENTUR service offers can be made to the Client, unless the regulatory enactments stipulate consent as mandatory; - advertise their services by sending commercial notices, unless the regulatory enactments stipulate consent as mandatory;
– to prevent criminal offences;
– provide DEUTSCH-LETTISCHE CONSULTINGAGENTUR management, financial accounting and analytics;
– to ensure effective Learning Center management processes;
– to increase the efficiency of service provision;
– to ensure and improve the quality of services;
– administer payments;
– apply to state administration and operational institutions and to the court for the protection of their legal interests;
- to inform the public about their activities.
6.4. Protection of vital interests – DEUTSCH-LETTISCHE CONSULTINGAGENTUR is entitled to process personal data in order to protect the vital interests of the Data Subject or another natural person, for example in case of a threat to health or life.
6.5. Consent of the Data Subject - any other processing of personal data not mentioned above is carried out solely based on the consent of the Data Subject. The data subject himself gives his consent to the collection and processing of personal data for certain purposes. The consent of the data subject is his free will and independent decision, which can be given at any time, thus allowing DEUTSCH-LETTISCHE CONSULTINGAGENTUR to process personal data for the specified purposes. The data subject's consent is binding if it is given orally or in writing. The data subject has the right to withdraw his previously given consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to withdrawal.
7. Purposes of personal data processing
7.1. for ensuring the learning process (customer registration, development of documents complying with the requirements of regulatory acts, production of documents certifying completion of the program).
7.1.1. within the adult non-formal education program:
• name and surname;
• personal code;
• a copy of the document certifying the previously acquired education (if applicable);
• a document certifying the identity of the person.
7.1.2. within the framework of the professional development and continuing education educational program:
• a copy of the previously acquired education document;
• a personal identity document.
• photo of persons
7.1.3. for the preparation and conclusion of the contract;
7.1.4. for customer service;
7.1.5. for consideration and processing of objections;
7.1.6. for settlement administration;
7.1.7. for debt recovery and collection;
7.1.8. for website maintenance and performance improvement;
7.1.9. for the development of new learning directions;
7.1.10. for the promotion and distribution of training services or for commercial purposes.
7.2. to promote the development of the industry and offer new services to Customers, i.e. see:
7.2.1. for creating new services and making offers about them;
7.2.2. for the purpose of market analysis and development of the business model, the statistical data of the Clients is processed;
7.3. to create and maintain DEUTSCH-LETTISCHE CONSULTINGAGENTUR's internal processes, ensure the circulation of documents and other internal processes (e.g. archiving of contracts and other documents) to the necessary and sufficient extent.
7.4. in order to provide the necessary information to the state administrative authorities and subjects of operational activity in the cases and to the extent specified in external regulatory acts.
7.5. to ensure the operation of the DEUTSCH-LETTISCHE CONSULTINGAGENTUR, including operational security.
7.6. For other specific purposes of which the Data Subject is informed at the time he provides the relevant data to DEUTSCH-LETTISCHE CONSULTINGAGENTUR.8. Rights of the data subject
8.1. Request correction of your personal data if it is inadequate, incomplete or incorrect.
8.2. Object to the processing of your personal data if the processing is based on legitimate interests, including objecting to personal data profiling.
8.2.1. profiling is any type of automated personal data processing, which manifests as the use of personal data for the purpose of evaluating specific personal aspects related to a natural person, in particular analyzing or predicting aspects related to the said natural person's personal wishes, interests, reliability, behavior, location or movement;
8.2.2. when processing Customer's personal data, DEUTSCH-LETTISCHE CONSULTINGAGENTUR may perform profiling in order to create and express individual offers. Automated individual decisions are made for business purposes only and will not create legal consequences for the Data Subject. The data subject has the right at any time to object to the adoption of an automated decision and not to be the subject of such a decision by informing the DEUTSCH-LETTISCHE CONSULTINGAGENTUR.
8.3. Request the deletion of your personal data, for example, if the personal data is processed on the basis of consent and the Customer has withdrawn his consent. This right does not apply if the Personal Data whose deletion is requested is processed also on the basis of another legal basis, such as a contract or the obligations arising from relevant regulatory enactments, or their preservation is determined by the requirements of the applicable regulatory enactments.
8.4. Limit the processing of your personal data in accordance with the applicable regulatory enactments, for example, when the DEUTSCH-LETTISCHE CONSULTINGAGENTUR evaluates whether the Data Subject has the right to delete his data.
8.5. To receive information on whether DEUTSCH-LETTISCHE CONSULTINGAGENTUR processes personal data and, if so, access to it.
8.6. Receive your personal data provided by the Data Subject to DEUTSCH-LETTISCHE CONSULTINGAGENTUR and processed on the basis of consent and contract performance in written form or in one of the more commonly used electronic formats and, if possible, transfer such data to another service provider (data portability).
8.7. The data subject has the right at any time to object to the profiling of his/her personal data or to refuse to receive commercial notices ( a commercial notice is sent to the Clients so that the Clients are always informed about new and/or services created directly for the Clients), informing the DEUTSCH-LETTISCHE CONSULTINGAGENTUR of this by sending an electronic request in writing to the specified e - postal address. The requested changes will take effect within three working days. Changes will not affect the legality of personal data processing prior to the Customer's objections and/or refusal specified in this paragraph.
8.8. Contact the DEUTSCH-LETTISCHE CONSULTINGAGENTUR or the institution supervising the processing of personal data (Data State Inspectorate, www.dvi.gov.lv) regarding questions about the processing of personal data.
9. Cookie Policy
9.1. Cookies are small data files that are important for the provision of certain website functions. Cookies allow websites to remember various settings such as language, font and other options that you have chosen when displaying web pages. This is why cookies are stored on your computer. This is how most major web pages and service providers work.
9.2. Using cookies, general user habits and website usage history are processed, problems and deficiencies in website operation are diagnosed, user behavior statistics are collected, and full and convenient use of website functionality is ensured.
9.3. Depending on the functions to be performed and the purpose of use, DEUTSCH-LETTISCHE CONSULTINGAGENTUR uses mandatory cookies, functional cookies, analytical cookies and targeting (advertising) cookies.
9.3.1. With functional cookies, the website remembers the settings chosen by the user and the choices made, so that the user can use the website more conveniently. These cookies are stored permanently on the user's device.
9.3.2. Analytical cookies collect information on how the user uses the website, identify the most frequently visited sections, including the content that the user chooses while browsing the website. The information is used for analysis purposes to find out what is of interest to website users and to improve the functionality of the website and make it more user-friendly. Analytical cookies only identify the user's device, but do not reveal the user's identity. In certain cases, some of the analytical cookies are managed by third parties - data processors (operators), such as Google Adwords , instead of the website owner, according to its instructions and only according to the specified purposes .
9.3.3. Target (advertising) cookies are used to collect information about the websites visited by the user and to offer Learning Center services of interest to a specific user or to address offers corresponding to the interest shown by a specific user. Generally, these cookies are placed by third parties, such as Google Adwords , with the permission of the website owner, according to the stated purposes . Target cookies are stored permanently on the user's terminal.
9.4. Cookies allow DEUTSCH-LETTISCHE CONSULTINGAGENTUR to keep track of website data flow and user interaction with the website - DEUTSCH-LETTISCHE CONSULTINGAGENTUR uses this data to analyze visitor behavior and improve the website.
9.5. DEUTSCH-LETTISCHE CONSULTINGAGENTUR uses cookies to improve the experience of using websites and homepages:
9.5.1. adapt the functionality of the website to the user's usage habits - including language, search requests, previously viewed content;
9.5.2. obtain statistical data on the flow of visitors to the page - number of visitors, time spent on the page, etc
9.6. Unless otherwise specified, cookies are stored until the activity for which they were collected is performed and then deleted.
9.7. When visiting the DEUTSCH-LETTISCHE CONSULTINGAGENTUR website, a window is displayed to the user with a message that the website uses cookies.
9.8. By closing this message window, the user confirms that he has familiarized himself with the information about cookies, the purposes of their use, cases when their information is transferred to a third party, and agrees to them. The legal basis for the use of cookies is the user's consent.
9.9. It is possible to restrict and delete cookies in the security settings of every web browser. However, it should be noted that you cannot refuse the use of mandatory and functional cookies, because without them it is impossible to ensure the full use of the website and homepage.
10. Duration of personal data storage
DEUTSCH-LETTISCHE CONSULTINGAGENTUR stores and processes personal data as long as at least one of the following criteria is met:
10.1. the contract concluded with the Data Subject is valid;
10.2. the period of storage of personal data is determined or follows from the regulatory enactments of the Republic of Latvia and the European Union;
10.3. it is necessary for the realization and protection of the Controller's legitimate interests;
10.4. the Data subject's consent to the relevant personal data processing is valid, if there is no other legal basis for data processing.
11. Protection of personal data
11.1. DEUTSCH-LETTISCHE CONSULTINGAGENTUR provides, constantly reviews and improves security measures to protect the Clients' personal data from unauthorized access, accidental loss, disclosure or destruction. To ensure this, DEUTSCH-LETTISCHE CONSULTINGAGENTUR applies modern technologies, technical and organizational requirements, i.e. see intrusion detection using firewalls.
11.2. Cooperation partners are not allowed to process personal data for their own purposes.
11.3. DEUTSCH-LETTISCHE CONSULTINGAGENTUR is not responsible for any unauthorized access to personal data or loss of personal data beyond DEUTSCH-LETTISCHE CONSULTINGAGENTUR's control.
12. Sharing of Personal Data
DEUTSCH-LETTISCHE CONSULTINGAGENTUR may share personal data with:
12.1. partners (e.g. State Education Development Agency, State Employment Agency, etc.) or institutions (Citizenship and Migration Affairs Administration, State Revenue Service, Riga Social Service of the Welfare Department of Riga City Council, State Education Information System, etc.) involved in providing services used by Customers;
12.2. debt collection companies, credit bureaus, debt history database holders or other debt recovery organizations;
12.3. assignees – in order to ensure effective cash flow management, the Learning Center has the right to assign the right of claim against the debtor or debtors.
12.2. DEUTSCH-LETTISCHE CONSULTINGAGENTUR is obliged to provide information about personal data to law enforcement authorities, courts or other state and local government institutions, if this results from regulatory enactments or the relevant institution's request for information;
13.3. DEUTSCH-LETTISCHE CONSULTINGAGENTUR will provide personal data only to the necessary and sufficient extent in accordance with the requirements of regulatory acts and the objective circumstances of the specific situation.
13.4. DEUTSCH-LETTISCHE CONSULTINGAGENTUR will issue certificates for training, specifying the name, surname, personal code, period, course, name of the educational program, only with the request of a learner specifying the purpose of the certificate.
By browsing the website, you accept the use of necessary cookies. You can also accept the use of other cookies.