1. Terms used:
DATA PROCESSOR - a natural or legal person, public authority, agency or other body that processes PERSONAL DATA on behalf of the SCHOOL.
DATA PROCESSING - any act or set of acts performed with or without automated means on PERSONAL DATA or sets of PERSONAL DATA, such as collecting, recording, organizing, structuring, storing, adapting or modifying, retrieving, viewing, using, disclosing, transmitting, disseminating or otherwise making available, matching or combining, restricting, erasing or destroying data.
DATA SUBJECT CONSENT - any freely given, specific, informed and unambiguous indication of the DATA SUBJECT's wishes by which he or she, by statement or express affirmative action, consents to the processing of his or her PERSONAL DATA.
DATA SUBJECT - a natural person who can be identified, directly or indirectly.
CLIENT - any natural person (DATA SUBJECT) who uses, has used, or has expressed a wish to use any of the services provided by the SCHOOL or is in any other way connected with them or has been provided with information about them in order to enable the provision of the service.
PERSONAL DATA - any information relating to an identified or identifiable natural person.
PERSONAL DATA PROCESSING PROVIDER - Eriva Ltd (hereinafter referred to as the "SCHOOL"), reg. No.: 40003941437, registered office: Skultes iela 50/15, Skulte, Mārupes novads, LV-2108, website: www.eriva.lv, www.pilotuskola.lv, e-mail address: info@eriva.lv
THIRD PARTY - a natural or legal person, public authority, agency or body other than the DATA SUBJECT, controller, processor or a person who is authorised to process PERSONAL DATA under the direct authority of the SCHOOL or processor.
SCHOOL - SIA "Eriva", Reg. No. 40003941437.
2. Purpose of the Privacy Policy.
The purpose of this Privacy Policy (the "Policy") is to provide information about how the SCHOOL collects, processes, stores, shares, erases and protects CLIENT PERSONAL DATA, thereby ensuring that CLIENT PERSONAL DATA is processed lawfully, fairly and in a manner that is transparent to CLIENTS. The Policy applies to CUSTOMER PERSONAL DATA, any processing of natural PERSONAL DATA and the services provided to CUSTOMERS.
3. Applicable Law.
The SCHOOL is concerned with the privacy and protection of CLIENT'S PERSONAL DATA, and respects CLIENT'S right to lawful processing of PERSONAL DATA in accordance with applicable law:
3.1. regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of PERSONAL DATA and on the free movement of such data (27 April 2016);
3.2. the Personal Data Processing Act;
3.3. other applicable legislation in the area of privacy, DATA PROCESSING and the services provided by the SCHOOL.
4. PERSONAL DATA PROCESSOR.
The SCHOOL shall process CLIENTS' PERSONAL DATA to the extent and in the manner required and permitted by the laws and regulations of the Republic of Latvia and the European Union. The SCHOOL shall be entitled to engage the services of PERSONAL DATA PROCESSORS for the provision of its services in accordance with the applicable laws and regulations. For further information about the Personal Data Processors engaged, please contact the SCHOOL through the contact channels indicated.
5. What PERSONAL DATA does the SCHOOL process?
The categories of PERSONAL DATA processed by the SCHOOL depend on the services provided to CLIENTS. In order to provide the CLIENT with quality services and to provide, maintain, protect and improve existing services, the SCHOOL processes data collected from the provision of services:
5.1. personal identification data - name, surname, personal identification number, signature (also electronic), identity document data (copy of passport or ID card), copy of proof of previous education, etc;
5.2. contact details of the person - address, telephone number, e-mail address;
5.3. CLIENT details - CLIENT contract number, CLIENT registration date, status;
5.4. billing details - billing system account number, bank account number, invoice number, date, amount, method of invoice receipt, date of payment, amount owed, debt recovery information;
5.5. data proving the fulfillment of the SCHOOL's obligations towards the CLIENT - training history, billing data;
5.6. attendance data - data for each training participant on the classes attended;
5.7. training data - information on the performance of trainees;
5.8. cookies (web browsing data) - data about visits to the SCHOOL's website;
5.9. photographs and images - photographs for the production of educational documents, photographs of events, date of photo;
5.10. video data - videos from events, video surveillance in the SCHOOL, date of recording;
5.11. communication data - type of communication received/delivered, number, date, registrant, content, channel, delivery status;
5.12. other data - data which the CLIENT communicates to the SCHOOL.
6. The legal basis for the processing of customer personal data.
6.1. Conclusion and performance of a contract - in order to conclude and perform a contract with a CLIENT and to provide services of high quality, the SCHOOL must collect and process certain PERSONAL DATA which is collected before or during the conclusion of a contract. The CLIENT's registration or enrolment in events (training courses, seminars) announced by the SCHOOL shall be considered as a mutually concluded contract.
6.2. Compliance with legal obligations - the SCHOOL is obliged to process certain PERSONAL DATA in order to comply with the requirements of laws and regulations, as well as to respond to lawful requests from the state and local government.
6.3. Legitimate (lawful) interests of the SCHOOL - in the interests of the SCHOOL, which are based on providing quality services and timely support to the CLIENT, the SCHOOL has the right to process the CLIENT'S PERSONAL DATA to the extent objectively necessary and sufficient for the purposes set out in this Policy. The legitimate interests of the SCHOOL are:
6.3.1. to carry out business activities;
6.3.2. to provide quality services;
6.3.3. to verify the identity of the CLIENT before entering into a contract;
6.3.4. to ensure the fulfilment of the contractual obligations;
6.3.5. to process the CLIENT's data by transferring them to other partners of the SCHOOL for the provision of quality service;
6.3.6. to save the CLIENT's applications and submissions, notes on them, including those made orally, by calling the office, on the websites;
6.3.7. analyse the functioning of the SCHOOL's website, develop and implement improvements;
6.3.8. segment the CUSTOMER database for more efficient service delivery;
6.3.9. design and develop services;
6.3.10. to carry out direct marketing resulting in new and/or individual offers of the SCHOOL's services to the CLIENT, unless consent is required by law or regulation;
6.3.11. advertise its services by sending commercial communications to CLIENTS, unless the laws and regulations make consent mandatory;
6.3.12. prevent criminal offences;
6.3.13. to ensure the management, financial records and analytics of the SCHOOL;
6.3.14. ensure effective governance processes of the SCHOOL;
6.3.15. enhance the efficiency of service delivery;
6.3.16. ensure and improve the quality of services;
6.3.17. administer payments;
6.3.18. to apply to public administration and operational bodies and to the courts for the protection of their legal interests;
6.3.19. inform the public about its activities.
6.4. CLIENT Consent - The CLIENT, as the SUBJECT of the PERSONAL DATA, gives his/her own consent to the collection and processing of PERSONAL DATA for certain purposes. The CLIENT's consent is his/her free will and independent decision, which may be given at any time, thereby allowing the SCHOOL to process the PERSONAL DATA for the stated purposes. The CLIENT's consent shall be binding upon him if it is given orally (during a telephone conversation after the CLIENT has been identified) or in writing by sending an email. The CLIENT has the right to withdraw his/her prior consent at any time through the specified channels of communication with the SCHOOL. The withdrawal of consent shall not affect the lawfulness of the processing based on the consent prior to the withdrawal.
6.5. Protection of Vital Interests - The SCHOOL shall be entitled to process PERSONAL DATA in order to protect the vital interests of the CLIENT or another natural person, such as to prevent a threat to the health or life of the CLIENT or THIRD PARTIES during training.
7. Purposes of the processing of customer personal data.
7.1. In order to provide a quality service, the SCHOOL processes PERSONAL DATA for the following purposes:
7.1.1. for the provision of the educational process (registration of the CLIENT, elaboration of documents complying with the requirements of the Cabinet of Ministers' Regulations, production of documents confirming the completion of programmes, etc.): name, surname, personal identification number, proof of identity, proof of education;
7.1.2. for the preparation and conclusion of the contract;
7.1.3. for the purpose of servicing CLIENTS;
7.1.4. for the consideration and processing of objections;
7.1.5. administration of settlements;
7.1.6. debt recovery and collection;
7.1.7. website maintenance and performance improvement;
7.1.8. development of new training courses;
7.1.9. for commercial purposes.
7.2. The SCHOOL processes PERSONAL DATA in order to promote the development of the sector and to offer new services to CLIENTS, including:
7.2.1. for the development of new services and for the expression of service offers;
7.2.2. for market analysis and business model development, statistical DATA PROCESSING OF CLIENTS OF THE SCHOOL.
7.3. the SCHOOL processes PERSONAL DATA in order to establish and maintain the SCHOOL's internal processes, to ensure the circulation of documents and other internal processes (e.g. archiving of contracts and other documents) to the extent necessary and sufficient for this purpose.
7.4. to provide information to state administration authorities and subjects of operational activity in the cases and to the extent specified in external normative acts.
7.5. for the purpose of ensuring the School's activities, including security.
7.6. for other specific purposes of which the DATA SUBJECT is informed at the time of providing the relevant data to the SCHOOL.
8. Rights of the CLIENT as DATA SUBJECT.
The CLIENT (DATA SUBJECT) shall have the rights regarding the processing of his/her data classified as PERSONAL DATA in accordance with the applicable laws and regulations. These rights are generally as follows:
8.1. to request the rectification of their PERSONAL DATA if it is inadequate, incomplete or incorrect;
8.2. object to the PROCESSING of your PERSONAL DATA where the processing is based on legitimate interests, including objecting to profiling of PERSONAL DATA (profiling is any form of automated PROCESSING of PERSONAL DATA consisting in the use of PERSONAL DATA to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person's personal preferences, interests, reliability, behaviour, location or movements):
8.2.1. when processing CUSTOMER PERSONAL DATA, the SCHOOL may carry out profiling in order to design and make individual offers. Automated individual decisions are made for business purposes only and will not have legal consequences for the CLIENT. The CLIENT has the right at any time to object to an automated decision and not to be the subject of such a decision by informing the SCHOOL.
8.3. request the erasure of his/her PERSONAL DATA, for example if the PERSONAL DATA is processed on the basis of consent and the CLIENT has withdrawn his/her consent. This right shall not apply if the PERSONAL DATA whose erasure is requested is also processed on the basis of another legal basis, such as a contract or obligations arising from the relevant laws or regulations, or its retention is required by the applicable laws or regulations;
8.4. restrict the processing of their PERSONAL DATA in accordance with applicable laws and regulations, for example, while the SCHOOL is assessing whether the CLIENT has the right to have their data erased;
8.5. to be informed whether the SCHOOL processes the CLIENT'S PERSONAL DATA and, if it does, to have access to it;
8.6. to receive their PERSONAL DATA provided by the CLIENT to the SCHOOL and processed on the basis of consent and contractual performance in written form or in one of the commonly used electronic formats and, where possible, to transfer such data to another service provider (data portability);
8.7. CLIENTS have the right to object at any time to the profiling of their PERSONAL DATA or to opt-out of receiving commercial communications by informing the SCHOOL in writing by sending an electronic request to the SCHOOL's email address. The notified changes will take effect within three working days. The changes will not affect the lawfulness of the PERSONAL DATA PROCESSING prior to the CLIENT's objection and/or refusal as specified in this paragraph;
8.8. contact the SCHOOL or the authority supervising the processing of PERSONAL DATA (the State Data Inspectorate, www.dvi.gov.lv) with questions about the processing of PERSONAL DATA.
9. Terms of use and processing of cookies.
9.1. Cookies are small data files that are important for the provision of certain functions on websites. Cookies allow websites to remember various settings such as language, font and other options you have chosen when displaying web pages. Cookies are therefore stored on your computer. This is how most major websites and service providers work.
9.2. Cookies are used to process general user habits and site usage history, diagnose problems and gaps in the site, collect statistics on user habits, and ensure that the site functionality is fully and conveniently used.
9.3. Depending on the functions to be performed and the purpose of use, the SCHOOL uses mandatory cookies, functional cookies, analytical cookies and targeting (advertising) cookies.
9.3.1 With functional cookies, the website remembers the settings and choices made by the user in order to allow the user to use the website more easily. These cookies are stored permanently on the user's device;
9.3.2 Analytical cookies collect information about how the user uses the website, identifying the most frequently visited sections, including the content that the user has selected when browsing the website. The information is used for analytical purposes, to find out what is of interest to users of the website 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 some cases, some of the analytical cookies are managed by THIRD PARTY data processors (operators), such as Google Adwords, on behalf of the website owner, in accordance with the website owner's instructions and only for the purposes indicated;
9.3.3. Targeting (advertising) cookies are used to collect information about the websites visited by the user and to offer the services of the SCHOOL that are of direct interest to a specific user or to target offers that are relevant to the interest expressed by a specific user. These cookies are usually placed by THIRD PARTIES, such as Google Adwords, with the permission of the website owner, according to the purposes indicated. Targeting cookies are stored permanently on the user's terminal equipment.
9.4. Cookies allow the SCHOOL to track website traffic and user interaction with the website - the SCHOOL uses this data to analyse visitor behaviour and improve the website.
9.5. The SCHOOL uses cookies to improve the user experience on its websites and webpages:
9.5.1. tailor the functionality of the website to the user's usage habits - including language, search queries, previously viewed content;
9.5.2. to obtain statistical data on the website traffic - number of visitors, time spent on the website, etc.
9.6. Unless otherwise stated, cookies are stored until the performance of the action for which they were collected. They are then deleted.
9.7. When visiting the SCHOOL's website, the user is presented with a window with a message stating that cookies are used on the website.
9.8. By closing this message window, the user confirms that he/she has read the information on cookies, the purposes for which they are used, the cases in which their information is passed on to a THIRD PARTY and accepts them. The legal basis for the use of cookies is the user's consent.
9.9. The security settings of each web browser allow for the restriction and deletion of cookies. However, it should be noted that the use of mandatory and functional cookies cannot be refused, as without them the full use of the website and the website cannot be ensured.
10. the SCHOOL obtains the CLIENT'S PERSONAL DATA when the CLIENT:
10.1. registers for the training programmes offered by the SCHOOL;
10.2. attends training offered by the SCHOOL;
10.3. visits or browses the SCHOOL's websites www.eriva.lv;
10.4. asks the SCHOOL for further information about the training or contacts it in connection with a complaint or request for information identifying the CLIENT;
10.5. participates in surveys;
10.6. photographs and/or films training and events organised by the SCHOOL;
10.7. is filmed by CCTV equipment in the SCHOOL and/or the area in which it is located;
10.8. the SCHOOL may in certain circumstances process CLIENT PERSONAL DATA received from THIRD PARTIES, for example, a company providing data about employees to be trained.
11. Duration of storage of PERSONAL DATA.
The SCHOOL shall retain and process CLIENT PERSONAL DATA for as long as at least one of the following criteria exists:
11.1. for as long as the contract with the CLIENT is valid;
11.2. the retention period of the Personal Data is established by or results from the laws and regulations of the Republic of Latvia and the European Union;
11.3. to the extent necessary for the exercise and protection of the legitimate interests of the SCHOOL;
11.4. as long as the DATA SUBJECT's consent to the relevant PERSONAL DATA PROCESSING is valid, unless there is another lawful basis for the PERSONAL DATA PROCESSING.
12. PROTECTION OF CUSTOMER'S PERSONAL DATA.
12.1. The SCHOOL shall provide, keep under review and improve safeguards to protect CLIENT PERSONAL DATA from unauthorised access, accidental loss, disclosure or destruction. To ensure this, the SCHOOL applies modern technology, technical and organisational requirements, including the use of firewalls, intrusion detection, etc.
12.2. The SCHOOL shall thoroughly examine all service providers that process CLIENTS' PERSONAL DATA on its behalf and on its behalf, as well as assess whether the partners (processors of PERSONAL DATA) apply appropriate security measures to ensure that the processing of CLIENTS' PERSONAL DATA is carried out in accordance with the SCHOOL's delegation and the requirements of the laws and regulations. Affiliates are not permitted to process CLIENT PERSONAL DATA for their own purposes.
12.3. The SCHOOL shall not be liable for any unauthorised access to and/or loss of PERSONAL DATA where this is beyond its control, for example due to the fault and/or negligence of the CLIENT.
13. Sharing of CLIENT'S PERSONAL DATA.
13.1. In order to provide services to CLIENTS, the SCHOOL may share CLIENT PERSONAL DATA with:
13.1.1. partners or institutions involved in the provision of the services used by CLIENTS;
13.1.2. debt collection companies, credit reference bureaus, debt history database holders or other debt collection organisations;
13.1.3. to Assignors - in order to ensure efficient cash flow management, the COLLEGE shall have the right to assign its claim against the debtor.
13.2. The SCHOOL is obliged to provide information on PERSONAL DATA to law enforcement authorities, court or other state and municipal authorities, if it results from the laws and regulations or information request of the relevant authority.
13.3. The SCHOOL shall provide the PERSONAL DATA of CLIENTS only to the extent necessary and sufficient, in accordance with the requirements of laws and regulations and the objective circumstances of the particular situation.
