Privacy Policy for the website www.zobudakteris.lv

SIA “HONESTUM SERVICES” Reg. No. 40003415675 Address: Bruņinieku iela 63, Latgale Suburb, Riga, LV-1011, Latvia

1. Introduction

SIA “HONESTUM SERVICES” (hereinafter – the Controller) processes personal data obtained from the data subject – a user of the website www.zobudakteris.lv (hereinafter – the User) on the website www.zobudakteris.lv (hereinafter – the Website).

The Controller cares about the User’s privacy and the protection of personal data, and respects the User’s rights to lawful processing of personal data in accordance with applicable legislation – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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), as well as other applicable legislation in the field of privacy and data processing.

In light of the above, the Controller has drawn up this privacy policy in order to provide the User with the information required by the Regulation.

This privacy policy applies to data processing regardless of the form and/or environment in which the User provides personal data (on the Website, on paper, in person, or by telephone).

The Controller reserves the right to change these terms at any time. It is the Website visitor’s responsibility to check the Website’s content periodically to stay informed of any changes to the terms.

2. Identity and contact details of the Controller

The Controller is SIA “HONESTUM SERVICES”, Reg. No. 40003415675. The Controller’s address is Bruņinieku 63-1, Riga; website – www.zobudakteris.lv; email – kabinets.br63@gmail.com; phone – +371 25 667 447.

3. Purposes of personal data processing and the legal basis for processing

If the User submits personal data to the Controller — by phone, via the Website’s contact forms, by email, or by other means of correspondence — we store and use this information to perform or conclude the relevant service agreement, including: identifying the client; preparing and concluding the agreement; providing services (performing contractual obligations); customer service; reviewing and handling complaints; building customer loyalty; administering payments and settlements; debt recovery and collection; proving facts, maintaining and improving the website; business planning and analytics; and planning and record-keeping. We will also process this data to provide information to public authorities and operational bodies in the cases and to the extent set out in external legislation.

The legal basis for data processing is the conclusion and performance of a contract, compliance with legal obligations, the consent of the Client (the data subject), and our legitimate interests (for example, verifying the Client’s identity before concluding a contract; ensuring performance of contractual obligations; analysing use of the website; ensuring the efficiency of service delivery, etc.).

4. Categories of personal data

Categories of personal data — name, surname, personal identity number, email or postal address, IP address, phone number, the content of a message or letter, etc.

5. Categories of recipients of personal data

Data is disclosed to those employees of the Controller who need it to perform their direct duties in order to perform or conclude the relevant service agreement.

When obtaining and using personal data, we partly use the services of external service providers who, under contract, strictly follow our instructions and whom we continuously monitor, both before and during the provision of the service.

The following external service providers are currently involved in the operation of the Website:

• Cloudflare — hosting the Website and delivering it to visitors;
• Web3Forms — forwarding contact form messages to the Controller’s email address;
• Google Maps — the map showing the clinic’s location in the “Contacts” section, which loads only with the visitor’s consent (see section 10).

6. Categories of data subjects

Categories of data subjects — the Controller’s current, former and prospective clients, as well as other persons wishing to contact the Controller.

7. Transfer of data outside Latvia

We do not plan to transfer the data we receive outside Latvia, the European Union or the European Economic Area, nor will it be transferred to any international organisation. At the same time, given that the Website is linked to Google and Facebook services, the Controller cannot guarantee that these companies will not transfer data outside the European Union or the European Economic Area.

8. Data retention period

We process and store the User’s personal data for as long as either party has a legal obligation to retain it.

Once those circumstances cease to apply, and unless stated otherwise in our data protection notices, we delete personal data no later than three months after the original reason for retaining the data ceases to be valid, except where we have a continuing legal obligation to retain the data (for example, but not limited to, accounting or legal proceedings purposes).

9. Data subject access to personal data

The data subject has the right to obtain access to their personal data within one month of submitting the relevant request.

The User may submit a request to exercise their rights in writing, in person at the Controller’s registered address (presenting an identity document), by post, or by email signed with a secure electronic signature.

On receiving a User’s request to exercise their rights, the Controller verifies the User’s identity, assesses the request, and fulfils it in accordance with applicable legislation.

The User has the right to receive the information required by law in connection with the processing of their data, the right to request access to their personal data, and to request that the Controller supplement, correct or erase it, restrict its processing, or object to its processing, insofar as these rights do not conflict with the purpose of the data processing (the conclusion or performance of a contract).

The data subject is not entitled to receive information where disclosure of that information is prohibited by law in the area of national security, national defence, public security, criminal law, or in order to safeguard the state’s financial interests in tax matters or the supervision of financial market participants and macroeconomic analysis.

10. Use of cookies

The Website itself does not place cookies in the visitor’s browser and does not collect data about the visitor’s behaviour on the Website.

The Website does not currently use visitor analytics tools such as Google Analytics, nor any advertising or profiling cookies. Should any be introduced in future, this policy will be updated accordingly and, where the law requires it, the visitor’s consent will be requested.

The server hosting the Website may log requests sent by visitors (device used, browser, IP address, date and time of access). The data referred to in this paragraph is used for technical purposes: to ensure the proper functioning and security of the Website and to investigate possible security incidents. The basis for collecting the data referred to in this paragraph is the Controller’s legitimate interest in ensuring the Website’s technical availability and integrity.

Cookies are small files that, each time a visitor visits the Website, the browser stores on the visitor’s computer to the extent specified in the browser settings on the visitor’s computer. Certain cookies are used to select and tailor the information and advertising offered to the visitor, based on content the visitor has viewed previously, thereby making the Website simple, convenient and individually tailored for visitors to use. Further information about cookies, including how to delete and manage them, is available at www.aboutcookies.org.

The Website uses cookies to collect users’ IP addresses and browsing information and to allow the Website to remember a visitor’s choices. Cookies allow the Controller to track the Website’s data flow and users’ interaction with the Website — the Controller uses this data to analyse visitor behaviour and improve the Website. The legal basis for the use of cookies is the Controller’s legitimate interest in ensuring the Website’s functionality, availability and integrity.

Visitors may control and/or delete cookies as they choose. A visitor may delete all cookies stored on their computer, and most browsers can be set to block cookies from being placed on the computer. If cookies are blocked, the visitor will need to manually adjust settings each time they visit the Website, and some services and features may not work.

Statistical data about Website visitors may only be accessed by those employees of the Controller who are responsible for analysing such data.

Unless stated otherwise, cookies are stored for as long as needed to carry out the purpose for which they were collected, after which they are deleted.

If the Controller’s Website provides for a forum or comments feature, the IP address, as well as data provided by the visitor themself, will be stored on the Website. For your convenience (so that you do not have to re-enter your details next time), cookies containing this data may be stored for one year.

11. Third-party websites

We may cooperate with third parties authorised to place third-party cookies on our websites or in our services, apps and tools with your consent. These service providers allow us to provide you with a better, faster and more secure website experience. Please note that third-party cookies are subject to those third parties’ own privacy policies, so we accept no responsibility for those privacy policies.

The Website does not use the “Facebook pixel” tool or any other social network tracking tools. The links to the Controller’s Facebook and WhatsApp profiles are ordinary links — they send no data until the visitor follows them.

The “Contacts” section of the Website offers a Google Maps map showing the clinic’s location. The map does not load automatically: the visitor is first shown a notice and a button, and only once that button is pressed does the Website connect to Google. When the map loads, Google may receive the visitor’s IP address and set cookies in the visitor’s browser; that processing is governed by Google’s privacy policy. The legal basis for loading the map is the visitor’s consent, given by pressing that button. If the visitor does not press it, no connection to Google is made.

12. Right to lodge a complaint with a supervisory authority

The data subject has the right to lodge a complaint with the supervisory authority (the Data State Inspectorate). The Data State Inspectorate accepts documents by post, by email (documents signed with a secure electronic signature), or they may be left in the mailbox on the 1st floor at Blaumaņa iela 11/13, Riga. The Data State Inspectorate accepts emails sent to info@dvi.gov.lv.

13. Validity of the privacy policy

We reserve the right to amend and supplement the content of this privacy policy from time to time in order to clarify the description of how we process your data.

In view of the above, we recommend reviewing this privacy policy regularly so that you remain informed about the processing of your personal data on the Website.