Privacy

SIA RC Ainava Privacy Policy

Effective February 29, 2025

The Privacy Policy (hereinafter referred to as the Policy) describes the procedure for processing personal data by RC Ainava.

The Policy is applicable if:

The Client uses, has used or has expressed a desire to use the services provided by RC Ainava, or is otherwise related to the services provided by RC Ainava, including in relations with the Client established before the entry into force of this Policy;

The Client visits the RC Ainava office, warehouse and other premises, including those where video surveillance is carried out.

PART 1. GENERAL PROVISIONS

1.1. A Client is any natural person who uses, has used or has expressed a desire to use any services provided by RC Ainava, or is otherwise related to them.

1.2. Personal data is any information about an identified or identifiable natural person, therefore it is any information directly or indirectly related to the Client.

1.3. Processing of personal data is any operation performed on personal data (including collection, recording, storage, viewing, modification, provision of access, making requests, transfer, deletion, etc.).

1.4. The controller is RC Ainava (hereinafter – the Company), reg. No. 43202005939, legal address Valkas iela 7, Alūksne, Alūksne, Alūksne municipality – the company on whose behalf and in whose interests the personal data are processed and which is responsible for the data processing.

1.5. The Client may contact RC Ainava regarding questions regarding the processing of personal data, withdrawal of consent, requests, exercise of data subject rights and complaints regarding the use of personal data, using the contact information for matters related to the processing of personal data: [email protected]. A request for the exercise of your rights can be submitted:

by electronic mail to the e-mail address [email protected], signed with a secure electronic signature.

1.6. RC Ainava carries out lawful processing and protection of personal data of customers. Information obtained from customers is protected in accordance with this Policy and the requirements of regulatory enactments. More detailed information on the processing of Personal Data may also be described in contracts, other documents related to services and on the RC Ainava website: www.ainava.eu

1.7. RC Ainava ensures the confidentiality of personal data within the framework of applicable regulatory enactments and has implemented appropriate technical and organizational measures to protect personal data from unauthorized access, unlawful processing or disclosure, accidental loss, alteration or destruction.

1.9. Data subjects' data are used in the activities of RC Ainava to provide the client with quality services and to improve them, to send notifications, offers and advertisements, to protect the rights and interests of the company and third parties, and to comply with regulatory enactments.

The purpose of the Privacy Policy is to provide the natural person - the data subject - with information about the purpose, scope, protection and processing period of personal data during data acquisition and processing of the data subject's personal data, regardless of the form and/or environment in which the Client provides personal data (in paper format, orally, electronically or by telephone) and in which company systems or in paper format they are processed.

PART 2. PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA

2.1. RC Ainava processes personal data for the following purposes:

For the provision of services and

for the sale of goods

- for the identification of the client;

- for the preparation and conclusion of a contract;

- for the delivery of goods and ensuring the operation of services;

- for the fulfillment of warranty obligations;

- for improving goods and services, developing new goods and services;

- for advertising and distribution of goods and services or for commercial purposes;

- for customer service;

- for reviewing and processing objections;

- for customer retention, increasing loyalty, measuring satisfaction;

- for billing administration;

- for debt recovery and collection;

- for maintaining and improving the website.

For business planning and analytics

- for statistics and business analysis;

- for planning and accounting;

- for measuring efficiency;

- for ensuring data quality;

- for conducting market and public opinion research;

- for preparing reports;

- for conducting customer surveys;

- within the framework of risk management activities.

For conducting video surveillance

- to prevent and detect criminal offenses related to property protection

For providing information to state administrative institutions and operational entities in the cases and to the extent specified in external regulatory enactments.

Use of data in any other lawful manner that complies with the provisions of regulatory enactments

2.2. Legal basis for processing personal data

for the conclusion and execution of a contract - to conclude a contract at the request of the Client and ensure its execution;

for the execution of regulatory enactments - to fulfill the obligation set forth in the binding external regulatory enactments of RC Ainava;

in accordance with the consent of the Client - the data subject;

in legitimate interests - to realize the interests of RC Ainava and the Clientthe obligations existing between them or the concluded contract, or the legitimate interests of RC Ainava arising from the law.

2.3. The legitimate interests of RC Ainava are:

to conduct commercial activities;

to provide trade services;

to verify the identity of the Client before concluding the contract;

to ensure the fulfillment of contractual obligations;

to prevent unreasonable financial risks for its commercial activities;

to store Client applications and submissions for the purchase of goods and the provision of services, other applications and submissions, notes on them;

to segment the customer database for more efficient provision of services;

to develop and develop goods and services;

to advertise its goods and services by sending commercial communications;

to send other reports on the progress of contract execution and events relevant to the performance of the contract,

to ensure financial and business accounting and analytics;

to ensure effective company management processes;

to ensure the efficiency of service provision and sales and delivery of goods;

to ensure and improve the quality of services;

to administer payments and debts;

to address state administrative and operational institutions and the court to protect its legal interests;

to prevent and detect criminal offenses related to the protection of property;

to inform the public about its activities.

PART 3. PROCESSING OF PERSONAL DATA

3.1. RC Ainava processes and protects the Client's data using modern technology capabilities, taking into account existing privacy risks and RC Ainava's reasonably available organizational, financial and technical resources in accordance with current technical development capabilities.

3.2. RC Ainava does not make automated decisions regarding the Client. Profiling is not performed in the data processing performed by the Company.

3.3. In order to ensure the high-quality and operational fulfillment of the obligations of the contract concluded with the Client, RC Ainava may authorize its cooperation partners to perform certain goods delivery or service provision activities, such as transportation of goods, debt collection and the like. If, when performing these tasks, cooperation partners process the Customer's personal data at the disposal of RC Ainava, the relevant cooperation partners are considered to be data processors of RC Ainava and RC Ainava has the right to transfer to cooperation partners the Customer's personal data necessary for the performance of these activities to the extent necessary for the performance of these activities.

3.4. RC Ainava cooperation partners, acting in the capacity of data processors, will ensure the fulfillment of personal data processing and protection requirements in accordance with RC Ainava's requirements and legal acts, and will not use personal data for purposes other than for the performance of the contractual obligations concluded with the Customer on behalf of RC Ainava.

3.5. RC Ainava 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 RC Ainava or the Customer can exercise their legitimate interests (for example, to file objections or to bring and/or bring a lawsuit in court) in accordance with the procedures specified in external regulatory enactments;

as long as one of the parties has a legal obligation to store the data;

as long as the Client's consent to the relevant processing of personal data is valid, unless there is another lawful basis for data processing.

3.6. After the circumstances referred to in paragraph 3.5 cease to exist, the Client's personal data shall be deleted.

PART 4. CATEGORIES OF RECIPIENTS OF PERSONAL DATA

4.1. The Client's personal data shall be processed in the RC Ainava office or in the company's structural units and may be transferred to other recipients (third parties and processors).

4.2. Personal data may be transferred to other institutions and organizations, such as:

RC Ainava cooperation partners for the preparation and execution of credit agreements;

RC Ainava accounting service providers, auditors, lawyers, financial consultants;

Debt collection service providers, courts, out-of-court dispute resolution institutions, insolvency administrators; bailiffs;

To the company's service providers, such as archiving, postal or courier service providers, website maintenance service providers, call centers, marketing service providers, and others.

4.3. Data may be transferred without the Client's consent in cases where this is required by regulatory enactments or failure to transfer data may harm and threaten the legitimate interests and security of the company RC Ainava, the Client or other persons.

4.4. Security measures are observed for data transfer and processing to the same extent as provided by RC Ainava, in compliance with this Policy and other internal documents within the framework of the legal protection of personal data processing.

4.5. Client data is transferred in compliance with the grounds specified in regulatory enactments, the legitimate interest of RC Ainava and the consent provided by the Client.

4.6. Client data is not transferred outside the borders of the European Union and the European Economic Area. If such data were to be transferred, the requirements of regulatory enactments regarding data transfer would be complied with.

outside the borders of the European Union and the European Economic Area, including, data transfer could take place if there was a legal basis for fulfilling a legal obligation, such as the performance of a contract, or if the Customer's consent was obtained and/or appropriate security measures were taken.

PART 5. RIGHTS AND OBLIGATIONS OF THE CUSTOMER

5.1. The Customer as a data subject has the right to:

Request the correction of their personal data if they are inadequate, incomplete or incorrect.

Object to the processing of their personal data if the use of personal data is based on the implementation of the legitimate interests of RC Ainava, including for direct marketing purposes.

Request the deletion of their personal data, for example, if personal data is processed on the basis of consent, but the Customer has withdrawn their consent. The right to request the deletion of their data does not apply if the personal data, the deletion of which is requested, is also processed on the basis of another legal basis, such as a contract or arises from obligations specified in the relevant regulatory enactments.

Receive information about whether RC Ainava collects and processes Customer data. In the event of an affirmative answer, receive information about their personal data that they have provided to the company and that are processed on the basis of consent and contract performance in written form or in one of the most commonly used electronic formats. The Customer has the right to transfer these received data to another service provider (data portability). RC Ainava provides information to the Customer to the extent that does not infringe on the privacy of other persons.

Withdraw their consent to the processing of their Personal data in the manner in which it was provided. In such a case, further data processing based on the previously given consent for the specific purpose will not be carried out in the future. Withdrawing consent cannot stop data processing that is carried out on the basis of other legal grounds.

Receive information from RC Ainava about the purposes of processing the Customer's personal data.

Find out information about third parties to whom personal data has been transferred, unless the transfer of such information is prohibited by regulatory enactments.

Submit complaints about the use of personal data to the State Data Inspectorate if the Client believes that the processing of his personal data violates his rights and interests in accordance with applicable regulatory enactments.

5.2. The Client is obliged to provide RC Ainava with information about changes in his personal data in a timely manner and to the necessary extent, which may affect future contractual relations.

5.3. If the Client exercises his rights and requests RC Ainava to provide information with his personal data that is being processed, the company will verify the Client's identity, evaluate the request and fulfill it in accordance with the requirements of regulatory enactments.

SECTION 6. COMMERCIAL COMMUNICATIONS

6.1. RC Ainava shall carry out communication regarding commercial communications regarding RC Ainava and/or third-party services and other communications not related to the direct provision of contracted services (for example, customer surveys) in accordance with the provisions of external regulatory enactments or with the Client's consent.

6.2. The Client may give his consent to receive commercial communications from RC Ainava and/or its cooperation partners in the RC Ainava service application forms in person and in an electronic environment.

6.3. The Client's consent to receive commercial communications is valid until its withdrawal (including after the termination of the service agreement). The Client may at any time refuse to receive further commercial communications in any of the following ways:

by sending an e-mail to [email protected];

in person at the RC Ainava office;

using the automated option provided in the commercial communication to refuse to receive further communications by clicking on the opt-out indication in the relevant commercial communication (e.g. at the end of the e-mail).

6.4. RC Ainava stops sending commercial communications as soon as the Client's request is processed. The processing of the request depends on technological capabilities.

SECTION 7. USE OF COOKIES

7.1. Cookies are small files that are downloaded to the user's device when using the website.

7.2. In order to provide customers with an innovative and friendly website, RC Ainava uses technical cookies that allow the use of the website and ensure its functioning.

7.3. Other - analytical or functional cookies are not used and data on user habits are not analyzed and used.

SECTION 8. CONTACT INFORMATION

8.1. The customer can contact RC Ainava in connection with the withdrawal of consent, requests, exercise of data subject rights and complaints about the use of Personal data.

8.2. Contact information - RC Ainava SIA, reg. No. 43202005939, legal address Alūksne municipality, Alūksne, Valkas iela 7, Alūksne, LV-4301, e-mail address [email protected].

8.3. Additional information on the website: www.ainava.eu

8.4. To contact the data protection officer, the e-mail address [email protected] with the indication "Data Protection Officer" should be used.

The Company's Privacy Policy comes into force on February 29, 2025. The Company has the right to unilaterally amendments to this Policy. The current version of the Policy will be available on the Company's website www.ainava.eu.