1. Data Controller and Contact details
1.1. The Controller of your personal data processing is SIA SONIDO Ltd., registration No. 40103664698, legal address: Elijas iela 17-3, Rīga, LV – 1050.
1.2. Contact details regarding issues connected with personal data processing: Tel. No.: +371 27171061-, e-mail: firstname.lastname@example.org.
1.3. SIA SONIDO contact details for registering potential breaches of data protection regulations: Tel. No.: +371 27171061-, e-mail: email@example.com.
2. General Provisions
2.1. Personal data is information that relates to an identified or identifiable individual.
- individuals – SIA SONIDO clients (including potential, former and existing clients);
- SIA SONIDO office visitors who are subject to video security surveillance;
- visitors of SIA SONIDO website;
- individuals whose personal data are processed on social media in connection with SIA SONIDO marketing activities (henceforth – clients).
2.3. SIA SONIDO cares about the privacy and personal data protection of its clients, observes the laws pertaining to client’s right to personal data protection and data processing according to the Regulation (EU) 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, the Personal Data Processing Laws and other rules and regulations concerning privacy and data processing.
3. Purpose of Personal Data Processing
3.1. SIA SONIDO processes personal data for the following reasons:
3.1.1. for providing the call services:
- for billing purposes;
3.1.2. for processing of debt claims ;
3.1.3 investigating complaints and quality control;
3.1.4. improving loyalty, measuring customer satisfaction;
3.1.5. website maintenance and improvements;
3.1.6. business planning and analytics;
3.1.7. to provide information to state administration institutions and operative entities in the cases and to the extent specified in the applicable external laws and regulations;
3.1.8. to ensure the security and property protection of SIA SONIDO clients, employees, as well as to assess the quality of customer service provided;
3.1.9. to ensure the fulfilment of agreements with our partners.
4. Legal Basis for Personal Data Processing
4.1. SIA SONIDO processes personal data of Data Subjects, based on the following legal grounds:
- data processing is necessary to uphold the legitimate interests of SIA SONIDO (to organize an effective process of providing call centre services, to receive payments for the services rendered, and to promote SIA SONIDO in mass and social media).
- data processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract (Article 6 (b) of EU General Data Protection Regulation).
5. Processing of Personal Data
5.1. SIA SONIDO processes client’s information using the opportunities provided by the latest technologies, hence, taking into account the privacy risks and the reasonably available organizational, financial and technical resources.
5.2. SIA SONIDO may apply automated decision-making with regard to the client. In the case of such SIA SONIDO activity, the client will be informed separately according to laws and regulations.
5.3. Automated decision making that may produce legal effects for the client (for example, handing over to the debt recovery institutions) may only be done with the informed consent of SIA SONIDO and the client upon entering or during the execution of the agreement or based on the client’s express consent.
6. Protection of Personal Data
6.1. SIA SONIDO protects its clients’ data using the opportunities provided by the latest technologies, hence, taking into account the privacy risks and the reasonably available organizational, financial and technical resources.
7. Disclosure/Sharing of Personal Data
7.1. SIA SONIDO shall not disclose client data to third parties with the following exceptions:
- with the client’s written consent;
- concerned within the framework of a contract in order to perform the particular contract SIA SONIDO has entered in with its partners;
- to entities specified in external regulatory enactments (including institutions) at their justified request, in accordance with the procedures and to the extent prescribed by the external regulatory enactments.
7.2. SIA SONIDO shall not disclose to third parties the personal data of other persons (any data that is not the client’s personal data).
8. Sharing of Personal Data
8.1. SIA SONIDO shall exclusively share its client’s personal data with third persons ensuring the level of processing and protection of personal data equivalent to that prescribed by data protection regulations.
8.2. SIA SONIDO have the right to share personal data with SIA SONIDO prime contractors that help ensure the carrying out of their functions and obligations.
8.3. 8.2.punktā minētajā gadījumā SIA SONIDO virsuzņēmēji, kas saņem un apstrādā personas datus, ir uzskatāmi par personas datu pārziņiem Regulas izpratnē, ar tiem tiek slēgts rakstveida līgums, kurā tiek noteikts, ka SIA SONIDO apņemas izmantot saņemto informāciju tikai tiem nolūkiem, kuru dēļ dati tika nodoti, un saskaņā ar piemērojamo normatīvo aktu prasībām datu apstrādes un datu aizsardzības jomā.
9. Access to Personal Data by Third-Country Subjects
9.1. SIA SONIDO does not provide access to clients’ personal data to third countries (countries located outside the European Union and European Economic Area).
10. Duration of personal data storage
10.1. SIA SONIDO stores and processes the personal data of its clients while at least one of the following criteria fulfils:
- only as long as the commitment agreements between SIA SONIDO and their prime contractors are in place to ensure the services or while the client is being provided such services;
- for as long SIA SONIDO has a statutory obligation to store the data;
- as long as any client’s request/application is being reviewed and/or carried out;
- as long as the client’s consent for the processing of relevant personal data is in force unless there are other legal grounds for data processing;
10.2. Upon expiry of circumstances under Clause 10.1, the client’s personal data are deleted. Auditing records are stored for one year from their recording.
11. Access to Personal Data and Other Rights of the Client
11.1. The client is entitled to receive statutory information regarding his or her data processing.
11.2. The client is statutorily entitled to request from SIA SONIDO access to his or her personal data, and also request from SIA SONIDO to supplement, amend or delete them, or to restrict their processing regarding the client, or rights to object to the processing as well as rights to data portability. These rights are exercisable insofar as the data processing does not exceed the scope of obligations of SIA SONIDO, imposed on it under applicable laws and regulations.
11.3. Clients may submit a request on the exercise of his or her rights:
- in writing in person at SIA SONIDO by presenting a valid ID;
- electronically by signing the letter with a safe digital signature and sending it to firstname.lastname@example.org
- by sending a written letter to SIA SONIDO;
- by phone or sending an e-mail letter to SIA SONIDO: email@example.com provided that the patient has coordinated his communication with SIA SONIDO regarding the patient data via that particular e-mail address or phone number. Such consent must be written in person on-site (by presenting an ID) or signed with a safe digital signature.
11.4. When receiving a request from the client on the exercise of their rights, SIA SONIDO verifies the client’s identity, evaluates the request and performs it according to laws and regulations.
11.5. SIA SONIDO responds to the client to an extent possible taking into account the type of provision of answer specified by the client, but no later than one month after registering the said request from the client.
11.6. Should the answer be sent in a registered mail, it is addressed directly to the Data Subject (the person whose personal data the request concerns). Should the answer be sent electronically, it is signed with a safe digital signature (provided that the submitted application/request has been signed with a safe digital signature).
11.7. SIA SONIDO ensures meeting of data processing and protection requirements under the laws and regulations and, in case of objections from the client, takes reasonable steps to solve the objection. However, failing to do so entitles the client to the supervision authority – State Data Inspectorate.
11.8. The client is entitled to receive a copy of his or her personal data processed by SIA SONIDO free of charge.
11.9.Receiving and/or use of information stated in Clause 11.8. hereunder may be restricted with an aim to prevent adverse effects on rights and freedoms of other persons (including employees of SIA SONIDO).
11.10. SIA SONIDO undertakes to ensure accuracy of Personal data and relies on its clients, suppliers and other third parties delivering Personal data to ensure the completeness and accuracy of the Persona data delivered.
12. Consent to Data Processing and the Right to Withdraw It
12.1. The client gives consent to personal data (which is not defined as personal data under the General Data Protection Regulation) processing, the legal basis of which is the consent, in writing in person at SIA SONIDO offices or by sending an e-mail signed with a safe digital signature.
12.2. The client consents to the processing of their personal data (which is not defined as personal data under the General Data Protection Regulation) legal basis of which is the consent (for example, for sending commercial information) in person while at SIA SONIDO, by sending an e-mail signed with a safe digital signature, as well as by phone or in a regular e-mail, if SIA SONIDO has agreed on the use of relevant e-mail address and/or phone number for mutual communication as well as clear and unmistakable activities such as calls to the call centre or the use of SIA SONIDO online resources and website services that require providing personal data.
12.3. The client is entitled to withdraw the given consent for data processing in the same way it was given, and in this case, any further data processing based on previously given consent for this particular purpose will not be made.
12.4. Withdrawal of the consent does not affect data processing which was performed while the client’s consent was in force.
12.5. By withdrawing the consent, data processing may not be discontinued if such processing is based on other legal bases (for example, according to external laws and regulations or the Informed Consent signed between SIA SONIDO un the client, or any agreements between SIA SONIDO and the data Controller).
13. Commercial Communication
13.1. Communication containing commercial information about the services of SIA SONIDO complies with the external laws and regulations and/or the client’s consent.
13.2. Communication, including also commercial communication, can be provided by SIA SONIDO may be conducted via automated calling devices.
13.3. The client may provide a written consent to receive commercial information during an on-site visit, at the SIA SONIDO website and mobile applications.
13.4. The consent to receive commercial communications is valid until revoked. The client may discontinue further reception of commercial information at any time in one of the following ways:
- by sending an email to firstname.lastname@example.org;
- by calling +371 27171061
- in person at SIA SONIDO offices;
13.5. SIA SONIDO shall cease sending out commercial notices, as soon as the request of the client is processed. The processing of such requests depends on technical resources available and may therefore take up to three days.
13.6. By expressing their opinion in surveys and leaving their contact details (e-mail, phone), the client agrees that SIA SONIDO may contact the client via the provided contact information in relation to feedback provided by the client.
14. Other Provisions
14.2. The Data Subject shall have the right not to be subject to a decision based solely on automated processing (one that excludes participation of humans), including profiling, which produces legal effects concerning them or similarly significantly affects them.
14.3. Prior to applying automated decision-making, SIA SONIDO shall carefully assess the effects such activities may have on the personal data protection of the client.
14.4. Every person has the right to lodge a complaint with the Data State Inspectorate of Latvia
14.5. Data Subject shall have the right to receive compensation from the Controller or processor for the damage suffered, subject to the conditions provided for in the Regulation and this policy.
14.6. In any event, upon every instance of data collection, the Data Subject shall be informed about the purpose and justification for such data processing in order to ensure understanding between the parties concerned.