Contact Information
SIA IT Sales contact information for matters related to personal data processing is: [email protected]. By using this contact information or contacting SIA IT Sales at its legal address, you can ask questions about personal data processing.
Scope of Application of the Document
The Privacy Policy applies to ensuring privacy and personal data protection with respect to:
- natural persons – clients, subscribers, and other users of SIA IT Sales services (including potential, former, and current users), as well as third parties who, in connection with the provision of services to a natural person (subscriber, client, user), receive or transfer any information to SIA IT Sales (including contact persons, payers, etc.);
- visitors to SIA IT Sales stores, offices, and other premises, including those subject to video surveillance;
- visitors to SIA IT Sales websites and mobile applications, and callers to SIA IT Sales contact center phones (hereinafter referred to as Clients).
SIA IT Sales cares about Clients' privacy and personal data protection, respects Clients' rights to the lawfulness of personal data processing in accordance with applicable regulations – 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 (Regulation), and other applicable regulations in the field of privacy and data processing.
The Privacy Policy applies to data processing regardless of the form and/or medium in which the Client provides personal data (on the SIA IT Sales website, mobile applications, self-service portal, in paper format, or by phone) and in which company systems or paper format they are processed.
For specific types of data processing (e.g., cookie processing, etc.), environments, or purposes, additional specific rules may be established, and the Client is informed of these at the time they provide the relevant data to SIA IT Sales.
Purposes of Personal Data Processing
SIA IT Sales processes personal data for the following purposes:
- Provision of services and sale of goods;
- Client identification; preparation, conclusion, and proof of conclusion of contracts;
- Delivery of goods and installation and provision of services (fulfillment of contractual obligations);
- Ensuring/maintaining the operation of services;
- Fulfillment of warranty obligations; improvement of goods and services, development of new goods and services; promotion, advertising, and distribution of services;
- Client service; review and processing of applications and objections;
- Client retention, increasing loyalty, and satisfaction measurements;
- Administration of payments;
- Creditworthiness assessment and credit monitoring;
- Debt recovery and collection;
- Maintenance and improvement of websites and mobile applications; business planning and analytics: statistics and business analysis;
- Planning and accounting;
- Efficiency measurement;
- Data quality assurance;
- Conducting market and public opinion research;
- Preparation of reports;
- Conducting client surveys;
- Within the framework of risk management activities;
- Ensuring the security of information, information systems, and the company;
- Providing information to public authorities and operational entities in cases and to the extent specified in external regulations;
- Other specific purposes, about which the Client is informed at the time they provide the relevant data to SIA IT Sales.
Legal Basis for Personal Data Processing
SIA IT Sales processes Client personal data based on the following legal grounds:
- Conclusion and performance of a contract – to conclude a contract based on the Client’s request and ensure its performance;
- Compliance with regulations – to fulfill an obligation imposed on SIA IT Sales by external regulations;
- Client’s consent as the data subject;
- Legitimate interests – to realize the legitimate interests of SIA IT Sales arising from the obligations or contract with the Client or from the law;
- Ensuring the vital interests of the data subject or another natural person – to ensure the physical and property security of SIA IT Sales employees, Clients, and visitors.
The legitimate interests of SIA IT Sales include:
- Conducting commercial activities;
- Providing electronic communication services;
- Verifying the Client’s identity before concluding a contract;
- Ensuring the fulfillment of contractual obligations;
- Preventing unreasonable financial risks to its commercial activities (e.g., conducting credit risk assessments before the sale of goods and services and during contract performance);
- Retaining Client applications and submissions regarding the purchase of goods and provision of services, other applications and submissions, notes on them, including those made in writing or orally, by calling call centers, on websites, and in the self-service portal;
- Recording conversations with Clients regarding service operation, maintenance, and billing to conduct client service quality control;
- Recording conversations with Clients to organize the fulfillment of service contract obligations;
- Recording conversations with Clients during which an oral contract is concluded, to prove the fact of contract conclusion;
- Analyzing the performance of SIA IT Sales websites, internet sites, and mobile applications, developing and implementing improvements;
- Administering Client accounts on SIA IT Sales websites, internet sites, and mobile applications;
- Conducting client retention activities;
- Segmenting the client database for more efficient service provision;
- Developing and improving goods and services;
- Advertising its goods and services;
- Sending other notifications about the progress of contract performance and events essential to contract performance, as well as conducting Client surveys about goods, services, and usage experience (NPS);
- Maintaining and developing electronic communication networks;
- Maintaining and developing communication networks;
- Monitoring the operation of communication networks to identify technical issues, as well as unlawful activities and their prevention;
- Preventing fraud;
- Ensuring corporate governance, financial and business accounting, and analytics;
- Ensuring efficient company governance processes;
- Efficiency of service provision, goods sales, and delivery;
- Ensuring and improving service quality;
- Administering payments;
- Administering outstanding payments;
- Addressing public administration and operational authorities and courts to protect its legal interests;
- Informing the public about its activities.
Personal Data Processing
SIA IT Sales processes Client data using modern technological capabilities, taking into account existing privacy risks and the reasonably available organizational, financial, and technical resources of SIA IT Sales.
SIA IT Sales may make automated decisions regarding Clients. The Client is informed separately about such SIA IT Sales activities in accordance with regulations. The Client may object to automated decision-making in accordance with legal provisions, while being aware that in some cases this may limit their ability to use certain potential opportunities (e.g., receiving commercial offers).
Automated decision-making that produces legal effects for the Client (e.g., approval or rejection of the Client’s application) may only be carried out during the conclusion or performance of a contract between SIA IT Sales and the Client, based on the Client’s explicit consent or in cases specified in external regulations.
To ensure the qualitative and prompt fulfillment of contractual obligations with the Client, SIA IT Sales may authorize SIA IT Sales group companies or its business partners to perform specific activities related to the delivery of goods or provision of services, such as performing service installation work, sending invoices, and similar activities. If, in performing these tasks, SIA IT Sales group companies or business partners process the Client’s personal data held by SIA IT Sales, these group companies or partners are considered data processors (operators) for SIA IT Sales, and SIA IT Sales is entitled to transfer the Client’s personal data necessary for these activities to the extent required to perform these tasks.
Personal Data Protection
SIA IT Sales protects Client data using modern technological capabilities, taking into account existing privacy risks and the reasonably available organizational, financial, and technical resources of SIA IT Sales, including the following security measures:
- Data encryption during transmission (SSL encryption);
- Firewalls;
- Intrusion protection and detection programs;
- Other protective measures in accordance with current technological development capabilities.
Categories of Personal Data Recipients
SIA IT Sales does not disclose Client personal data or any information obtained during the provision of services and the operation of a contract to third parties, including information about received electronic communications, content, or other services, except:
- If the data must be transferred to the relevant third party within the framework of a concluded contract to perform a function necessary for the performance of the contract or delegated by law (e.g., to a bank within the framework of payments or to provide a service, such as in the case of electricity service sales, where SIA IT Sales exchanges data with the distribution network operator, as informed in the respective service contract);
- In accordance with the Client’s clear and explicit consent;
- To persons specified in external regulations upon their justified request, in the manner and to the extent specified in external regulations;
- In cases specified in external regulations for the protection of SIA IT Sales’ legitimate interests, such as by addressing courts or other state institutions against a person who has violated these legitimate interests of SIA IT Sales.
Access to Personal Data by Third-Country Entities
In some cases, subject to regulatory requirements, SIA IT Sales personal data is accessed by developers or service providers located in third countries (i.e., countries outside the European Union and the European Economic Area) in the capacity of a data processor (operator) as understood by the Regulation.
In such cases, SIA IT Sales ensures the procedures specified in regulations for ensuring a level of personal data processing and protection equivalent to that required by the Regulation.
Duration of Personal Data Storage
SIA IT Sales stores and processes Client personal data as long as at least one of the following criteria applies:
- As long as the contract concluded with the Client is in force (including recordings of conversations in which an oral contract is concluded or a service request is made);
- The data is necessary for the purpose for which it was received;
- As long as SIA IT Sales or the Client can pursue their legitimate interests in the manner specified in external regulations (e.g., submitting objections or filing or pursuing a claim in court);
- As long as either party has a legal obligation to retain the data (e.g., under the Accounting Law, issued invoices must be retained for 5 years, etc.);
- As long as the Client’s consent to the relevant personal data processing is valid, if there is no other lawful basis for data processing.
After the circumstances mentioned in this section cease, the Client’s personal data is deleted. Audit records are retained for at least one year from the date of their creation in accordance with regulations.
Recordings of conversations with Clients regarding service operation, maintenance, and billing, based on SIA IT Sales’ legitimate interests, are stored for six (6) months from the date of recording and are then deleted.
Access to Personal Data and Other Client Rights
The Client has the right to receive information specified in regulations regarding the processing of their data. Most of the Client’s information is already available in the self-service portal https://intop.lv/lv/login and on SIA IT Sales websites and applications used by the Client to receive IT Sales services, where the Client can verify the accuracy of their data and, if necessary, manage it, including making changes.
The Client also has the right, in accordance with regulations, to request access to their personal data from SIA IT Sales, as well as to request that SIA IT Sales supplement, correct, or delete it, restrict processing with respect to the Client, or object to processing (including processing of personal data based on SIA IT Sales’ legitimate interests), and the right to data portability. These rights are exercisable to the extent that data processing does not arise from SIA IT Sales’ obligations imposed by applicable regulations and carried out in the public interest.
The Client can submit a request to exercise their rights:
- In writing in person at SIA IT Sales stores or at the legal address, presenting an identity document;
- Via email, signed with a secure electronic signature;
- By logging into the self-service portal at intop.lv/manskonts.
Upon receiving the Client’s request to exercise their rights, SIA IT Sales verifies the Client’s identity, evaluates the request, and fulfills it in accordance with regulations.
SIA IT Sales sends a response to the Client by mail to the contact address provided at [email protected] in a registered letter or in the manner specified by the Client for receiving the response.
SIA IT Sales ensures compliance with data processing and protection requirements in accordance with regulations and, in the case of Client objections, takes appropriate actions to resolve them. However, if this fails, the Client has the right to contact the supervisory authority – the Data State Inspectorate.
Client Consent to Data Processing and Right to Withdraw It
The Client can give consent to personal data processing, the legal basis of which is consent (e.g., analysis of service usage patterns, individually tailored advertising, etc.), by logging into the self-service portal https://intop.lv/lv/login, in SIA IT Sales service application forms, on SIA IT Sales and other websites (e.g., newsletter subscription forms), by calling the SIA IT Sales contact center at +371 23070170, or in person at SIA IT Sales stores.
The Client has the right to withdraw consent for data processing at any time in the same manner in which it was given, i.e., by calling the SIA IT Sales contact center or in person at SIA IT Sales stores, and in such cases, further data processing based on the previously given consent for the specific purpose will not be carried out.
Withdrawal of consent does not affect data processing carried out while the Client’s consent was valid.
Withdrawing consent does not interrupt data processing carried out based on other legal grounds.
Communication with the Client
SIA IT Sales communicates with the Client using the contact information provided by the Client (phone number, email address, postal address).
Communication regarding the fulfillment of service contract obligations is carried out by SIA IT Sales based on the concluded contract (e.g., coordinating service delivery or repair times, information about invoices, planned works, communication interruptions, changes in services, etc.).
Commercial Communications
Communication regarding commercial announcements about SIA IT Sales and/or third-party services and other announcements not directly related to the provision of contracted services (e.g., client surveys) is carried out by SIA IT Sales in accordance with external regulations or with the Client’s consent.
Communication, including commercial announcements, may also be carried out by SIA IT Sales using automated calling equipment.
The Client can give consent to receive commercial announcements from SIA IT Sales and/or its business partners by logging into the portal www.intop.lv, in SIA IT Sales service application forms, SIA IT Sales service portals/applications, SIA IT Sales and other websites (e.g., newsletter subscription forms).
The Client’s consent to receive commercial announcements is valid until its withdrawal (even after the termination of the service contract). The Client can opt out of receiving further commercial announcements in one of the following ways:
- Making the appropriate setting in their user profile on the SIA IT Sales self-service portal www.intop.lv;
- Sending an email to [email protected];
- Calling the SIA IT Sales contact center;
- In person at SIA IT Sales stores;
- Changing notification settings on devices;
- Using the automated option provided in the commercial announcement to opt out of further announcements by clicking the opt-out link at the end of the respective commercial announcement (email).
SIA IT Sales stops sending commercial announcements as soon as the Client’s request is processed. Processing the request depends on technological capabilities, which may take up to seven days.
By expressing their opinion in surveys and providing their contact information (email, phone), the Client agrees that SIA IT Sales may contact them regarding the feedback provided, using the contact information provided by the Client.
Website Visits and Cookie Processing
SIA IT Sales websites may use cookies.
SIA IT Sales websites may include links to third-party websites, which have their own usage and personal data protection policies, for which SIA IT Sales is not responsible.
Other Provisions
SIA IT Sales has the right to make additions to the Privacy Policy, making its current version available to the Client in their user profile and by posting it on the SIA IT Sales website.
SIA IT Sales retains previous versions of the Privacy Policy, which are available on the SIA IT Sales website.
This version of the Privacy Policy takes effect on March 27, 2021, and replaces the previously approved version of the Privacy Policy.
