Please read this Probaks Group Privacy Notice ("privacy notice") carefully to understand our privacy policy regarding your personal data and how we will use it. This privacy notice applies to individuals who use Probaks Group services as consumers ("you"). This privacy notice explains how Probaks Group Ltd. ("Probaks Group", "we") obtains, uses and discloses your personal data. It also explains how you can access and update your personal data and choose alternatives for the use of your personal data.
This privacy notice covers both our online and offline data collection activities, including the personal data we collect through our various channels, such as websites, applications, third party social networks, consumer participation in events. Please note that we may obtain personal data from various sources (website, offline event). Please see section 8 for more information on how to object.
In cases where we process your personal data in order to fulfill our legal obligations, the provision of your personal data is mandatory according to the law and legal obligations. In other cases, the provision of your personal data is not mandatory, however, if you do not provide us with the necessary personal data, we will not be able to contact you, provide you with our goods and / or services, sign agreement. We will tell you when you need to provide personal data, for example indicating this information in our registration forms.
This privacy notice may change from time to time (see section 10).
This privacy notice provides important information on the following issues:
1. sources of personal data
2. personal data that we collect about you and how we collect it
3. cookies / similar technologies, registration files and web beacons
4. use of your personal data
5. disclosure of your personal data
6. retention of personal data
7. storage or transfer of your personal data
8. access to your personal data and other rights
9. your choice regarding the use and disclosure of your personal data
10. changes in privacy notice
11. data controllers and contacts
1. SOURCES OF PERSONAL DATA This privacy notice applies to personal data we collect from or about you using the methods described below (see Section 2) from the following sources:
Probaks Group websites. Consumer-created websites used by or for the purposes of the Probaks Group, including websites we use with our own domains / URLs and mini-websites that we use on third party social networks such as Facebook ("websites").
Email, text messages or other electronic messages. Electronic communication between you and Probaks Group.
Offline registration forms. Printed or digital registrations and similar questionnaires obtained, for example, by post, at competitions and other promotional activities or events.
Viewing ads. Viewing our ad (for example, if you view one of our ads on a third-party website, we may receive information about that).
Data created by us. During our cooperation with you, we may create personal information about you (e.g., tracking your purchases on our websites).
Data from other sources. Third-party social networks (e.g. Facebook, Google), market research (unless feedback is provided anonymously), third-party data collections, Probaks Group service promotion partners and publicly available information sources.
2. PERSONAL DATA WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
Depending on your cooperation with Probaks Group (online, offline, over the phone, etc.), we collect various information about you as described below.
Personal contact information. It includes all the information you provide so that we can contact you, such as your name, email address, social network details or phone number.
Demographic information and interests. All information that describes your demographic situation and habits. For example, date of birth, age or age range, gender, geographical location (such as zip code), favorite items, hobbies, and interests, including household or lifestyle information.
Information from computer / mobile device. All information about the computer system or other technological device you use to visit our websites or applications, such as Internet Protocol (IP) address used to connect your computer or device to the Internet, the type of operating system, and the type and version of your Internet browser. If you visit the Probaks Group website or application from a mobile device, such as a smartphone, the information obtained, if permitted, will include your phone's unique device ID, ad ID, geographic location, and other similar mobile device data.
Information obtained from Internet home pages / communication. When you browse and use our websites or newsletters, we use automated data mining technologies to collect information about your activities. This includes information about links you click, pages or content you view, and for how long, as well as other similar information and statistics about your actions, such as content response time, download errors, and duration of visits of pages. This information is obtained through automated technologies such as cookies and web beacons, and it is also obtained through third-party observations for analytical and promotional purposes. You have the right to object to use such technologies, see section 3 for more information.
Market research and consumer feedback. All information you voluntarily provide us by sharing your experience of using our services.
Consumer-generated content. All content that you create and then share on third-party social networks or by uploading it to one of our websites or applications, including through third-party network applications such as Facebook. For example, photos, videos, personal stories, or other similar media or content. If it is permitted, we obtain and publish consumer-generated content related to a range of activities, including contests and other promotions, website community features, consumer engagement, and third-party social networks.
Information about third-party social networks. Any information that you share publicly on a third-party social network, or information that is part of your profile on a third-party social network (such as Facebook) and that you allow a third-party social network to share with us. For example, basic information about your account (e.g., name, email, gender, birthday, city, profile picture, user ID, friends list, etc.) and any additional information or activities you allow a third-party social network to share . We receive your third-party social network information each time when you use third-party social network that is integrated into a Probaks Group page (such as Facebook, Connect), or each time you interact with us through a third-party social network website. To learn more about how Probaks Group collects information about you from a third-party social network or stop sharing such social network information, please visit the relevant third-party social network website.
Payment and financial information. All information we need to complete your order or use to make a purchase, such as your debit or credit card information (cardholder's name, card number, expiry date, etc.), or other forms of payment (if available). In any case, we or our payment processing service provider (s) use payment and financial information in accordance with the law, regulations and security standards, such as the PCI DSS.
Confidential personal data. We do not attempt to collect or otherwise process confidential personal data in the course of our regular business activities. If for any reason it is necessary to process your confidential personal data, we rely on your prior consent to the processing of any data that is voluntary. If we process your confidential personal data for other purposes, we rely on the following legal bases: (i) detection and prevention of criminal offenses (including fraud prevention) and (ii) compliance with applicable laws and regulations (e.g. to comply with our diversity reporting).
3. COOKIES / SIMILAR TECHNOLOGIES, REGISTRATION FILES AND WEB BEACONS
Cookies / Similar technologies. Please see our Cookie Notice to learn how you can manage your cookie settings and learn more about the cookies we use and the purposes why we use them.
Registration files. We collect information in the form of registration files that track website activity and compile statistics about your browsing habits. These records are created automatically and help us figure out defects, improve performance and maintain the security of our websites.
Web beacons. Web beacons (also known as "web tracking devices") are small strings of code that create a graphic image on a website or email to send us back data. Information collected through web beacons will include information such as your IP address, as well as information about how you responded to your email campaign (e.g., when the email was opened, which links you clicked in the email, etc.) We will use web beacons on our websites or include them in emails that we send to you. We use information provided by web beacons for a variety of purposes, including, but not limited to, website traffic reports, individual visitor tracking, advertising, email auditing and reporting, and personalization.
4. USE OF YOUR PERSONAL DATA
The following paragraphs describe different purposes why we collect and use your personal data, as well as the various personal data that is collected for each purpose. Please note that not all of the following applications apply to every person.
Competitions, marketing and other product and service promotion activities. With your consent (if necessary), we use your personal information to provide you with information about goods or services (such as marketing messages or campaigns or advertisements). This may be done by means of communication such as e-mails, advertisements, SMS, telephone calls and mailing lists to the extent permitted by law. Some of our campaigns and promotions run on third-party websites and / or social networks. Such use of your personal data is voluntary, which means that you may not consent (if necessary) or withdraw your consent, or object to processing of your personal data for these purposes. Please see points 8 and 9 for more information on how you can change your marketing communication choices. The use of your personal data for the purpose of participating in competitions or advertisements is voluntary, however, if you do not provide personal data in this case, you will not be able to participate in competitions / advertisements. For more information on our competitions and other promotional activities, please see the official regulations or the additional information published with each competition / advertisement.
Our reasons:
- with your consent (if necessary)
- fulfilment of contractual obligations
- legal obligations
- our legal interests
Our legal interests:
- find out which of our services you might be interested in and tell you about them
- identify the types of consumers of new services
- prevention of fraud, legal action, enforcement or defense
Third-party's social networks: We use your personal data when you use third-party's social networking features, such as feature "Like" , to provide you with ads and interact with you on third-party's social networks. Learn more about how these features work, profile data we collect about you, and how give up by reviewing the relevant third-party's social network privacy notices.
Our reasons:
- with your consent (if necessary)
- our legal interests
Our legal interests:
- find out which of our services you might be interested in and tell you about them
- identify the types of consumers of new services
Personalization (offline and online). With your consent (if necessary), we use your personal data to (i) analyze your choices and habits, (ii) anticipate your needs based on your profile analysis, (iii) improve and personalize your experience on our websites, and applications; (iv) ensure that the content of our websites / applications is optimized for you and your computer or device; (v) provide you with customized advertising and content; (vi) allow you to participate in interactive features of your choice. Based on this type of information and with your consent (where applicable), we also show you specific, Probaks Group content or ads, taking into account your interests. The use of your personal data is voluntary, which means that you may not consent (if necessary) or withdraw your consent, if any, or object to the processing of your personal data for this purpose. See section 9 for details about withdrawal. Other general objectives (e.g. internal or market research, analysis, security). In accordance with the law and regulations, we use your personal data for other general business purposes, such as maintaining your account, conducting internal or marketing research, and evaluating the effectiveness of your advertising campaigns. We also use your personal data to manage and operate our communication, IT and security systems.
Our reasons:
- with your consent (if necessary)
- legal obligations
- our legal interests
Our legal interests:
- improvement and development of new services
- quality control and improvement of provided services (to become more efficient)
- customer satisfaction surveys
- prevention of fraud, legal action, enforcement or defense
- fulfillment of legal obligations
Legal reasons or consolidation / acquisition. If Probaks Group or its assets are taken over or merged with another company, including in the event of bankruptcy, we will transfer your personal data to all our successors and assigns. We will also disclose your personal data to third parties (i) if required by law; (ii) if necessary in the course of legal proceedings; (iii) in response to a request from a competent law enforcement authority; (iv) to protect our rights, privacy, security or property; or (v) to comply with any agreement or the terms of our website.
Our reasons:
- legal obligations
- our legal interests
Our legal interests:
- fulfilment of legal obligations
- protection of our property and staff
5. DISCLOSURE OF YOUR PERSONAL DATA
In addition to Section 5, we share your personal data with the following types of third party organizations:
Service providers. These are the outsourcing companies we use to conduct our business (providers of the following services): postal services, courier services, marketing (product and service promotion management, e-mailing, advertising campaign management), market research, IT / IS support, including Internet website and database operation and development, payment processing, legal affairs, audit, accounting). Service providers and their chosen staff are only allowed to access and use your personal data on our behalf for certain tasks that they are asked to perform in accordance with our instructions, and they must respect the privacy and security of your personal data.
Third party companies that use personal data for their marketing purposes. Except where you have given your consent, we do not license or sell your personal data to third party companies for their marketing purposes. Their identity will be revealed when your consent is required.
Recipients - third parties who use personal data for legal purposes or due to a consolidation / acquisition. We will disclose your personal data to third parties for legal reasons (e.g. legal entities to whom we have an obligation to disclose your personal data, in particular to public administrations or law enforcement authorities) or in the context of a takeover or consolidation (see section 4 for details).
6. RETENTION OF PERSONAL DATA
Probaks Group takes all necessary steps to ensure that your personal data is processed only for a minimum period of time determined in accordance with the following criteria:
- Probaks Group will keep copies of your personal data in the format required for identification only as long as: - we communicate with you (for example, if you are on our mailing list and have not given up; until you withdraw your consent to the processing of your personal data for marketing purposes or while you object to the processing of your data for this purpose) - your personal data is necessary for the purposes set out in this privacy notice and we have a valid legal basis;
as well as
2.Statute of limitations for all applicable claims / tax liabilities related to the specific purpose of the data processing, plus one additional year calculated from the end of the year when the applicable statute of limitations has ran out. This additional year is necessary if the claims are enforced shortly before the end of the statute of limitations and serve to set a single date for the deletion, destruction or anonymisation of the data. In addition, if significant legal requirements arise, we may continue to process your personal data for such additional time as may be required in connection with that requirement.
During the periods referred to in sub-paragraph (b), we will limit the processing of your personal data to the sole storage and / or preservation of the security of that data, except when it is necessary to obtain the data in connection with any claim or obligation under law.
On expiration of the periods referred to in subparagraphs (a) and (b), we will either (i) permanently delete or destroy the relevant personal data or (ii) render the relevant personal data anonymous.
7. STORAGE AND / OR TRANSFER OF YOUR PERSONAL DATA
We take steps (described below) to maintain the privacy and security of your personal data. Please note that this protection does not apply to information that you choose to share in a publicly, such as social networks of third parties.
People who can access your personal data. Your personal data will be processed by our authorized staff on a need-to-know basis, depending on the specific purposes why your personal data was collected.
Events in work environment. We store your personal data in work environment where security measures are taken to prevent unauthorized access. We adhere to reasonable standards of personal data protection. Unfortunately, the transmission of information on the Internet is not completely secure, and although we do our best to protect your personal data, we cannot guarantee the security of your data by transmitting it to our websites / applications.
8. ACCESS TO YOUR PERSONAL DATA AND OTHER RIGHTS
Access to personal data. You have the right to access, review and request a physical or electronic copy of the information held about you. You also have the right to request information about your personal data.
This right can be used by sending us an e-mail to nauris.probaks@gmail.com or by mail SIA "Probaks Group", Ozolciema Street 42 / 2-65, Riga, LV-1058 (before providing any information we reserve the right to verify your identity). If the request is made by someone else without proof that the request was made on your behalf, the request will be rejected. Please note that all identifying information provided to us will only be processed in accordance with the law and regulations.
Additional rights (e.g. modification, deletion of personal data). If required by law, you may (i) request the deletion of your personal data, transfer; (ii) restrict the use and disclosure of your personal data; and (iii) revoke your consent to any of our processing operations (revocation of consent does not affect lawful processing based on consent prior to revocation).
In accordance with law and regulations, you may also have the following additional rights with respect to the use of essential personal data:
- the right to object, on the basis of your particular situation, that we or someone acting on our behalf uses your relevant personal data, and
- the right to object that we or someone on our behalf processes your relevant personal data for direct marketing purposes.
We may be required to retain some of your personal information after you request its deletion in order to fulfill our legal or contractual obligations. We may also be permitted to retain some of your personal data for our business purposes in accordance with the law and regulations.
We hope that we have been able to answer your questions about how we process your personal data, but if you have any unresolved issues, you also have the right to complain to the supervisory authority: Data State Inspectorate.
9. YOUR CHOICE REGARDING THE USE AND DISCLOSURE OF YOUR PERSONAL DATA
We try to offer you a choice upon the personal data you provide us. The following mechanisms allow you to control your personal data in the following ways:
Cookies / similar technologies. Please see Section 3.
Advertising, marketing and promotion activities. You agree that Probaks Group may use your personal data to promote products or services through ticking the relevant boxes in registration forms. If you decide that you no longer wish to receive such notifications, you may give up receiving marketing notifications at any time, following the instructions provided in such notification. In order to give up receiving marketing notifications via any media, including third party social networks, you may give up any time by using the links in our notifications, logging to websites / applications or third party social networks, and customizing user settings for your account profile by clicking the appropriate boxes. Please note that even if you choose not to receive marketing notifications, you may still receive administrative notifications from us, such as order or other transaction confirmations, as well as other important non-marketing notifications.
Personalization (offline and online): if you want Probaks Group to use your personal data to provide a personalized / target experience and content, you can put a tick in the relevant box (es) in the registration form (s). If you no longer wish to use such personalization, you may give up any time by logging to the websites / applications.
Target advertising. We work with ad networks and other advertising providers ("Advertisers") that provide advertising on our behalf, and other businesses on the Internet. Some of these ads are tailored to your interests based on information collected from Probaks Group web pages and other websites. You can learn more about this type of advertising, as well as how to give up advertising based on interests and provided by companies participating in the Digital Advertising Alliance ("DRA") self-regulatory program, by visiting
www.aboutads.info/choices . You can also stop receiving location data from your mobile device using your device's location service settings.
10. CHANGES IN PRIVACY NOTICE
If we change the way we process your personal data, we will update this privacy notice. We reserve the right to make changes to our practices and this privacy notice at any time. We will notify you of any changes in this privacy policy by posting relevant information on our websites / applications or by sending you an updated policy document.
11. DATA CONTROLLERS AND CONTACTS
In order to ask questions about privacy notice and our methods of ensuring privacy or to comment them or file a complaint about our compliance with the law of privacy policy, please contact us by email: nauris.probaks@gmail.com or mail SIA "Probaks Group", Ozolciema Street 42 / 2-65, Riga, LV-1058 or call us +371 29214715.
We will accept and deal with all complaints about the way how we process personal data (including complaints where we have violated your rights under the law of privacy policy).