PRIVACY POLICY

1. Who are we?

We, SPH Engineering, are the company registered in the Republic of Latvia and we provide a variety of services for you. For purposes of providing services to you, we have to process your personal data. This Privacy Policy explains how we are processing (collect, store, disclose) your personal data.
 

2. Why do we process your data?

We process your personal data in compliance with the General Data Protection Regulation (GDPR) in order to ensure lawfulness, fairness, and transparency of a processing. The main goal of your personal data processing is to perform a contract in order to provide a Product or Service to you. For this purpose, we request your consent to process your personal data.
 

3. What categories of data are processed and what are purposes of a processing?

We process the following categories of personal data:

• Your first name (name);

• Your last name (surname);

• Your country of residence;

• Your address;

• Your phone number;

• Your email address.

We have to process your name and surname in order to identify you. We cannot accept any payment from you without such identification. We process your address to ensure compliance with the bookkeeping regulations on invoices.

We process your email address and phone number as the way of distributing information and contacting you. We provide answers to your requests or product inquiries, we send activation code for our products and we announce important information via these contact tools. We can contact you to receive your feedback on Product or Service of your choice.

We need to process your country of residence to make sure our services are not limited or restricted in your country. We will inform you If any limitation is present.
 

4. Who can access your personal data?

Our employees will be allowed to process your personal data in order to provide the requested service or product. If you agreed to receive marketing information from us, then our PR manager will have an access to your contact information as well.

Officials (police, tax offices and etc.) will have an access to your personal data only in the case when law binds us to disclose and to provide your personal data to them. Our lawyers will examine any official request very closely beforehand. We will not disclose your personal data before we will be 100% sure that officials have firm legal grounds to receive your personal data.
 

5. How long your personal data will be stored?

We will upkeep your personal data as long as you are using our Product or Service, or until the moment you revoke your consent. Please, keep in mind that the storage term depends on the Product or Service of your choice. If you would like to precisely know how long we are going to keep your personal data, based on Products and Services of your choice, feel free to use your right to access(more info about the right in the next chapter)by emailing us.

However, we will not keep your personal data longer than required by law.
 

6. What are your rights in regards to your personal data?

The GDPR stands tall since 2018, 25th May and starting with the date you, as our client, have rights in regards to your personal data:

• You have the right to access. You can request from us whether or not your personal data are being processed by us. You can ask for detailed information, which categories (such as name, surname, email address etc.) of your personal data is processed, who can access to your personal data, how long are we going to store your personal data. You can request us to provide a copy of your personal data.

• You have the right to rectification. In case you have seen a mistake in your personal data (for instance, we sent an email to you and a mistake is present in your name), you can request for a correction of inaccurate personal data.

• You have the right to erasure of your personal data. You can request erasure of your personal data, when you withdraw your consent for the processing or when you are stopped using our Products or Services. However, please, keep in mind, that we cannot erase data required to be kept by law;

• You have the right to restrict processing of your personal data. You can restrict to process your personal data when you think we process your personal data without any ground;

• You have the right to withdraw your consent for the processing of your personal data at any time. However, please, keep in mind, that such revoke will not affect the lawfulness of processing based on your consent beforehand;

• You have the right to portability. You have the right to receive your personal data from us in a structured form in order to transfer these data to another company. If technically possible, you can request us to transfer your personal data directly to another company.

• You have the right to complain. In case, you think we are violating your rights, you can complain to supervisory authority (like Data State Inspectorate (Datu Valsts Inspekcija)).
 

7. What will we do when you are performing your rights regarding rectification or erasure of personal data, as well as restrict processing of your personal data?

When you are requesting to perform the access, editing or erasure of your personal data, we will comply with your request and we will perform the requested action. If you will ask for an editing, erasure of your personal data or restrict to process your personal data, we will notify of your request any third party who has been provided with your personal data by us.
 

8. What if you don’t want to provide personal data to us?

In case the processing of personal data is required for concluding a contract (such as Name, Surname, and email) and you are not willing to share these personal data with us – we are not able to identify you as a contracting party, thus we are not able to comply with the requirements of accounting and anti-money laundering legislation; therefore we cannot sign a contract with you and cannot provide you a Service or Product.
 

9. Do we transfer your personal data to third countries?

Yes, we transfer your data to third countries (outside of the European Union). However, we ensure of recipient’s compliance with the GDPR prior to performing a transfer of your personal data.
You can take a glance at our partners’ statements on compliance with GDPR here:

By using our Products and Services and agreeing to this Privacy Policy, you provide us with your consent to perform such transfer of your personal data outside of the EU.

10. At what age you can use our Products and Services?

You may use our Products and Services if you reached the age of 13. You have to testify you are eligible to use our Products and Services, by expressing consent with this Privacy Policy.

We do not store personal data of minors and children under the age of 13. If you are a parent or a legal guardian of children or minor and you are aware that your ward has provided us with Personal Data, please contact us immediately via email: privacy@ugcs.com. If we become aware that Personal Data from a person under the age of 13 are in our possession without verification of parental consent, we will take immediate steps to erase the information data from our servers.
 

11. What will we do in case of a data breach?

In the case of a personal data breach, we will notify supervisory authority about the breach not later than 72 hours. We will notify you via email immediately if we see a high risk of your rights and freedoms (due to the breach) violation.
 

12. How can you protect your rights?

In case a dispute will happen, we invite you to settle any dispute with us in negotiation manner. We always ready to hear from you and to look for the best solution for all of us. In any case, you have the right to complain to the Data State Inspectorate (Datu Valsts Inspekcija) or look for a help of a court to protect your rights.

Data State Inspectorate web-page: http://www.dvi.gov.lv/en/
 

13. References to other internet-resources

Our Services may contain links to other sites not administered or operated by us. If you proceed with a third party link, you will be directed to a third party's site. We strongly advise you to review a Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
 

14. Legal and Contact Information

Company Name: SIA “SPH Engineering”, registration number 50103629321, official (legal) address: Latvia, LV-1050, Riga, Dzirnavu street 62 – 9.

Contact details of our representative: Janis Kuze, Sales director, +371 25453422, privacy@ugcs.com.

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