PENTHOUSE CALLING VOL. 3

I General rules

1. The purpose of this Privacy Policy is to provide data subjects (hereinafter referred to as "you") with information about the purposes for which we obtain personal data, the amounts and time limits of data processing, data protection, as well as to inform you about your rights and obligations. The data subject is any customer of STATS who uses or has used the services and/or products of STATS group companies, visitors to the offices, shops, etc. of STATS group companies, visitors to STATS websites and social media profiles, callers to the contact numbers of STATS companies, tenants and/or purchasers of STATS real estate, participants in public events organised by STATS (open days, customer days, fairs, etc.).
2. When processing personal data, STATS Group complies with the laws and regulations of the Republic of Latvia, 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, as well as other laws and regulations in the area of privacy and personal data processing.
3. The STATS Group Privacy Policy applies to the processing of personal data regardless of the form in which you or any other natural person has provided your personal data, such as IT systems, websites, mobile applications, paper, telephone, video conferencing or automated calling and communication methods (bots, chatbots).
4. The STATS Group's Cookie Policy is available at https://stats.lv/datu-apstrade/ in the "Cookies and their use" section.

II Identity and contact details of the controller

1. Controller of the processing of personal data

STATS group company "STATS VADĪBAS SISTEMAS", reg. No.: 40103975459, acts as a data controller and in this capacity is responsible for the processing of your personal data carried out by or on behalf of STATS group companies. (More information about the companies that are part of the STATS group can be found at https://stats.lv/par-mums/).

2. Controller of the processing of personal data

We respect your privacy and care about the security of your personal data that we hold. Contact information for contacting STATS Group on personal data protection issues: stats@stats.lv, phone +371 67032550.

III Purposes, types and sources of personal data

1. We process the personal data you provide for the following purposes:
   1. For the provision of services and sale of goods (identification of the customer; preparation, conclusion and performance of the contract, including warranty obligations; processing of applications and complaints; administration of payments).
   1. to promote, improve and develop the quality of the STATS Group's products and services;
   1. Ensuring contractual relations (assessing creditworthiness, recovering and enforcing debts, providing legal redress for customer claims).
   1. Business development (analysing customer relationships; conducting customer surveys; measuring business performance).
   1. For information systems and information security
   1. To fulfil the obligations set out in the regulatory enactments (to ensure data retention; to provide information to state and local government institutions in the cases set out in the regulatory enactments).
2. We process the following personal data:
   1. Your name and contact details (telephone number, email address) for the legitimate interests of the provision of the service - for internal and external communication and elements thereof,
   1. In addition to the above, we may process the following personal data:
      1. Personal identification number, residential address, information about your preferences regarding the product/service you have chosen for the purpose of establishing and fulfilling the contractual relationship,
      1. Your purchase history, your feedback and complaints and related correspondence,
      1. Your image (video) and voice (audio) if you are taking part in an online meeting, for example, and activate the microphone or camera functions during the meeting,
      1. Technical data sent by your devices (such as computers and mobile devices), as well as information obtained through cookies and other similar technologies,
      1. Your personal data that we are required to process in accordance with the requirements of laws and regulations.
3. Sources of personal data:
   1. Information provided by you verbally, in writing or on STATS websites when you enquire about products and/or services from STATS group companies;
   1. From cookies and similar technologies when you use STATS websites or promotional material placed on the internet;
   1. Information available in official databases such as Lursoft;
   1. Partners of STATS Group companies.

V Transfer of personal data to third countries

1. Your personal data is not transferred outside the European Union or the European Economic Area.

VI Ensuring data security

1. In order to guarantee the security of personal data, STATS VADĪBAS SISTEMAS has implemented the necessary electronic, physical and administrative security measures using modern technologies. Your data is kept secure and protected against unauthorised access, disclosure, alteration or destruction by any organisation or individual.

VII You have the following rights

1. Receive the information required by the regulatory enactments in relation to the processing of your personal data.
2. The right to object to processing (including processing based on the legitimate interests of the service provider) and the right to restrict our processing.
3. The right to rectify erroneous data or to have your personal data erased.
4. The right to data portability, i.e. the right to request that your personal data is transferred from our company to another company.
5. Submit your request to exercise your rights in writing. Documents shall be accepted by STATS VADĪBAS SISTEMAS by post (registered letter), electronic mail (documents signed with a secure electronic signature) or may be submitted in person at the address.
6. Receive your personal data that you have provided and that is being processed, in written form or in one of the most commonly used electronic formats. The reply will be sent to you by post (registered letter) to your address of residence, to the e-mail address provided by you (documents signed with a secure electronic signature) if you wish to receive the reply electronically.
7. "STATS MANAGEMENT SYSTEMS shall ensure compliance with the requirements for the processing and protection of personal data in accordance with the regulatory enactments. If you have a justified concern about the processing of your personal data in breach of the requirements of the laws and regulations, you have the right to lodge a complaint with the Data State Inspectorate (www.dvi.gov.lv), 17 Elijas Street, Riga, LV-1050.

VIII Duration of data storage

1. Your data collected during the provision of the service will be stored, in whole or in part, until no longer necessary to safeguard your legitimate interests.
2. All information for the purpose of compliance with a legal obligation to which the customer is subject is kept for as long as is necessary to achieve the purpose of processing personal data in accordance with applicable laws and regulations.
3. Personal data processed for the purposes of legitimate interests shall be kept for as long as is necessary to achieve the purpose of the processing.
4. Personal data is stored for as long as STATS MANAGEMENT SYSTEMS is legally obliged to store the data. When this criterion is no longer applicable, your personal data will be deleted or destroyed or transferred to a public archive for storage in accordance with the requirements of the laws and regulations.

IX Closing questions

1. This Privacy Policy is effective from the date of issue.
2. "STATS MANAGEMENT SYSTEMS may make changes or additions to this Privacy Policy by posting the current version of this Privacy Policy on its website.