Privacy Policy
The purpose of the Personal Data Protection Policy of SIA EVELATUS (hereinafter – the Policy) is to provide natural persons with general information on the procedure for processing data of natural persons and ensuring data protection. The Policy applies to any processing of data of natural persons held by EVELATUS Ltd., regardless of the form and/or environment in which the data of natural persons are processed.
The Personal Data Protection Policy is intended for the following groups of persons – employees of EVELATUS Ltd, recipients of services of EVELATUS Ltd, business partners, Data Subjects whose Personal Data are processed directly or indirectly as a result of the activities of EVELATUS Ltd.
1. Controller and contact details
1.1 Controller: Limited Liability Company “EVELATUS”, single registration No. 40003734912, registered office at 2a-14 Ainavas Street, Riga, LV-1084, contact information: e-mail: info@evelatus.lv, telephone No.: +371 20334403
1.2 Information relating to the processing of data of natural persons and the exercise of the rights of natural persons is published on the website: evelatus.lv.
1.3 Contact details for issues related to the processing of personal data:
1.3.1. e-mail: to be established info@evelatus.lv
1.3.2. telephone: +371 20334403
1.3.3. for correspondence: Riga, Ieriķu iela 3, LV-1084, t/c Domina
1.3.4. contact details for notification of possible data protection and/or processing breaches: info@evelatus.lv
2. General information
2.1 Personal data means any information relating to an identified or identifiable natural person (“data subject”).
2.2 Processing of personal data means any operation performed on personal data or on sets of personal data
an operation or set of operations which is performed, whether or not by automated means, such as
collection, recording, organisation, structuring, storage, adaptation or alteration,
retrieval, consultation, use, disclosure, transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (‘processing’).
2.3 A processor is a natural or legal person who processes personal data on behalf of and in accordance with instructions given by EVELATUS Ltd.
2.4 A data subject is a natural person who can be identified, directly or indirectly.
2.5 Special categories of personal data are personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade-union membership, genetic data, biometric data (unique identification of a natural person is possible), health data, data concerning the sex life or sexual orientation of a natural person. (hereinafter sensitive personal data)
2.4 Personal data may be collected from:
2.4.1. data subjects;
2.4.2. third parties (for the purpose of obtaining credit for the purchase of goods).
2.6 To facilitate the comprehensibility of the information, certain types of processing or processing for a specific processing purpose may be aggregated or specified (Annex to the Personal Data Protection Policy).
Purposes of the processing of personal data
3. SIA “EVELATUS” processes personal data for the following purposes:
3.1. for the sale of goods and provision of services; and:
3.1.1. to identify the customer;
3.1.2. the preparation and conclusion of a contract;
3.1.3. delivery of the goods (performance of the contractual obligations);
3.1.4. the development of new goods and services;
3.1.5. for the promotion and distribution of goods and services or for commercial purposes;
3.1.6. customer service;
3.1.7. to deal with objections or complaints;
3.1.8. settlement administration;
3.1.9. the recovery and enforcement of debts;
3.1.10. website and mobile application maintenance and performance improvement.
3.2 Business planning and analytics;
3.3. for the prevention or detection of criminal offences related to the protection of the property of JSC “EVELATUS”, for the protection of vital interests of persons, including life and health.
3.4.
3.5 EVELATUS Ltd. may also process the data for other purposes compatible with the original purpose, provided that the data subject’s rights are respected.
3.2 If provided for by the laws and regulations in force in the Republic of Latvia, the data subject shall be informed of other specific purposes of data processing at the time of providing personal data to SIA “EVELATUS”.
3.3 In cases where personal data are obtained from a third party, EVELATUS Ltd. processes the data in order to provide the customer with a credit service.
4. Legal basis for the processing of personal data
4.1 EVELATUS Ltd. processes personal data on the following legal grounds:
4.1.1. the data subject has given consent to the processing of his/her personal data for one or more specific purposes;
4.1.2. the processing is necessary for the performance of a contract to which the data subject is a party or to carry out measures at the request of the data subject prior to entering into the contract;
4.1.3. processing is necessary for compliance with a legal obligation to which EVELATUS Ltd is subject;
4.1.4. the processing is necessary for the protection of the vital interests of the data subject or of another natural person;
4.1.5. processing is necessary for the protection of the legitimate interests of EVELATUS Ltd or of a third party.
4.2 The legitimate interests of EVELATUS Ltd are:
4.3.1. to carry out commercial activities;
4.3.2. to provide services related to the supply of goods;
4.3.3. verify the identity of the data subject before purchasing certain goods and/or entering into a contract;
4.3.4. to ensure compliance with contractual obligations;
4.3.5. to save data subjects’ applications and requests for the provision of services, other applications and requests, and comments thereon, including those made orally, by telephone or on the website;
4.3.6. analyse the performance of the website of EVELATUS Ltd, develop and implement improvements;
4.3.7. attract new customers;
4.3.8. develop and promote its services by sending commercial communications;
4.3.9. send information on the progress of the Contract and events relevant to the performance of the Contract, and conduct surveys on the Services and the user experience;
4.3.10. prevent unlawful activities;
4.3.11. provide financial and business accounting and analytics;
4.3.12. ensure efficiency of service delivery and improve service quality;
4.3.13. administer payments, including payments made in error;
4.3.14. apply to public administration, law enforcement authorities, courts, public prosecutors, supervisory and other authorities for the protection of their legitimate interests;
4.3.15. inform the public about its activities;
4.3.16. maintain and protect its property;
4.3.17. and other legitimate interests not listed above.
5. Protection of processing of personal data
5.1 Taking into account the nature, extent, context and purposes of the processing of personal data, as well as potential risks to the rights and freedoms of data subjects, EVELATUS Ltd. shall implement organisational and technical measures, including:
5.2.3. provide the data subject with the information provided for in the General Data Protection Regulation;
5.2.4. draw up internal rules and regulations on the processing of personal data;
5.2.5. train the employees of EVELATUS Ltd in data protection matters;
5.2.6. provide limited access to the real estate of SIA “EVELATUS” where personal data are stored and processed;
5.2.8. document the personal data breach process;
5.2.9. within the framework of the regulatory enactments, ensure the confidentiality of personal data and implement appropriate technical and organisational measures to protect personal data from unauthorised access, unlawful processing or disclosure, accidental loss, alteration or destruction;
5.2.10. when concluding a contract provided for in the laws and regulations, use processors for the processing of personal data which provide sufficient guarantees that the requirements laid down in the laws and regulations will be implemented in such a way as to comply with the requirements of the laws and regulations on data protection and to ensure the protection of the data subject’s rights;
5.2.11. take other actions to protect the rights and freedoms of data subjects.
6. Categories of recipients of personal data
6.1 EVELATUS Ltd. shall not disclose to third parties personal data, or any information obtained during the provision of services and the performance of the contract, including information about goods and services received, except:
6.1.1. if the third party in question is required to provide data within the framework of the concluded contract in order to perform a function necessary for the performance of the contract or delegated by law (for example: to a bank – within the framework of billing, etc.);
6.1.2. where the data subject has given his or her explicit, unambiguous consent to the request or transfer of data from or to a third party (e.g. for checking the data subject’s solvency in third party databases, etc.);
6.1.3. to the persons provided for in the laws and regulations in force in the Republic of Latvia (for example: subjects of operational activity, pre-trial investigation authorities, state security authorities, public prosecutor’s office, court, supervisory authorities, etc.) upon their justified request, in the manner and to the extent provided for in the external laws and regulations;
6.1.4. in the cases provided for by external regulatory enactments for the protection of the legitimate interests of EVELATUS Ltd., for example, by applying to court or other state institutions against a person who has infringed the legitimate interests of EVELATUS Ltd.
6.2 In the event that personal data are disclosed to third parties, EVELATUS shall ensure that the processing of personal data is carried out in a secure and confidential manner, in accordance with the terms of the concluded agreement, the requirements of the regulatory enactments in the field of data protection and the internal regulatory enactments of EVELATUS.
6.3 EVELATUS Ltd. does not transfer personal data to third countries or international organisations (outside the European Union and the European Economic Area).
6.4 Taking into account the specific nature of its activities, in certain cases (for example, the processing of a business trip), having previously informed the data subject of the possible risks associated with the transfer of personal data and obtained the data subject’s consent, SIA EVELATUS transfers information containing personal data to the relevant data subjects in third countries.
7. Duration of retention of personal data
7.1 EVELATUS Ltd. stores and processes personal data for as long as at least one of the following criteria exists:
7.1.1. as long as the contract concluded with or in respect of the data subject is valid;
7.1.2. as long as EVELATUS Ltd. or the data subject can exercise their legitimate interests within the limitation period for claims set out in external laws and regulations (e.g.: file objections, bring legal proceedings, etc.);
7.1.3. as long as EVELATUS Ltd. is legally obliged to store the data (retention periods established by law);
7.1.4. in the absence of another legal basis for processing, as long as the data subject’s consent to the processing of personal data is valid.
7.2 After the circumstances referred to in this section have ceased to apply, the personal data shall be deleted.
8. Right of access to personal data and other rights
8.1 EVELATUS Ltd. shall provide data subjects with the information set out in the General Data Protection Regulation, including information on the rights of data subjects, in a clear and plain language, in a transparent, concise and comprehensible manner, in writing (paper or electronic form):
8.1.1. access to their data;
8.1.2. to receive the information required by the regulatory enactments concerning the processing of their personal data;
8.1.3. to correct their personal data if the information held by SIA “EVELATUS” is outdated, inaccurate or incorrect;
8.1.4. to the portability of personal data;
8.1.5. to erase personal data (right to be forgotten). These rights shall be exercised subject to the limitations set out in the regulatory enactments;
8.1.6. to restrict the processing of personal data;
8.1.7. to object to the processing of personal data;
8.1.8. in relation to automated individual decision-making.
8.2 The data subject may submit a request for the exercise of his or her rights in the following manner:
8.2.1. in writing in person at the office of SIA “EVELATUS”, 3 Ieriķu Street, Riga, t/c Domina, upon presentation of an identity document;
8.2.2. by electronic mail, signing the request with a secure electronic signature and sending it to the e-mail address: info@evelatus.lv
8.3 Upon receipt of the data subject’s request to exercise his/her rights, EVELATUS shall verify the identity of the data subject, assess the validity of the request and provide a response in accordance with the laws and regulations in force in the Republic of Latvia.
8.4 SIA EVELATUS shall send the reply to the data subject by registered mail to the contact address provided by the data subject or provide it in person by requesting the personal identification document.
8.5 If the data subject’s request is manifestly unfounded or excessive, or if the data subject refuses to identify himself or to provide additional self-identifying information, EVELATUS Ltd. shall refuse to comply with the request pursuant to Article 12(5)(b) of the General Data Protection Regulation.
8.6 If the data subject considers that the processing of personal data by EVELATUS Ltd. violates the rights and interests of the data subject under applicable laws and regulations, the data subject shall have the right to lodge a complaint with the supervisory authority – the State Data Inspectorate (www.dvi.gov.lv).
8.7 The scope of information provided to data subjects may be limited in order to prevent adverse effects on the rights and freedoms of other persons (including employees of EVELATUS Ltd, other data subjects).
8.8 EVELATUS Ltd. undertakes to ensure the accuracy of personal data and relies on its Customers, suppliers and other persons who transfer personal data to ensure the completeness and accuracy of the personal data transferred.
9. Procedure for informing data subjects
9.1 In the event that information is obtained from the data subject, as well as in the event that information is not obtained from the data subject, SIA EVELATUS shall provide the data subject with the information required by the Data Regulation within the scope and time limits specified therein.
9.2 Information provided in the exercise of the data subject’s rights shall be free of charge. If the data subject’s requests are manifestly unfounded or excessive, in particular due to their regular repetition, EVELATUS Ltd. may charge a reasonable fee for fulfilling the data subject’s requests.
10. Consent to data processing and right of withdrawal
10.1 Where the legal basis for processing personal data is the data subject’s consent, EVELATUS Ltd shall obtain the data subject’s consent to the processing of personal data, which is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by means of a statement or an explicit affirmative action, gives his or her assent to the processing of personal data.
10.2 The data subject shall have the right at any time to withdraw the consent given to EVELATUS Ltd. for the processing of the data in the same manner as given or by contacting EVELATUS Ltd. using the contact details provided in Section 1.3 of the Policy, in which case no further processing of the data based on the consent previously given for the specific purpose will be carried out.
10.3 Withdrawal of consent shall not affect the processing of personal data carried out at the time when the consent was valid.
10.4 Withdrawal of consent shall not interrupt the processing of personal data carried out on the basis of other legal grounds.
11. Communication
11.1 EVELATUS Ltd. shall communicate with the data subject using the contact details (telephone number, e-mail address, postal address) provided by the data subject.
11.2 For the performance of contractual obligations, EVELATUS Ltd. shall communicate with the data subject on the basis of the concluded contract (e.g. coordination of repair times, information on invoices, planned works, changes in services, etc.).
12.
12.1 The website of EVELATUS Ltd. may use cookies, about which a notice shall be placed on the website.
12.2 Cookies are files that websites place on users’ computers in order to recognise the user and facilitate their use of the website. Internet browsers can be configured to alert the Customer to the use of cookies and allow the Customer to choose whether or not to accept them. Not accepting cookies will not prevent the data subject from using the website, but it may limit the data subject’s use of the website;
12.3 The website of EVELATUS Ltd. may contain links to third party websites, which have their own terms of use and personal data protection, for which EVELATUS Ltd. is not responsible.
13.
13.1 EVELATUS Ltd. has the right to unilaterally amend this Policy by publishing the changes and information about the changes on the EVELATUS Ltd. website.
13.2 EVELATUS Ltd. retains the previous versions of the Policy and they are available on the EVELATUS Ltd. website.
For the purpose of processing personal data
We may obtain your personal data in one of the following ways:
1) from you, by submitting an application and CV to us for the vacancy;
2) in the process of entering into a contract with each other, by obtaining the data from you;
3. if the contract is concluded with a third party who has identified you as a family member;
4) from you if you make any submissions, emails, calls to us;
5) in certain cases from third party databases, for example when assessing your creditworthiness,
we may obtain data from third parties for this purpose;
6) where appropriate, from CCTV footage and access control systems;
7) where applicable, from doctors as a result of medical examinations.
| The controller of personal data processing is SIA “EVELATUS”, unified registration No. 40003734912, legal address:Ainavas iela 2a – 14, Riga, LV-1084, contact information: e-mail: info@evelatus.lv, telephone No.: +371 20334403. |
| If you have any questions regarding this notice or the processing of your personal data, please contact us via the communication channels indicated in the previous paragraph (1.1) or by contacting our employee at the following e-mail address: info@evelatus.lv. |
2. General description of our processing of personal data |
| This notice describes how we carry out the processing of personal data of our employees, candidates, employees’ family members, contacts and other persons whose data may come into our possession in connection with the purposes of the processing of HR data.
The purpose of this notice is to provide you with an opportunity to familiarise yourself with our personal data processing rules. We will provide you with access to this notice when you submit your CV for employment. We will also provide access to those persons whose data has been provided to us by employees or candidates (e.g. relatives’ data, data of referees, etc.). EVELATUS Ltd reserves the right to amend and update this notice as necessary. This notice will provide you with a general overview of our processing activities and purposes, however, please note that other documents (e.g. Terms and Conditions of employment, employment contract, internal procedures and instructions) may also contain additional information about the processing of your personal data. We are aware that personal data is an asset for you and we will process it in a way that respects confidentiality requirements and takes care of the security of your personal data in our possession. |
3. For what purposes do we process your personal data and what is the legal basis? |
| We will only process your personal data in accordance with our predefined legitimate purposes, including:
3.1.1 For this purpose, we collect CVs from candidates, we contact the candidate and references identified by the candidate to collect references. With the candidate’s consent, we retain CVs for other competitions and, in order to be able to defend our interests in legal proceedings, we retain data to respond to claims and cases brought before the courts. 3.1.2 For this purpose, we may need at least the following personal data: – name, surname, contact details (e-mail, telephone number); – information on the candidate’s education and previous work experience; – information and contact details of persons who can provide references; – references of the candidate; – other information that may be relevant for the performance of the job and for identifying the most suitable candidate. 3.1.3 The main legal bases to be used to achieve these purposes are: – Consent (Article 6(1)(a) of the General Data Protection Regulation) to the fact of submitting a CV and to the retention of CVs for future competitions; – the conclusion of a contract with the data subject (Article 6(1)(b) of the GDPR) for the processing of the data of candidates for whom the decision to conclude an employment contract has been taken; – the performance of a legal obligation (Article 6(1)(c) of the GDPR) in certain cases for certain types of data where the legislation lays down minimum requirements for a specific job; – the legitimate interests of the controller (Article 6(1)(f) of the GDPR) in relation to the provision of evidence in the event of potential claims, as well as in relation to the minimum amount of information to be requested. 3.2.1.For this purpose, we will collect the information required to be included in the employment contract and its annexes, identify you, verify your qualifications, draw up the employment contract, provide you with an e-mail address for work purposes, assign you a user name to access the relevant information systems, and keep track of your working hours, the work you have done, in some cases, if necessary for the performance of your duties, we will share your job title and contact details with our business partners and clients and other employees, calculate and pay your wages to your nominated current account, check your health status and collect other information necessary for your employment. 3.2.2 For this purpose and for the sub-purposes set out above, we may need at least the following personal data: – Employee’s name, personal identification number; – home address, telephone number; – date of commencement of the employment relationship, place of work, position; – details of the employee’s education and qualifications; – description of the duties to be performed, position, remuneration; – evidence of performance of the duties, the employee’s appraisals, the employee’s state of health. 3.2.3 The main legal bases to be used to achieve these purposes are: – the conclusion of a contract with the data subject (Article 6(1)(b) of the General Data Protection Regulation); – the fulfilment of a legal obligation (Article 6(1)(c) GDPR) – in relation to the information to be reflected in the employment contract and the necessary qualification requirements; – the performance of the controller’s duties and the exercise of rights in the field of employment (Article 9(1)(b) of the GDPR) – for the processing of special categories of data (health data, trade union membership). 3.3.1 For this purpose, we would need to comply with the requirements of the Labour Law, the Labour Protection Law, the Accounting Law, the Archive Law and other laws and regulations. Also, in certain cases, we would be required to provide relevant information about you to public authorities (e.g. the State Revenue Service, the State Labour Inspectorate, bailiffs, investigative authorities, courts, supervisory authorities) on the basis of their statutory rights. 3.3.2 For this purpose, we may need to process the following personal data: – – any information about you requested by public authorities; – health data for the purposes of statutory health checks and accident investigations; – information about your trade union membership in the event of notice; – information on children (age, name) to ensure the granting of additional leave days, information on your activities as a donor to ensure the granting of a paid day, etc. information that the legislation requires to be collected. 3.3.3 The main legal bases used to achieve these purposes are: – Compliance with legal obligations (Article 6(1)(c) of the General Data Protection Regulation); – the performance of the controller’s obligations and the exercise of rights in the field of employment (Article 9(1)(b) GDPR) – for the processing of special categories of data (health data, trade union membership). 3.4.1 Within this purpose, we could provide you with various “social benefits”, such as the organisation of corporate events and promotions. Facilitating effective communication. For training and business trips. We could also collect information to tailor the working environment to you, we could inform other colleagues about your anniversaries, your absences and publish pictures of employer-organised events. 3.4.2 For this purpose, we might need at least the following personal data: information about important events in your life, your anniversaries, photos/videos from events, in some cases your health condition, to ensure an appropriate working environment, etc. 3.4.3 The main legal bases used to achieve these purposes are: – consent of the data subject (Article 6(1)(a) and 6(1)(f) of the General Data Protection Regulation) – e.g. for the publication of anniversaries, organisation of employee training, publication of photographs from events, provision of an appropriate working environment – the performance of the controller’s duties and the exercise of rights in the field of employment (Article 9(1)(b) of the General Data Protection Regulation) – for the processing of special categories of data (health data), e.g. to ensure an appropriate working environment. 3.5.1 For this purpose, we would need to carry out video surveillance of our premises, buildings and outlets; – use personal data processors for various functions; – exchange information within the group of companies where necessary; – to exercise the rights conferred by law or regulation for the purposes of their legitimate interests, to record working time, to record employee access to certain premises and information systems; – control the protection of our trade secrets and personal data of our customers, e.g. by controlling outgoing shipments, checking the performance of an employee’s duties, in certain cases transfer information about you to business partners or customers or potential customers (in the context of procurement), if this is necessary for us to be able to |
| provide our services and your work is related to the provision of those services, and we should retain data to protect ourselves in the event of employee claims against us, etc.
3.5.2 For this purpose, we may need to process at least the following personal data: – data contained in video recordings, data recorded by access control systems concerning visits to premises or connections to information systems, your name, title and contact details, in certain cases, the content of outgoing emails in the event of risks being identified, etc. 3.5.3 The main legal bases used to achieve these purposes are: – the legitimate interests of the controller (Article 6(1)(f) of the General Data Protection Regulation). |
4. Who would have access to your personal data? |
| We take appropriate measures to process your personal data in accordance with applicable law and to ensure that your personal data is not accessed by third parties who do not have an appropriate legal basis for processing your personal data.
Your personal data could be accessed as necessary: 1) our employees or directly authorised persons who need to do so for the performance of their duties, such as accountants, line managers or, if the data is public, all employees; 2) personal data processors in accordance with the services they provide and only to the extent necessary, e.g. auditors, financial management and legal consultants, database developer/technical maintainer, other persons involved in the provision of the controller’s services; 3) State and local authorities in cases provided for by law, e.g. law enforcement authorities, municipalities, tax authorities, bailiffs; 4. third parties, subject to a careful assessment of whether there is an appropriate legal basis for such transfers, such as debt collectors, courts, out-of-court dispute resolution bodies, bankruptcy or insolvency administrators, third parties maintaining registers (e.g. population register, debtors’ register, etc.), courts. |
5. Which partners in the processing of personal data or personal data processors do we choose? |
| We take appropriate measures to ensure the processing, protection and transfer of your personal data to data processors in accordance with applicable law. We carefully select our personal data processors and, when making a transfer, assess the need for the transfer and the amount of data to be transferred. Data transfers to processors are carried out in compliance with the requirements of confidentiality and secure processing of personal data.
We are currently able to cooperate in processing the following categories of personal data: 1) Auditors, financial management and legal consultants; 2) IT infrastructure, database owner/developer/technical maintainer; 3) Fleet management system maintainer (GPS data); 4) Other persons involved in the provision of our services. Personal data controllers may change from time to time and we will make changes to this document. |
6. Is your personal data transferred to countries outside the European Union (EU) or the European Economic Area (EEA)? |
| Taking into account the specific nature of its activities, EVELATUS Ltd. carries out, in certain cases (for example, for the purpose of processing a business trip), the transfer of information containing personal data to the data subjects concerned in third countries, after informing the data subject in advance of the possible risks associated with the transfer of personal data and obtaining the data subject’s consent. |
7. How long will we keep your personal data? |
| Your personal data will be kept for as long as its retention is necessary for the relevant purposes of the processing and in accordance with the requirements of applicable law.
When assessing the duration of storage of personal data, we take into account the requirements of applicable laws and regulations, the performance of contractual obligations, your instructions (e.g. in the case of consent) as well as our legitimate interests. If your personal data is no longer necessary for the purposes specified, we will delete or destroy it. We set out below the most common retention periods for personal data: 1. personal data necessary for the performance of an employment contract – we will keep until the contract is performed and until other retention periods are met (see below); 2. personal data that we need to keep in order to comply with legal requirements, we will keep in the relevant the time limits set out in the relevant laws and regulations, e.g. the Accounting Act provides that, that supporting documents must be kept until the date on which they are necessary to establish the existence of each the beginning of an economic transaction and to trace its progress, but not less than 5 years; whereas in the case of supporting documents relating to wages charged to employees, 10 or in certain cases, 75 years; 3. we will keep the data to prove compliance with our obligations for the general limitation period in accordance with the limitation periods for claims laid down in laws and regulations – 10 years Civil Code, 2 or 3 years (Labour Law) and in accordance with other time limits, taking into account also the time limits for bringing actions under the Civil Procedure Law and the Labour Law. |
8. What are your rights as a data subject in relation to the processing of your personal data? |
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If there are any changes to the personal data that you have provided to us, such as a change in your personal identification number, contact address, telephone number or email address, please contact us and provide us with the updated data so that we can achieve the relevant purposes of processing your personal data. In accordance with the provisions of the General Data Protection Regulation, you have the right to access your personal data held by us, to request its rectification, erasure, restriction of processing, to object to the processing of your data, as well as the right to data portability. We respect this right to access and control your personal data, so if we receive your request, we will respond to it within the time limits set out in the legislation (usually no later than one month, unless there is a specific request that requires more time to prepare a response) and, if possible, we will correct or delete your personal data accordingly. You may obtain information about your personal data held by us or exercise your other rights as a data subject in any of the following ways: 1) by submitting an application in person and identifying yourself at our office at 3 Ieriķu Street, Riga, LV-1084, Domina, Mon – Fri, 09:00 – 18:00 ; 2) by submitting an appropriate application by sending it to us by post to the following address; 3) by submitting an appropriate application by sending it to our e-mail address: info@evelatus.lv, signed with a secure electronic signature. Upon receipt of your submission, we will assess its content and the possibility of your identification, depending on the relevant situation, we reserve the right to ask you to further identify yourself in order to ensure the security and disclosure of your data to the appropriate person. If the processing of your personal data is based on your consent, you have the right to withdraw it at any time and we will no longer process your personal data that we processed on the basis of your consent for the relevant purpose. However, please be informed that the withdrawal of consent may not affect the processing of personal data which is necessary to comply with the requirements of laws and regulations or which is based on a contract, our legitimate interests or other grounds for lawful processing set out in laws and regulations. You may also object to the processing of your personal data if the processing is based on legitimate interests. |
9. Where can you lodge a complaint in relation to personal data processing issues? |
| If you have any questions or objections in relation to our processing of your personal data, please contact us in the first instance. If you believe that we have not been able to mutually resolve the issue and you believe that we have violated your right to the protection of personal data, you have the right to lodge a complaint with the Data Inspectorate. |
10. Why do you need to provide us with your personal data? |
| The information you provide is necessary for the performance of our contractual obligations, to comply with our legal obligations and to pursue our legitimate interests. In these cases, it is necessary for us to obtain certain information in order to achieve the relevant purposes, so failure to provide such information may jeopardise the start of the employment relationship or the performance of the contract. Where the data is not strictly necessary but its provision could help to improve the working environment or your employment conditions, we will indicate that the provision of the data is voluntary. |
11. How do we obtain your personal data? |
| 1. Information about the controller |
| The controller of personal data processing is SIA “EVELATUS”, unified registration No. 40003734912, legal address:Ainavas iela 2a – 14, Riga, LV-1084, contact information: e-mail: info@evelatus.lv, phone No.: +371 2233402 |
| If you have any questions regarding this notice or the processing of your personal data, please contact us via the communication channels indicated in the previous paragraph (1.1) or by contacting our employee at the following e-mail address: admin@evelatus.lv. |
| 2. General description of our processing of personal data |
| This notice describes how we carry out the processing of personal data of our employees, candidates, employees’ family members, contacts and other persons whose data may come into our possession in connection with the purposes of the processing of HR data.
The purpose of this notice is to provide you with an opportunity to familiarise yourself with our personal data processing rules. We will provide you with access to this notice when you submit your CV for employment. We will also provide access to those persons whose data has been provided to us by employees or candidates (e.g. relatives’ data, data of referees, etc.). EVELATUS Ltd reserves the right to amend and update this notice as necessary. This notice will provide you with a general overview of our processing activities and purposes, however, please note that other documents (e.g. Terms and Conditions of employment, employment contract, internal procedures and instructions) may also contain additional information about the processing of your personal data. We are aware that personal data is an asset for you and we will process it in a way that respects confidentiality requirements and takes care of the security of your personal data in our possession. |
| 3. For what purposes do we process your personal data and what is the legal basis? |
| We will only process your personal data in accordance with our pre-defined legitimate purposes, including:
3.1. for the purpose of the recruitment process and the exercise of the rights and obligations arising therefrom. 3.1.1 As part of this purpose, we collect CVs from candidates, we contact the candidate and references identified by the candidate to collect references. With the candidate’s consent, we retain CVs for other competitions and, in order to be able to defend our interests in legal proceedings, we retain data to respond to claims and cases brought before the courts. 3.1.2 For this purpose, we may need at least the following personal data: – name, surname, contact details (e-mail, telephone number); – information on the candidate’s education and previous work experience; – information and contact details of persons who can provide references; – references of the candidate; – other information that may be relevant to the performance of the job and to the identification of the most suitable candidate. 3.1.3 The main legal bases to be used to achieve these purposes are: – Consent (Article 6(1)(a) of the General Data Protection Regulation) to the fact of submitting a CV and to the retention of CVs for future competitions; – the conclusion of a contract with the data subject (Article 6(1)(b) of the GDPR) for the processing of the data of candidates for whom the decision to conclude an employment contract has been taken; – the performance of a legal obligation (Article 6(1)(c) of the GDPR) in certain cases for certain types of data where the legislation lays down minimum requirements for a specific job; – the legitimate interests of the controller (Article 6(1)(f) of the GDPR) in relation to the provision of evidence in the event of potential claims, as well as in relation to the minimum amount of information to be requested. 3.2 For the conclusion and performance of an employment contract. 3.2.1.For this purpose, we will collect the information required to be included in the employment contract and its annexes, identify you, verify your qualifications, execute the employment contract, provide you with an e-mail address for work purposes, assign you a user name to access the relevant information systems, keep records of your working hours, the work you have done, in some cases, if necessary for the performance of your duties, we will share your job title and contact details with our business partners and clients and other employees, calculate and pay your wages to your nominated current account, check your health status and collect other information necessary for your employment. 3.2.2 For this purpose and for the sub-purposes set out above, we may need at least the following personal data: – Employee’s name, personal identification number; – home address, telephone number; – date of commencement of the employment relationship, place of work, position; – details of the employee’s education and qualifications; – description of the duties to be performed, position, remuneration; – evidence of performance of the duties, the employee’s appraisals, the employee’s state of health. 3.2.3 The main legal bases to be used to achieve these purposes are: – the conclusion of a contract with the data subject (Article 6(1)(b) of the General Data Protection Regulation); – the fulfilment of a legal obligation (Article 6(1)(c) GDPR) – in relation to the information to be reflected in the employment contract and the necessary qualification requirements; – the performance of the controller’s duties and the exercise of rights in the field of employment (Article 9(1)(b) of the GDPR) – for the processing of special categories of data (health data, trade union membership). 3.3. Compliance with statutory requirements relating to employment or with requirements laid down in other laws and regulations: 3.3.1 For this purpose, we would need to comply with the requirements of the Labour Law, the Labour Protection Law, the Accounting Law, the Archive Law and other statutory requirements. Also, in certain cases, we would be required to provide relevant information about you to public authorities (e.g. the State Revenue Service, the State Labour Inspectorate, bailiffs, investigative authorities, courts, supervisory authorities) on the basis of the rights of public authorities under the laws and regulations. 3.3.2 For this purpose, we may need to process the following personal data: – – any information about you requested by public authorities; – health data for the purposes of statutory health checks and accident investigations; – information about your trade union membership in the event of notice; – information on children (age, name) to ensure the granting of additional leave days, information on your activities as a donor to ensure the granting of a paid day, etc. information that the legislation requires to be collected. 3.3.3 The main legal bases used to achieve these purposes are: – Compliance with legal obligations (Article 6(1)(c) of the General Data Protection Regulation); – the performance of the controller’s obligations and the exercise of rights in the field of employment (Article 9(1)(b) GDPR) – for the processing of special categories of data (health data, trade union membership). 3.4 Ensuring social conditions and an appropriate working environment for employees: 3.4.1 For this purpose, we could provide you with various “social benefits”, such as the organisation of corporate events and promotions. Facilitating effective communication. Organising staff training and business trips. We could also collect information to tailor the working environment to you, we could inform other colleagues about your anniversaries, your absences and publish pictures of employer-organised events. 3.4.2 For this purpose, we might need at least the following personal data: information about important events in your life, your anniversaries, photos/videos from events, in some cases your health condition, to ensure an appropriate working environment, etc. 3.4.3 The main legal bases used to achieve these purposes are: – consent of the data subject (Article 6(1)(a) and 6(1)(f) of the General Data Protection Regulation) – e.g. for the publication of anniversaries, organisation of employee training, publication of photographs from events, provision of an appropriate working environment – the performance of the controller’s duties and the exercise of rights in the field of employment (Article 9(1)(b) of the General Data Protection Regulation) – for the processing of special categories of data (health data), e.g. to ensure an appropriate working environment. 3.5 Prevention of threats to security, pecuniary interests and other important legitimate interests of ours or third parties: 3.5.1 For this purpose, we would need to carry out video surveillance of our premises, buildings and outlets; – use personal data processors for various functions; – exchange information within the group of companies where necessary; – to exercise the rights conferred by law or regulation for the purposes of their legitimate interests, to record working time, to record employee access to certain premises and information systems; – control the protection of our trade secrets and personal data of our customers, e.g. by controlling outgoing shipments, checking the performance of an employee’s duties, in certain cases transfer information about you to business partners or customers or potential customers (in the context of procurement), if this is necessary for us to be able to |
| provide our services and your work is related to the provision of those services, and we should retain data to protect ourselves in the event of employee claims against us, etc.
3.5.2 For this purpose, we may need to process at least the following personal data: – data contained in video recordings, data recorded by access control systems concerning visits to premises or connections to information systems, your name, title and contact details, in certain cases, the content of outgoing emails in the event of risks being identified, etc. 3.5.3 The main legal bases used to achieve these purposes are: – the legitimate interests of the controller (Article 6(1)(f) of the General Data Protection Regulation). |
| 4. Who would have access to your personal data? |
| We take appropriate measures to process your personal data in accordance with applicable law and to ensure that your personal data is not accessed by third parties who do not have an appropriate legal basis for processing your personal data.
Your personal data could be accessed as necessary: 1) our employees or directly authorised persons who need to do so for the performance of their duties, such as accountants, line managers or, if the data is public, all employees; 2) personal data processors in accordance with the services they provide and only to the extent necessary, e.g. auditors, financial management and legal consultants, database developer/technical maintainer, other persons involved in the provision of the controller’s services; 3) State and local authorities in cases provided for by law, e.g. law enforcement authorities, municipalities, tax authorities, bailiffs; 4. third parties, subject to a careful assessment of whether there is an appropriate legal basis for such transfers, such as debt collectors, courts, out-of-court dispute resolution bodies, bankruptcy or insolvency administrators, third parties maintaining registers (e.g. population register, debtors’ register, etc.), courts. |
| 5. Which partners in the processing of personal data or personal data processors do we choose? |
| We take appropriate measures to ensure the processing, protection and transfer of your personal data to data processors in accordance with applicable law. We carefully select our personal data processors and, when making a transfer, assess the need for the transfer and the amount of data to be transferred. Data transfers to processors are carried out in compliance with the requirements of confidentiality and secure processing of personal data.
We are currently able to cooperate in processing the following categories of personal data: 1) Auditors, financial management and legal consultants; 2) IT infrastructure, database owner/developer/technical maintainer; 3) Fleet management system maintainer (GPS data); 4) Other persons involved in the provision of our services. Personal data controllers may change from time to time and we will make changes to this document. |
| 6. Is your personal data transferred to countries outside the European Union (EU) or the European Economic Area (EEA)? |
| Taking into account the specific nature of its activities, EVELATUS Ltd. carries out, in certain cases (for example, for the purpose of processing a business trip), the transfer of information containing personal data to the data subjects concerned in third countries, after informing the data subject in advance of the possible risks associated with the transfer of personal data and obtaining the data subject’s consent. |
| 7. How long will we keep your personal data? |
| Your personal data will be kept for as long as its retention is necessary for the relevant purposes of the processing and in accordance with the requirements of applicable law.
When assessing the duration of storage of personal data, we take into account the requirements of applicable laws and regulations, the performance of contractual obligations, your instructions (e.g. in the case of consent) as well as our legitimate interests. If your personal data is no longer necessary for the purposes specified, we will delete or destroy it. We set out below the most common retention periods for personal data: 1. personal data necessary for the performance of an employment contract – we will keep until the contract is performed and until other retention periods are met (see below); 2. personal data that we need to keep in order to comply with legal requirements, we will keep in the relevant the time limits set out in the relevant laws and regulations, e.g. the Accounting Act provides that, that supporting documents must be kept until the date on which they are necessary to establish the existence of each the beginning of an economic transaction and to trace its progress, but not less than 5 years; whereas in the case of supporting documents relating to wages charged to employees, 10 or in certain cases, 75 years; 3. we will keep the data to prove compliance with our obligations for the general limitation period in accordance with the limitation periods for claims laid down in laws and regulations – 10 years Civil Code, 2 or 3 years (Labour Law) and in accordance with other time limits, taking into account also the time limits for bringing actions under the Civil Procedure Law and the Labour Law. |
| 8. What are your rights as a data subject in relation to the processing of your personal data? |
| Update of personal data.
If there are any changes to the personal data you have provided to us, such as a change in your personal identification number, contact address, telephone number or email address, please contact us and provide us with the updated data so that we can achieve the relevant purposes of processing your personal data. Your right to access your personal data. In accordance with the provisions of the General Data Protection Regulation, you have the right to access your personal data held by us, to request its rectification, erasure, restriction of processing, to object to the processing of your data, as well as the right to data portability. We respect this right to access and control your personal data, so if we receive your request, we will respond to it within the time limits set out in the legislation (usually no later than one month, unless there is a specific request that requires more time to prepare a response) and, if possible, we will correct or delete your personal data accordingly. You may obtain information about your personal data held by us or exercise your other rights as a data subject in any of the following ways: 1) by submitting an application in person and identifying yourself at our office: 372 Brīvības gatve, t/p ALFA, every day 10:00-22:00; 2) by submitting the relevant application by post to us at the following address: 2a-14 Aivavas Street, Riga, LV-1084; 3) by submitting an appropriate application by sending it to our e-mail address: admin@evelatus.lv, signed with a secure electronic signature. Upon receipt of your submission, we will assess its content and the possibility of identifying you, depending on the relevant situation, we reserve the right to ask you to further identify yourself in order to ensure the security and disclosure of your data to the relevant person. Withdrawal of consent. If the processing of your personal data is based on your consent, you have the right to withdraw it at any time and we will no longer process your personal data that we processed on the basis of your consent for the relevant purpose. However, please be informed that the withdrawal of consent may not affect the processing of personal data which is necessary to comply with the requirements of laws and regulations or which is based on a contract, our legitimate interests or other grounds for lawful processing set out in laws and regulations. You may also object to the processing of your personal data if the processing is based on legitimate interests. |
| 9. Where can you lodge a complaint in relation to personal data processing issues? |
| If you have any questions or objections in relation to our processing of your personal data, please contact us in the first instance. If you believe that we have not been able to mutually resolve the issue and you believe that we have violated your right to the protection of personal data, you have the right to lodge a complaint with the Data Inspectorate. |
| 10. Why do you need to provide us with your personal data? |
| The information you provide is necessary for the performance of our contractual obligations, to comply with our legal obligations and to pursue our legitimate interests. In these cases, it is necessary for us to obtain certain information in order to achieve the relevant purposes, so failure to provide such information may jeopardise the start of the employment relationship or the performance of the contract. Where the data is not strictly necessary but its provision could help to improve the working environment or your employment conditions, we will indicate that the provision of the data is voluntary. |
| 11. How do we obtain your personal data? |
| We may obtain your personal data in one of the following ways:
1) from you, by submitting an application and CV to us for a vacancy; 2) in the process of entering into a contract with each other, by obtaining the data from you; 3. if the contract is concluded with a third party who has identified you as a family member; 4) from you if you make any submissions, e-mails, calls to us; 5) in certain cases from third party databases, for example when assessing your creditworthiness, we may obtain data from third parties for this purpose; 6) where appropriate, from CCTV footage and access control systems; 7) where applicable, from doctors as a result of medical examinations. |
Annex 2
CERTIFICATE for data processing
I, the name, surname, personal code ofthe limited liability company “EVELATUS”
I certify that in the performance of my duties I will process (i.e. any operation performed on personal data, including collection, recording, input, storage, organisation, alteration, use, transfer, transmission and disclosure, blocking or erasure) personal data (i.e. any information relating to an identified or identifiable natural person) in accordance with the General Data Protection Regulation and other laws and regulations on the protection of personal data.
In view of the above, I undertake, within the scope of my duties, to ensure that all appropriate safeguards are in place to ensure the confidentiality of information and personal data to which I have access in the performance of my duties and, more specifically, to ensure that the above information is not accessed by persons who are not authorised or entitled to obtain such information and personal data.
Subject to, but not limited to, the rules on the protection of personal data, I undertake to:
1. to use personal data only for purposes related to my direct job responsibilities.
2. to disclose the information and personal data in my possession only to persons authorised and entitled to receive them.
3. not to disclose personal data and information acquired after the termination of the employment relationship and which has come to my knowledge in the performance of my duties, unless the obligation to disclose such information is imposed on me by the legislation of the Republic of Latvia.
4. not to make copies of any information or personal data except as necessary for the performance of my duties.
5. not to take any action that would facilitate the unlawful processing of personal data, including disclosure to, or placing in the possession of, a third party.
6. Not to disclose to third parties the unique user name and password (crypto-key) provided to me by my employer.
7. immediately report unlawful attempts to obtain personal data and other information that I have access to in the course of my employment, as well as security incidents (harmful events or acts that compromise the integrity, availability or confidentiality of information technology) and personal data breaches (a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed).
8. use all appropriate organisational and technical safeguards to secure personal data and other information against unlawful use and processing and to ensure the physical and logical protection of information and personal data.
9. use only secure means and channels of communication for the transmission, transfer and disclosure of personal data and other information within the scope of their duties.
10. to return all information and personal data, data files, data media in my possession and acquired in the course of my duties at the end of my duties.
This acknowledgement will continue to apply without any limitation beyond the duration of my employment, regardless of the reasons for the termination of the employment relationship, as the obligations referred to in the acknowledgement relate to the processing and protection of information and personal data.
By signing this declaration, I certify that:
1. I am aware that I may be held liable in accordance with the procedure laid down by the laws and regulations for unlawful disclosure, transfer or loss of personal data and information and for other breaches of the measures for the protection of such information and breaches of the confidentiality of personal data and information referred to in this declaration;
2. I am aware of the legal framework governing the processing and protection of personal data.
20___ _________._____________ ____________________
(signature)
Annex 3
Information to be included in the notice
Based on Article 13 of 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 and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter “GDPR”),
EVELATUS Ltd. informs that:
1) The personal data provided in your application documents will be processed for the purposes of this selection procedure;
2) The controller of the above-mentioned processing of your personal data is the Limited Liability Company “EVELATUS”, Ainavas iela 2a-14, Riga, LV-1084.You can obtain additional information referred to in Article 13 of the GDPR on the website of SIA “EVELATUS” https://m.ss.lv/msg/ru/work/ar…
RESTRICTED INFORMATION
Annex 4
List of CCTV cameras
APPROVE:
of the Limited Liability Company “EVELATUS”
The Board of Directors
____________________vārds uzvārds
2021 ____February
| No. p.k. | ||||
| 1. | Address, Riga, LV-0000, Cadastre No. 000000000000000, (Administration building TC DOMINA) | 4 | 0 | 9 |
| 1 | 2 | 3 | 4 | 5 | 6 | 7 | 8 | 9 |
| 1. | ||||||||
| 1.1. | ||||||||
| 1.1.1. | ||||||||
| 1.1.1.1. |
Located on the ceiling, opposite the entrance door. Room at an angle of view: main entrance door. |
Make of camera (dome camera or conventional, with or without voice recording function). 2. Recording is done continuously or when there is movement. 3. The set angle of the CCTV is not automatically changed, or anyone can change the angle. Zoom in on the image, etc. | Where is the monitor installed (in security premises) | (Persons being filmed. i.e. employees, customers, etc.) | Server room | Who is looking at the monitor, | The person who accesses the system with the right to copy or delete recordings. | 30 days |
Annex 5
Flow chart for documents containing personal data
Physical documents containing data:
1.1. leasing documents
1.2. Repair receipt
1.3 Receipts
1.4 Applications
1.5 Other documents
2. All documents referred to in paragraph 1 shall be kept in a place inaccessible to unauthorised persons.
Each shop has a designated place for documents, for example, 
3. Documents are delivered to the warehouse/office in 2 ways:
3.1. by putting everything in an opaque bag and handing it over to the courier. 
3.2. packed in a box and sent by courier service.
4. Bags and boxes are unpacked by 1 designated employee, in a designated place, under a camera. 
5. All documents are handed over to the accounting staff without being moved.
6. Accounting staff process data that are wheezing:
6.1. the date of the document
6.2. document number
6.3 Document amount
6.4. the details of the customers named on the voucher
7. All documents containing data of natural persons shall be stored in a locked cabinet with restricted access. 
8. All physical documents containing personal data of staff members shall be handed over to the person responsible, who shall store them in a locked cabinet with restricted access.

9. All requests for physical data shall be recorded in a “Personal Data Request Log”
Annex 6
Log of requests for personal data

Annex 7
| Annex 7 | |||
| APPROVED BY: | |||
| Members of the Board of EVELATUS Ltd. | |||
| Svetlana Ģērmane | |||
| Viktorija Ustinova | |||
| ____ February 2021 | |||
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