Privacy Policy

1. Introduction
HAGBERG Limited Liability Company, registration No. 40103233073, legal address: “Ozolkalni B”, Mārupe Municipality, LV-2167 (hereinafter - the Manager), on the website www.hagberg.lv (hereinafter - the Site) processes personal data obtained from the data subject - Site user (hereinafter - the User).
The Manager takes care of the User's privacy and protection of personal data, observes the User's right to the lawfulness of personal data processing in accordance with the applicable legislation, Regulation (EU) 2016/679 of the European Parliament and the Council on the protection of individuals with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46 / EC (General Data Protection Regulation), hereinafter – the Regulation and other applicable privacy and data processing legislation. 
In view of the above, the Manager has developed this privacy policy to provide the User with the information required by the Regulation.
The Privacy Policy applies to the processing of data, regardless of the form and/ or environment in which the User provides personal data (on the Site, in paper format, or by telephone).

2. Manager’s identity and contact details
The Manager is the Limited Liability Company “HAGBERG”, registration No. 40103233073, legal address: “Ozolkalni B”, Mārupe Municipality, LV-2167, Website: www.hagberg.lv, e-mail: info@hagberg.lv, phone: +371 25738833.

3. Contact information of the data protection specialist
The data protection specialist of the Manager is Lauris Klagišs (lauris.klagiss@gmail.com, phone: + 371 29470425).

4. Purposes of processing
The Manager processes the following personal data for the following purposes:
4.1. Provision of services;
4.2. Customer identification;
4.3. Preparation, conclusion, and execution of a contract with customers;
4.4. Real estate management; settlement administration; debt collection, for reviewing customer   objections;
4.5. For the provision of information at the level of public administration and in the cases and to the extent specified in the regulatory enactments of the subject of operational activities;
4.6. Personnel management, including personnel selection; conclusion and performance of an employment contract; working time accounting; ensuring the calculation of wages and the performance of wages; fulfillment of accounting requirements (execution of relevant justification documents, execution of business trip); provision of social benefits for employees (health insurance); recording and control of the performance of work duties;
4.7. To meet the requirements of accounting, record keeping, and other regulatory enactments;
4.8. For the implementation of the legitimate interests of the Manager;
4.9. For quality control (The Manager records telephone conversations to ensure and improve the quality of consultations);
4.10. To promote customer loyalty, satisfaction measurements.
The purposes of data processing referred to in the Privacy Policy are indicative and personal data, which may also be processed for purposes not directly mentioned for purposes that are closely related to the previous instructions and the fulfillment of the requirements of the necessary regulatory enactments.

5. Categories of personal data
The categories of personal data processed by the Manager depend on the purposes and type of data processing:
Purpose of personal data processing:
5.1. Data required for real estate management and administration: name, surname, personal identification code (other personal identification number), name, surname, personal identification code (other personal identification number) of the authorized person, contact information (telephone number, electronic address, postal address, IP address) , data on real estate owned by a natural person (address, cadastral number, area, date and legal basis of acquisition of ownership/ use rights, date of termination of ownership/ use rights), declared and actual address of residence, information on the bank account, contract number, date of registration of the contract, time of provision of management activities, number of persons declared as property, water, electricity, heat, gas, etc. amount of consumption, information on settlements (invoice number, date, amount, method of receiving the invoice, date of payment, amount of debt, information on debt recovery.
5.2. For staff selection and staff management: the information included in the candidate's CV as well as the candidate's own, information provided by employees; name, surname, personal identification number, address, telephone number, e-mail address, position, salary, hours worked, bank account number, periods of absence, number of children and years of birth, work experience, information on education and qualifications, language skills, etc. information containing personal data related to personnel management. Employment and career history, health information (compulsory health check data, incapacity sheets), training, ethical breaches, etc.

6. Legal basis for personal data processing
The legal basis for data processing is:
6.1. with the consent of the User (Article 6 (1) (a) of the Regulation);
6.2. processing is necessary for the performance of a contract with the data subject (employees, customers) or for taking action at the request of the data subject before the conclusion of the contract (Article 6 (1) (b) of the Regulation);
6.3. in cases where the processing is necessary for the exercise or defense of a legitimate interest of the Manager before a court (Articles 6 (1) (f) and 9 (2) (f) of the Regulation);
6.4. assessment of the employee's ability to work (Article 9 (2) (h) of the Regulation);
6.5. in cases where processing is necessary to safeguard the legitimate interests of the Manager, to organize an efficient service delivery process (e.g. recording of telephone conversations to ensure and improve the quality of advice, handling of complaints, improving the quality of service provision), receiving payment for services provided) (Article 6 (1) (f) of the Regulation). The maximum storage period for telephone records is 6 months. The Manager ensures the recording and confidentiality of conversation records;
6.6. processing is necessary for compliance with a legal obligation to which the Manager is subject (Article 6 (1) (c) of the Regulation).

7. Categories of recipients of personal data
The data shall be disclosed to those employees of the Manager who need them for the performance of their direct duties in order to perform or enter into the relevant service contract.
When acquiring and using personal data, the Manager partially uses the services of external service providers (e.g. server, mail, archiving, IT marketing, security, debt collection service providers) with whom personal data protection agreements have been concluded in accordance with Article 28 of the Regulation. 
Data may also be transferred to bailiffs, notaries, lawyers, lawyers, consultants, auditors, brokers, insurers, credit institutions, law enforcement agencies, courts, public service providers and other authorities.

8. Categories of data subjects
Categories of data subjects - existing, past and potential customers of the Manager.

9. Data transfer outside Latvia
The received data is not and will not be transferred outside Latvia, the European Union or the European Economic Area, as well as will not be transferred to any international organization.

10. Automated decision making
The Manager does not and does not intend to make automated decisions regarding data subjects.

11. Duration of data storage
The Manager shall keep the personal data for no longer than is necessary for the purpose for which the personal data are processed.
Personal data is stored as long as one of the parties has a legal obligation to store the data, or as long as the data subject or the Manager can exercise its legitimate interests (e.g. review of claims, protection of rights, settlement of issues, legal action or limitation etc.);
All information obtained during the recruitment competition will be stored, in whole or in part, for a maximum of 6 months in order to safeguard the Manager's legal interests. If that the Manager receives complaints about a particular recruitment process, all information processed during the recruitment process will be retained for as long as necessary for that particular process.
For quality control and improvement, the Manager shall keep records of telephone conversations, of which each data subject shall be informed. Personal data is stored for 31 days from the date of execution.
At the end of the storage period, personal data will be permanently deleted, unless there is an obligation to store them in accordance with regulatory enactments.
The storage of personal data for a longer period may be carried out if this is necessary for the Manager to ensure the protection of his rights about to claims or the data are necessary for the proper handling of a dispute or complaint.
Unless otherwise stated in the data protection instructions, the Manager deletes personal data no later than three months after the original reason for retention no longer applies, unless we have a legal obligation to continue to retain the data (for example, but not limited to, home, accounting or litigation purposes).

12. Data subject's access to personal data
The data subject has the right to access the personal data of the data subject within one month from the date of submission of the relevant request.
The User may submit a request for the exercise of their rights in writing in person, at the legal address of the Manager (upon presentation of an identity document) or by e-mail, signing with a secure electronic signature.
Upon receipt of the User's request for the exercise of their rights, the Manager verifies the User's identity, evaluates the request and executes it in accordance with regulatory enactments.
The User has the right to receive the information specified in regulatory enactments in connection with the processing of their data, the right to request access to their data, as well as to request the Manager to supplement, correct or delete them, restrict processing or the right to object to processing (conclusion or performance of contracts).
The data subject does not have the right to receive information if it is prohibited to disclose this information in accordance with regulatory enactments in the field of national security, national defense, public security, criminal law, as well as to ensure public financial interests in tax matters or supervision and macroeconomic analysis of financial market participants.

13. Right to complain to the supervisory authority
The Data Subject has the right to submit a complaint to the Supervisory Authority (State Data Inspectorate) at Blaumaņa Street 11/13, Riga, the Data State Inspectorate also accepts e-mails received to the e-mail address: info@dvi.gov.lv. 

14. Changes to the Privacy Policy
The Manager reserves the right to make changes to this Privacy Policy if certain circumstances change that will affect the processing of personal data. The manager recommends visiting this section regularly for up-to-date information.