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SIA HOKEJAM.LV Privacy Policy

 

Controller and its contact information

The controller of personal data processing is SIA HOKEJAM.LV (hereinafter — HOKEJAM.LV), uniform registration No. 40103334883, Legal address: Dienvidu 3/2-17, Salaspils, LV-2169.

You can ask about the processing of personal data using the contact information or contact HOKEJAM.LV in a legal address. An application for the exercise of your rights may be submitted in accordance with the procedures set out herein. 

Scope of application of the document

Personal data is any information that relates to an identified or identifiable natural person — a client, a cooperation partner or its employee, or a job candidate of HOKEJAM.LV — concerning their name, surname, personal identification number, place of residence, personal telephone number, personal email, occupation, amount of income, received services, billing information, telephone, electronic communications information and other information related to a natural person.

Privacy policy is applied to ensure the privacy and personal data protection in respect of:

• natural persons — customers and other service users (including potential, former and existing ones) and third parties that receive or transfer any information related to provision of services to a natural person (customer, user) to HOKEJAM.LV (including contacts, payers, etc.);

• visitors of HOKEJAM.LV shops, offices and other premises, including for which video surveillance is carried out;

• visitors of webpages and mobile applications maintained by HOKEJAM.LV (hereinafter — Customers).

HOKEJAM.LV takes care of the privacy of Customers and the protection of personal data, respects the rights of Customers to the lawfulness of the processing of personal data in accordance with applicable laws — laws of the Republic of Latvia and subordinate legislation, Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of of natural persons with regard to the processing of personal data and on the free movement of such data (Regulation) and other applicable legislation in the field of privacy and data processing.

The Privacy Policy applies to data processing regardless of the form and/or environment in which the Customer provides personal data (HOKEJAM.LV webpage, mobile applications, in paper or electronic format) and the systems or paper form the data are processed in.

The purposes of personal data processing

HOKEJAM.LV processes personal data for the following purposes:

• For the provision of services and the sale of goods:

- to identify the customer;

- to prepare and conclude a contract;

- to deliver goods and provide warranty (to fulfill the contractual obligations);

- to ensure/maintain the services;

- to fulfill the warranty obligations;

- to improve the goods and services, and develop new goods and services;

- to promote the use of the services;

- to advertise and distribute the services for commercial purposes;

- to serve the customers;

- to examine and process the objections;

- to retent the customers, promote their loyalty, and measure their satisfaction;

- to administrate the transactions;

- to recover and collect the debts;

- to maintain the websites and mobile applications and improve their performance.

For business planning and analytics:

- statistics and business analysis;

- planning and accounting;

- to measure the efficiency;

- to ensure data quality;

- for market and public opinion studies;

- to prepare the reports;

- for customer surveys;

- within risk management activities.

• To provide information to public administration and subjects of operational activities in cases and extent specified in external regulatory enactments.

• Video surveillance is used for the safety of HOKEJAM.LV property and individuals, for prevention of theft and fraudulent activities at the HOKEJAM.LV office and shops, and for fixing of a criminal offence as well as the identification of alleged offenders. Data is stored in video surveillance for up to 30 days. After the expiry of this deadline, HOKEJAM.LV ensures that the data are automatically erased if the data have not been requested in advance or that no criminal offences have been detected. Where data have been requested in advance from competent national or local authorities or criminal offences have been detected, data are stored as required.

• For other specific purposes for which the Customer is informed when they provide relevant data to HOKEJAM.LV.

Legal basis for processing personal data

HOKEJAM.LV processes the Customer’s personal data based on the following legal bases:

• the conclusion and fulfilment of the contract, in order to conclude the contract upon the Customer’s request and to ensure its fulfilment;

• enforcement of regulations — to fulfill the obligation laid down in external regulatory enactments binding for HOKEJAM.LV;

• according to the consent of the Customer —data subject;

• legal (legitimate) interests — to fulfill the legal (legitimate) interests arising from an existing commitment  or contract concluded between HOKEJAM.LV and the Customer, or interests arising from the law.

The legal (legitimate) interests of HOKEJAM.LV are:

• to carry out commercial activities;

• to offer quality and tested IT products and solutions;

• to verify the identity of the Customer prior to the conclusion of the contract;

• to ensure the fulfilment of the contractual obligations;

• to prevent unjustified financial risks for its commercial activities (including the credit risk assessment prior to the sale of goods and services and during the execution of the contract);

• to retain Customers’ requests and applications for the provision of purchases of goods and services, other requests and applications, remarks about them, including those, that are made orally, via telephone and on websites;

• to analyze the performance of HOKEJAM.LV webpages, websites and mobile applications, to develop and implement the improvements;

• to administer the Customer’s account in HOKEJAM.LV websites, websites and mobile applications;

• to take action related to retention of the Customers;

• to segment the Customers’ database for provision of more efficient services;

• to design and develop services;

• to advertise its goods and services by sending commercial information;

• to send other reports on the progress of the contract execution and events relevant to the execution of the contract, and to conduct Customer surveys on goods and services and the usage experience;

• to prevent fraud;

• to ensure corporate governance, financial and business accounting and analysis;

• to ensure effective business management processes;

• to ensure the efficiency of services and sales of goods and delivery;

• to ensure and improve the quality of services;

• to administer payments;

• to administer payments not made;

• to turn to national regulatory and operations authorities and in court for the protection of its legal interests;

• to inform the public about its activities.

Processing of personal data

HOKEJAM.LV processes the Customer’s data using capabilities of the modern technologies, taking into account existing privacy risks and organisational, financial and technical resources reasonably available to HOKEJAM.LV.

HOKEJAM.LV, in respect to the Customer, may take automated decisions. The Customer shall be informed individually about such activities of HOKEJAM.LV in accordance with laws and regulations. The Customer may object to automated decision-making in accordance with the legislation, however, recognizing that in certain cases it may restrict the Customer's right to use individual options potentially available to them (for example, to receive commercial offers).

To ensure qualitative and operative enforcement of contractual obligations concluded with the Customer, HOKEJAM.LV may authorise companies of HOKEJAM.LV group, its cooperation partners to carry out individual supplies of goods or services, such as delivery of goods, warranty service, sending invoices, etc.). If the companies of HOKEJAM.LV group or its cooperation partners are processing Customer’s personal data held by HOKEJAM.LV while performing these tasks, the relevant companies of HOKEJAM.LV group or cooperation partners are considered to be HOKEJAM.LV’s data processors, and HOKEJAM.LV has the right to transfer Customer’s data to the companies of HOKEJAM.LV group and its cooperation partners to the extent necessary for the performance of these activities.

HOKEJAM.LV cooperation partners and companies of HOKEJAM.LV group (in their capacity as data processors) will ensure the enforcement of personal data processing and protection requirements in accordance with HOKEJAM.LV requirements and legislation and will not use personal data for other purposes other than the execution of contractual obligations concluded with the Customer on behalf of HOKEJAM.LV.

 

Personal data protection

HOKEJAM.LV protects the Customer’s data using capabilities of the modern technologies, taking into account existing privacy risks and organisational, financial and technical resources reasonably available to HOKEJAM.LV, including the use of the following safety measures:

• pseudonymization of data;

• firewall;

• intrusion protection and detection programmes;

• other protective measures according to the current technological development possibilities.

Since HOKEJAM.LV service does not know what apps and programs are installed on the damaged device and works or can operate online with the Internet during the repair of the defective product (device), HOKEJAM.LV cannot predict where and which information will be transferred to third parties at the time of activation of the defective device, and HOKEJAM.LV does not take responsibility and does not guarantee the security and saving of data and information, accordingly. HOKEJAM.LV does not collect and otherwise process data stored in a defective device.

 

Categories of personal data recipients

HOKEJAM.LV does not disclose to third parties the customer's personal data or any information obtained during the provision of services and during validity period of contract, except:

• if the third party concerned has to transfer the data within the framework of a contract to carry out any function necessary for fulfilment of the contract or delegated by law (for example, within the framework of bank payments or in a guarantee service, goods that HOKEJAM.LV service is not authorized to repair are delivered to the authorised service centre of the relevant manufacturer);

• in accordance with a clear and unambiguous consent of the Customer;

• the persons prescribed by external regulatory enactments at their reasonable request in accordance with the procedures and in the amount stipulated by external regulatory enactments;

• in certain cases stated in external regulatory enactments, as well as for protection of HOKEJAM.LV legitimate interests, such as seeking a judicial remedy or turning to other state institutions against a person who has violated HOKEJAM.LV’s legitimate interests.

 

Access to personal data by third-country subjects

HOKEJAM.LV personal data cannot be accessed by developers or service providers (within the meaning of the Regulation — transfers to third countries) in a data processor (operator) status in third countries (i.e., countries outside European Union and European Economic Area).

 

Duration of personal data storage

HOKEJAM.LV stores and handles customer personal data while at least one of the following criteria exists:

• only as long as the contract concluded with the Customer is in force;

• while HOKEJAM.LV or the Customer may pursue their legitimate interests (for example, to lodge objections or to raise or bring claims in court) in accordance with the procedures prescribed by external regulatory enactments;

• while one of the parties has a legal obligation to store the data;

• while the Customer's consent to the relevant processing of personal data is valid, if there is no other legitimate basis for data processing.

The Customer's personal data is deleted, once these grounds no longer prevail.

 

Access to personal data and other Customer’s rights

The Customer has the right to receive the information specified in regulatory enactments regarding the processing of their data, to ensure the accuracy of their data and ability to correct them.

The Customer also has the right to request access from HOKEJAM.LV to their personal data in accordance with regulatory enactments and to request HOKEJAM.LV to supplement, rectify or delete them or to restrict the processing with respect to the Customer, or the right to object to processing (including the processing of personal data based on the legitimate (legitimate) interests of HOKEJAM.LV) and the right to data portability. These rights are implemented in so far as the processing of data does not derive from the HOKEJAM.LV obligations imposed on it by the laws and regulations in force and which are carried out in the public interest.

The Customer may submit a request for the exercise of their rights:

• in a written form at the HOKEJAM.LV office/shop presenting an identity document;

• while HOKEJAM.LV or the Customer may pursue their legitimate interests (for example, to lodge objections or to raise or bring claims in court) in accordance with the procedures prescribed by external regulatory enactments;

• by electronic mail, signing it with a secure electronic signature;

Upon receiving of a Customer's request for the exercise of its rights, HOKEJAM.LV verifies the identity of the Customer, assesses the request and executes it in accordance with regulatory enactments.

HOKEJAM.LV’s replies to the Customer by mail to their designated contact address in a registered letter, as far as possible taking into account the Customer’s indicated type of receiving replies.

HOKEJAM.LV ensures the enforcement of data processing and protection requirements in accordance with regulatory enactments and, in the event of Customer’s objection, take the useful steps to resolve the objection. However, if this fails, the Customer has the right to refer to the supervisory authority — Data State Inspectorate.

 

Customer's consent to data processing and the right to withdraw it

The Customer’s consent to the processing of personal data, with their consent as the legal basis, can be given at HOKEJAM.LV service portals/apps, HOKEJAM.LV and other websites (such as loyalty programs and newsletter sign-up forms), or on-site at HOKEJAM.LV office/shop.

The Customer has the right to withdraw the consent given to the processing of data at any time in the same way as it was given, or by sending a corresponding notification to info@hokejam.lv in which case further data processing based on the earlier given consent for the specific purpose will not be carried out in the future.

The withdrawal of consent does not affect the processing of data carried out at the time the Customer’s consent was in force.

With the withdrawal of consent, data processing based on other legal grounds can not be stopped.

 

Communication with the Customer

HOKEJAM.LV communicates with the Customer using the contact information (phone number, e-mail address, postal address, and using sms messages from service) given by the Customer.

HOKEJAM.LV carries out the communication regarding the fulfilment of the contractual obligations of services on the basis of the contract concluded (e.g. coordination of the time of delivery or service, information on invoices, planned works, changes in services, etc.).

 

Commercial communications

Communication on commercial statements about HOKEJAM.LV and/or third-party services and other notices regarding services not directly related with the provision of services (e.g. customer surveys), HOKEJAM.LV carries out in accordance with the external regulatory enactments or in accordance with the Customer's consent.

The Customer can give their consent to HOKEJAM.LV and/or its cooperation partners for commercial statements via HOKEJAM.LV and other websites (such as newsletter sign-up forms).

The Customer's consent for receiving the commercial communications is valid until its withdrawal (also after termination of the service contract). The Customer may, at any time, refuse to receive further commercial notifications in one of the following ways:

• sending an e-mail to info@hokejam.lv;

• in person at HOKEJAM.LV office/shop;

• using an automated option to opt out of receiving future notifications of commercial statements, by clicking the opt-out option at the end of the commercial statement (e-mail).

HOKEJAM.LV stops sending commercial announcements as soon as the Customer request to withdraw their consent for commercial communications is processed.

 

Cookies terms of use

Cookies are small text files that are stored by a web browser (such as Internet Explorer, Firefox, Safari, etc.) on a user’s terminal (computer, mobile phone, tablet) at the moment when a user visits a website, to identify a browser or browser-saved information or settings. Thus, with the help of cookies, the website gets the ability to preserve the user's individual settings, recognize them and respond appropriately, with an aim to improve the site usage experience. The user can disable or restrict the use of cookies, but it will not be possible to make full use of all the features of the sites without cookies.

Depending on the functions and uses to be performed, HOKEJAM.LV uses essential cookies, functional cookies, analytical cookies and target (ads) cookies.

Essential cookies require a user to be able to visit and browse a website freely and use the options offered by it, including information about services and purchasing them. These cookies identify the user's device, but do not disclose the identity of the user and do not collect or summarize information. Without these cookies, the website will not be able to work fully, such as providing the information required to the user, providing the requested services in the e-store. These cookies are stored in the user's device until the web browser is closed.

Functional cookies remember the user's chosen settings and choices to allow the user to use the site more easily. These cookies are stored in a user's device permanently.

Analytical cookies collect information about how a user uses a website, finds the most frequently visited sections, including the content that the user chooses when browsing the site. Information is used for analysis purposes to find out what website users are interested in and to improve the functionality of the site, making it easier to use. Analytical cookies only identify the user's device but do not disclose the identity of the user. In certain cases, some of the analytical cookies on behalf of site owner are managed by third-party data controllers (operators), such as Google Adwords, in accordance with the instructions and only according to the purposes specified.

Target (ads) cookies are used to collect information about websites visited by the user and offer our or cooperating partners’ services directly to a particular user, or to address offers that match the interest that the user has shown. Typically, with the site owner's permission these cookies are placed by third parties, such as Google Adwords, according to the purposes specified. The target cookies are stored permanently in the user’s device.

HOKEJAM.LV uses cookies to improve the experience of using sites and webpages:

- to ensure the functionality of the homepage;

- to adjust homepage functionality to user habits — including language, search requests, previously viewed content;

- obtain statistics on the number of visitors to the page visitor feeds, time spent on the page, etc.;

- for user authentication;

- if the user is a HOKEJAM.LV service client, display custom offers that meet the user's needs;

If not otherwise specified, the cookies are stored until the operation for which they are collected is fulfilled and then deleted.

Cookie information is not transferred for processing outside the European Union and the EEA.

 

Confirmation and disabling of cookies

When visiting HOKEJAM.LV sites and households, window with a message that the website uses cookies is displayed to the user. When you close this message window, the user confirms that he is familiar with the information about the cookies, for the purposes of their use, in cases where their information is transferred to a third party and agrees with them. Accordingly, the legal basis for the use of cookies is the consent from the user. If a website or a website user concludes a contract — the processing of thecookies is necessary for the execution of a contract with users, or for HOKEJAM.LV to fulfil its statutory obligation or to pursue legitimate interests.

You can restrict and delete cookies in security settings of any web browser. However, it should be taken into account that the use of essential and functional cookies cannot be waived because, without them, it is not possible to ensure the full use of the site and webpage.

We recommend that you save cookies for the best user experience and can fully use the web site.

If you have questions about use of cookies, please contact us info@HOKEJAM.LV.

Other provisions

HOKEJAM.LV websites may contain links to third-party Internet homepages that have their own use and personal data protection rules for which HOKEJAM.LV does not carry any responsibility.

HOKEJAM.LV is entitled to make additions in Privacy Policy by making it available to the Customer by placing its current version on the HOKEJAM.LV website.