Privacy Policy

 

This is the Privacy Policy of AS KALCEKS (hereinafter “Kalceks”). 

Its purpose is to explain to data subjects how Kalceks processes personal data, to communicate in a transparent manner the procedures and measures for the exercise of data subjects’ rights, and to describe other issues related to the protection of personal data. It is also designed to ensure that data subjects can exercise their statutory rights in a simple, accessible and comprehensible way. As the personal data protection legislation sets a general goal to ensure the privacy of individuals and the only way to ensure the fulfilment of this goal is to make the protection of personal data an integral part of the activities of private and public entities, Kalceks ensures that all personal data are adequately protected and safe. Adequate protection is the use of the necessary technical and organizational means and the processing of personal data in accordance with the regulatory framework.

The Privacy Policy is developed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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”), as well as Personal Data Processing Law and other regulatory enactments that regulate the issues of personal data processing.

The terms used in this Privacy Policy and their meaning are the same as in the definitions in Article 4 of the GDPR.

Kalceks encourages all data subjects from time to time to carefully read this Privacy Policy in order to obtain up-to-date information on the personal data processing processes performed by Kalceks, as they may change over time.

For information on the processing of personal data in connection with cookies on the Kalceks website, please see our Cookie Policy [link].

Controller

The controller of your personal data is akciju sabiedrība “Kalceks”, registration number 40003988264, legal address Krustpils Street 71E, Riga, LV-1057, Latvia.

Kalceks contact information for issues related to personal data processing is: [email protected], as well as Krustpils Street 71E, Riga, LV-1057, Latvia.

 

Categories of personal data

  1. For the various purposes, Kalceks processes mainly the following categories of personal data:

No.

Data category

Examples of data belonging to a data category

1.

Identification data

Name, surname, personal identification number, year of birth, gender

2.

Information on position

Job title, position 

3.

Contact information

Phone number, e-mail, address

4.

Information that is processed in the event of a visit to the Kalceks website

IP address, network and location data, as well as other information that you agree to process as part of your visit to the Website; for detailed information on the processing of personal data by cookies, please consult the Kalceks Cookie Policy [link]. 

5.

Other information

Information you provide to us for the purpose of the relevant letter, request or question, such as any other information contained in your CV and application letter, application or other document.

6.

Information obtained from video surveillance

Digital image, posture, gait, other information shown in the image, time of arrival, time of departure

  1. In order to ensure its internal personnel management processes, Kalceks processes mainly the following categories of personal data of Kalceks employees:

No.

Data category

Examples of data belonging to a data category

1.

Identification data

Name, surname, personal identification code, date of birth, gender, photo

2.

Contact information

Address, place of residence, telephone number, e-mail

3.

Professional information

Position, role, qualifications, education, experience, other information provided in the CV, content of the job application and training information (eg information in the application letter and CV, language skills and other relevant skills, etc.)

4.

Financial information

Remuneration, allowances, information on dependents, tax and social security contributions

5.

Information related to the employment relationship

Information on compulsory health examinations, occupational diseases, absence (justified and unjustified), trade union membership (before termination of employment), assessment information, fact of possible violation, description, justification, explanations, information provided by third parties about the employee, fact on decision-making, decision-making date, number, essence. Information related to the organization of employee training (type, scope, amount, date, result).

6.

Information obtained from video surveillance

Digital image, posture, gait, other information shown in the image, time of arrival, time of departure

7. 

Social networking information

Information on social networks (e.g. likedin.com, facebook.com), including images

In any case, Kalceks will process your data only if the processing of this personal data has a clear purpose and is based on one (or several) legal grounds.

How Kalceks obtains personal data

Kalceks obtains your personal data mainly in the following ways: 

  1. You personally submit personal data for processing, in other cases also by consenting to the processing of such personal data (for example, by visiting Kalceks website, asking questions or otherwise contacting Kalceks using the communication tool provided on the website, or by writing to e-mail addresses managed by Kalceks or Kalceks employees, as well as by using the services provided by Kalceks in any other way, including by visiting Kalceks office);

In the event that you provide us with personal data at your free choice, please take into account the purpose of the relevant personal data submission and consider the amount of personal data required and to be transferred to achieve this purpose. Kalceks requests that personal data be provided only to the extent necessary for the purpose of the respective letter, request or question, and in particular requests not to provide personal identification number, health and other special (confidential) data, financial data, other excessive or irrelevant personal data not applicable to the respective issue. 

  1. In certain cases, personal data may be obtained by Kalceks also from other entities, such as other legal or natural persons (for example, by concluding an agreement with a Kalceks partner who identifies you as a contact person), as well as from information contained in various public registers, as well as received from public authorities, including courts and law enforcement institutions. Kalceks may use also publicly available information, which may contain personal data, as well as obtain information from video surveillance recordings;

Purposes of personal data processing

Kalceks processes your personal data mainly for the following purposes:

No.

Purpose

Explanation

1.

For the provision of services (for the implementation of commercial activities)

  • Fulfilment of contractual obligations with customers;
  • Provision/ maintenance of services;
  • Improvement of services, development of new services;
  • Service;
  • Reviewing applications;
  • Complaints handling;
  • Direct marketing activities

2.

For ensuring security and interests of Kalceks and third parties 

  • Information security
  • Information system security 
  • Protection of legal interests

3.

For provision of information 

  • To public administration institutions, courts, law enforcement institutions in accordance with the procedures and to the extent specified in external regulatory enactments

4.

For ensuring personnel management processes and corporate culture of Kalceks 

  • Personnel selection
  • Conclusion and performance of an employment contract
  • Accounting of working time
  • Ensuring the calculation of wages and the performance of wages
  • Compliance with accounting requirements
  • Ensuring social benefits for employees
  • Recording, evaluating and controlling the performance of work duties
  • Corporate culture

Processing of personal data in the framework of direct marketing

Kalceks can also process your personal data as part of direct marketing. As part of direct marketing, Kalceks can send you by e-mail:

  1. invitations to participate in various surveys, interviews, etc.;
  2. invitations to various events;
  3. invitations to fill in feedback forms, etc.;
  4. information about news, Kalceks offers, etc.

At the same time, Kalceks calls to take into account that Kalceks will process your personal data in the framework of direct marketing only in two cases:

  1. if your consent has been obtained (i.e. you have signed up to receive direct marketing communications and thereby provided your personal data (e-mail, name, surname) - the so-called “opt-in” principle), or 
  2. if you are already Kalceks customer, who has not explicitly objected to the processing of your previously provided personal data (e-mail, name, surname) for receiving direct marketing communications for similar services offered by Kalceks (i.e. Kalceks will use your e-mail address in this case previously obtained from you in the course of business - the so-called “soft opt-in” principle).

Kalceks also calls to take into account that you can opt out of receiving direct marketing messages at any time. This can be done in the following ways:

  1. by selecting the appropriate free option in the relevant message received from Kalceks (“to unsubscribe”)
  2. by writing to: [email protected] or Krustpils Street 71E, Riga, LV-1057, Latvia.

Legal basis

Kalceks processes personal data mainly on the following legal bases:

No.

Legal basis

Explanation

1.

Conclusion and performance of the agreement

  • Data processing carried out in order to conclude an agreement between Kalceks and you and to perform this agreement, 

2.

Compliance with the provisions of regulatory enactments

  • Data processing, which is performed in connection with the fulfilment of the obligations specified in various regulatory enactments applicable to Kalceks 

3.

Kalceks legitimate interests

Data processing carried out in order to safeguard the legitimate interests of Kaleks as controller, such as:

  • Conducting business and providing services
  • Identifying data subjects (e.g. in case of data request)
  • Eliminating business risks (e.g. various risks related to the actions of third parties or users)
  • Preventing security risks (e.g. various risks related to personal data security risks from third parties)
  • Analysing service delivery with a view to developing and improving it (e.g. making service delivery more efficient and convenient)
  • Preventing fraudulent and other illegal activities and protecting Kalceks from the negative consequences of such activities (for example, preventing criminal offenses)
  • Monitoring the provision of services to prevent technical problems (e.g. ensuring the provision of quality services without technical disruption)
  • Ensuring corporate governance and accounting
  • Protecting your legal interests, including through state, local and judicial authorities, as well as law enforcement agencies (for example, preventing, detecting and limiting illegal expressions by third parties)
  • Informing the public about its activities, including through advertising

 

4.

Your consent

  • Processing of data with your consent, which is expressed as active operation, including by contacting us and providing your personal data or performing other active operations.

 

* If the processing of your personal data is based on your consent, you have the right to withdraw it at any time and Kalceks will no longer process your personal data processed on the basis of the consent for that purpose. At the same time, the withdrawal of consent may not affect the processing of personal data which is necessary for the fulfilment of the requirements of regulatory enactments or which is based on a contract, legitimate interests of Kalceks or other grounds specified in regulatory enactments for lawful data processing. 

Protection of personal data

As a data controller, Kalceks ensures:

  1. the confidentiality of personal data, ensuring that personal data are processed (including accessed) only by those persons who need it for the performance of their official duties. Kalceks’s representatives, who handle information containing personal data in the course of their daily work, are trained in personal data protection measures and are contractually committed to confidentiality.
  2. the appropriate technical and organizational measures for the protection of personal data. Such measures include, as far as possible and considering the state of the art, implementation costs and the nature, scale, context and purposes of the processing, as well as risks of varying probability and severity regarding the rights and freedoms of individuals, the pseudonymisation of personal data, the minimization of personal data, physical and logical data protection measures in the work environment, as well as making backups, etc.
  3. only tested, licensed and updated software.
  4. data security, including the following technical solutions: data encryption (SSL), firewalls, intrusion protection and detection software.
  5. involvement of certified personal data protection specialists in the processing of personal data and implementation of personal data protection measures.

Kalceks also regularly reviews, updates and improves its technical and organizational measures.

Categories of recipients of personal data

Kalceks shall not transfer personal data to third parties unless there is a legal basis for such processing and the purpose of the processing is not predetermined, and if those third parties, taking into account the nature, scale, context and purposes of the processing and the varying degrees of probability and severity risks to the rights and freedoms of natural persons, are unable to provide, in a transparent manner, appropriate technical and organizational measures to ensure and demonstrate that the processing of personal data is in accordance with law and/ or cannot provide reasonable assurance that the security of personal data processing and respect for the rights of data subjects will be ensured.

Personal data may be transferred for various purposes of personal data processing:

Transfer of personal data to third countries

Kalceks does not transfer personal data to third parties outside the European Economic Area.

Duration of retention of personal data

Kalceks takes into account the following principles when determining the retention period of personal data:

Audit records are kept for at least 18 (eighteen) months from the date of their performance. 

Upon termination of the above circumstances, personal data shall be permanently deleted, including backups of such data.

Retention period of personal data in personnel selection:

Automated data processing

In the process of data processing, Kalceks does not perform automated processing of personal data, within the framework of which legally binding decisions are made for you.

Rights of data subjects

·       Obligation to provide information 

Kalceks complies with the requirements of Articles 13 and 14 of the GDPR and proactively provides the information provided for in these Articles to data subjects.

·       Right of access (Article 15 of the GDPR)

Kalceks ensures that data subjects receive information about the personal data processing process that applies to them. At the request of the data subject, Kalceks shall provide access to the personal data of the data subject in accordance with the procedures specified in regulatory enactments. 

·       Right to rectification of personal data (Article 16 of the GDPR)

Kalceks ensures that inaccurate personal data of the data subject are corrected in accordance with the procedures specified in regulatory enactments, without undue delay. Taking into account the purposes of processing, the data subject has the right, when submitting the application, to request that incomplete personal data be supplemented. 

·       Right to erasure (‘right to be forgotten’) (Article 17 of the GDPR),

Kalceks ensures that, at the request of the data subject, personal data relating to that data subject are deleted in accordance with the requirements of Article 17 of the VDAR. Kalceks shall inform the data subject of the erasure of personal data, unless such information would be disproportionate or impossible. 

·       Right to restriction of processing (Article 18 of the GDPR),

Kalceks ensures that the processing of personal data of the data subject is restricted if the criteria specified in Article 18(1) of the GDPR are met. Where processing is restricted in accordance with paragraph 1, such personal data, with the exception of storage, shall be processed only with the consent of the data subject or for the purpose of establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the EU or Latvia.

·       Right to receive information on the rectification, erasure or processing of personal data (Article 19 of the GDPR),

Kalceks shall notify each recipient to whom personal data have been disclosed of any rectification or erasure of personal data or restriction of processing carried out in accordance with Articles 16, 17(1) and 18, unless it appears that this is not possible, or if it involves a disproportionate effort. Kalceks shall inform the data subject of those recipients if the data subject so requests.

·       Right to data portability (Article 20 of the GDPR),

Kalceks ensures the portability of personal data of the data subject in accordance with the criteria of Article 20 of the GDPR. Kalceks ensures the transfer of personal data to another controller, if technically possible.

·       Right to object (Article 21 of the GDPR),

The data subject has the right to object to the processing of personal data in accordance with the criteria of Article 21 of the GDPR. Upon receipt of an objection to the processing of data from the data subject in accordance with Article 21 of the GDPR, Kalceks shall no longer process the data, unless it is possible to indicate compelling legitimate reasons for processing that are more important than the interests, rights and freedoms of the data subject or where necessary for the establishment, exercise or defence of legal claims defend legitimate claims.

·       Automated individual decision-making, including profiling (Article 22 of the GDPR),

Kalceks ensures that the data subject has the right not to be the subject of a decision that is based solely on automated processing, including profiling, which has legal effects on the data subject or which similarly has a significant effect on the data subject.

·       Right to lodge a complaint with a supervisory authority

The compliance of physical data processing measures with the regulatory enactment in Latvia is monitored by the Data State Inspectorate. If you believe that the processing of your personal data is not in accordance with the requirements of regulatory enactments, you have the right to file a complaint with the Data State Inspectorate. The address of the Data State Inspectorate is Elijas Street 17, Riga, LV-1050. Detailed information is available on the website www.dvi.gov.lv, or by calling 67 22 31 31, or by writing to [email protected].

 

You can exercise all the above rights by sending a request and contacting us by e-mail [email protected] or by writing to our legal address: Krustpils Street 71E, Riga, LV-1057.

Kalceks encourages to contact us before submitting a formal complaint so that to find the quickest and most effective solution to the problem.

Disclaimer

Kalceks has the unilateral right to amend and/ or supplement this Privacy Policy. The current version of the Privacy Policy is always published on [link]. Kalceks maintains previous versions of the Privacy Policy and these are available on the above site.

 

 

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