Numeri General Data Protection Conditions
The aim of the General Data Protection Conditions of Numeri is to protect the Personal Data of Data Subjects in conformity with the legislation of the European Union and the laws of the Republic of Latvia. The General Data Protection Conditions proceed in particular from Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and from the Personal Data Processing Law.
1.1. Data Subject: a natural person, which Numeri holds information on, for example, clients who are natural persons, visitors, co-operation partners and employees, whom Numeri holds Personal Data on.
1.2. Personal Data: any information relating to a Data Subject; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.3. Personal Data Processing: any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
1.4. Data Controller: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
1.5. Data Processor: a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.
1.6. Personal Data Breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
1.7. Consent of the Data Subject means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Personal Data Processing relating to him or her.
2. General Provisions
2.1. SIA Numeri is a legal entity under the registration No.: 40003563943, located in Elizabetes Street 33-6, Riga, LV-1010, Latvia.
2.2. Numeri may process Personal Data:
- As a Data Controller, defining the purposes and means of processing;
- As a Data Processor, following the instructions of the Data Controller.
2.3. Numeri may process the following types of Personal Data as a Data Controller and as a Data Processor disclosed by the Data Subject or Data Controller:
- Personal Data (name, surname, personal identification number, passport data for non-residents);
- Contact information (declared place of residence, telephone number, e-mail address);
- Financial data (salary information, bank account information, taxation data);
- Other data (job position, work schedule, sick-leave information, annual leave information, qualification, education, language skills, data containing special categories of Personal Data of the Data Subject).
2.4. Numeri may process Personal Data created as a result of day-to-day communication between the Data Subject and Numeri and as a result of provision of service (data of client’s employees, client data).
2.5. Numeri may process Personal Data created as a result of visiting and using the website (cookies, log data).
2.6. Only persons authorised by Numeri have access for changing and processing Personal Data. Numeri follows the principle of maintaining the confidentiality of Personal Data and discloses Personal Data only within strictly limited extent in order to ensure protection of the Personal Data.
3. Principles of Personal Data Processing
3.1. All Numeri activities relating to the Personal Data Processing proceed from the following principles:
- Lawfulness, fairness and transparency: Personal Data are processed lawfully, fairly and in a transparent manner in relation to the Data Subject;
- Purpose limitation: Personal Data are collected and processed for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
- Data minimisation: Personal Data collection and processing is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- Accuracy: Personal Data are accurate and, where necessary, kept up to date; every reasonable step is taken to ensure that Personal Data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay;
- Storage limitation: Personal Data are kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data are processed;
- Integrity and confidentiality: Personal Data are processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
4. Purpose and Lawfulness of Personal Data Processing
4.1. Numeri may process Personal Data of the Data Subject on the basis of the Consent of the Data Subject: Numeri may process Personal Data within the extent and for explicit purposes as determined by the Data Subject. The Data Subject shall give his or her Consent for Personal Data processing freely, specifically, knowingly and unambiguously.
4.2. Numeri may process Personal Data of the Data Subject on the basis of entering into and performance of an agreement to which the Data Subject is party: processing of Personal Data are necessary for the performance of a contract to which the Data subject is Party or in order to take steps at the request of the Data Subject prior to entering into a contract. For example, processing of personal data may be necessary upon the establishment of customer relationship and entering into service agreements for providing accounting services, payroll services, tax consulting services, legal services, administration of customer’s documents.
4.3. Numeri may process Personal Data of the Data Subject in compliance with a legal obligation: processing of Personal Data for compliance with legal obligations is conducted only in the event that Numeri is obligated to process the Personal Data because it is requested from the company by applicable law. For example, such obligation may arise from the Labour Law, Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing, Law on Accounting etc.
4.4. Numeri may process Personal Data of the Data Subject in compliance with a legitimate interest: for the purpose of providing high-quality services and promoting business activity, Numeri may process the Personal Data of the Data Subject, respecting the Data Subject’s fundamental rights and freedoms. Numeri processes the Personal Data on the grounds arising from law only after careful assessment in order to establish that Numeri has a legitimate interest, on the basis of which processing of Personal Data are necessary and in conformity with the interests and rights of the Data Subject.
5. Rights of the Data Subject
5.1. The right to withdraw the Consent at any time: the Data Subject shall have the right to withdraw his or her Consent at any time, where processing of Personal Data are based on Consent. This does not affect the legality of Data Processing conducted before withdrawal of the Consent.
5.2. The right to receive information: the Data Subject has a right to receive information on the Personal Data gathered on him or her. It is possible to receive information from Numeri on the Processing of Personal Data by sending a written request by e-mail to firstname.lastname@example.org.
5.3. The right of access: the Data Subject has a right to access his or her Personal Data and receive a copy of the Personal Data undergoing processing.
5.4. The right to rectification: the Data Subject shall have the right to have the inaccurate Personal Data corrected and completed.
5.5. The right to be forgotten: in certain cases, the Data Subject has a right to demand erasure of Personal Data and Numeri shall be committed to erase the Personal Data without undue delay where one of the following grounds applies:
- The Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- The Data Subject withdraws consent given for the processing and where there is no other legal ground for the processing of Personal Data;
- The Data Subject objects to the processing of Personal Data and there are no overriding legitimate grounds for the processing, or the Data Subject objects to the processing;
- The Personal Data have been unlawfully processed;
- The Personal Data have to be erased for compliance with a legal obligation in Union or Member State law to which Numeri is subject.
5.6. The right to restriction of processing: the Data Subject shall have the right to demand restriction of processing of Personal Data in the following cases:
- The accuracy of the Personal Data is contested by the Data Subject, for a period enabling Numeri to verify the accuracy of the Personal Data;
- The processing is unlawful and the Data Subject opposes the erasure of the Personal Data and requests the restriction of their use instead;
- Numeri no longer needs the Personal Data for the purposes of the processing, but they are required by the Data Subject for the establishment, exercise or defence of legal claims;
- The Data Subject has objected to processing the Personal Data pending the verification whether the legitimate grounds of Numeri override those of the Data Subject.
5.7. The right to data portability: in certain cases the Data Subject shall have the right to receive the Personal Data concerning him or her, which he or she has provided to Numeri, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
5.8. The right to object: the Data Subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of Personal Data concerning him or her conducted for the performance of a task carried out for reasons of public interest or in the event of a legitimate interest of Numeri or a third person. Numeri shall no longer process the Personal Data unless Numeri demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
6. Retention of Personal Data
6.1. Numeri keeps the Personal Data in a form, which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data are processed, unless Numeri has a legal requirement stipulating different time limits for the storage of Personal Data:
- Accounting documents must be retained in conformity with the Law on Accounting;
- Employment documentation must be retained in conformity with the Labour Law and the Archives Law;
- data gathered under the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing shall be retained pursuant to the law.
6.2. If the job applicant was not elected during recruitment, the Curriculum Vitae of the Data Subject shall be retained for four months as of making the negative decision. The Personal Data of a job applicant who was not elected shall be deleted after four months have passed from the submission of the job application.
6.3. Numeri shall destroy and/or delete securely all Personal Data, the purpose of retention of which does not exist or the retention period of which has expired.
7. Exercising of Rights and Filing of Complaints
7.1. The Data Subject has a right to exercise the rights: contact Numeri in case of questions, requests or complaints relating to the processing of Personal Data.
7.2. All questions and proposals concerning the processing of Personal Data may be referred to the following contacts: SIA Numeri, Elizabetes street 33-6, Riga, LV-1010, Latvia, email@example.com.
7.3. The Data Subject has a right to file complaints: if the Data Subject is of the opinion that the processing of their Personal Data has violated their rights, the Data Subject has the right to file this claim to Numeri, the Data State Inspectorate or a court.
7.4. All complaints concerning the processing of Personal Data may be referred to the following contacts: Data State Inspectorate, Blaumaņa street 11/13-11, Riga, LV-1011, Latvia, firstname.lastname@example.org.