Privacy Policy

1. General provisions

1.1. SIA “CUBE aģentūra” respects the right to privacy of its employees, clients, business partners and other directly or indirectly related persons; accordingly, personal data protection requirements are an integral part of SIA “CUBE aģentūra” business processes.

1.2. This Privacy Policy provides transparent information about the purposes for which SIA “CUBE aģentūra” collects and processes personal data, the principles of such processing, and the rights of data subjects in protecting their personal data.

1.3. Personal data is processed in accordance with the laws and regulations in force in the Republic of Latvia and in compliance with 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 the Regulation.

1.4. Which personal data processing will actually be carried out and how the data will be used also depends on each specific case; that is, not all information in this Privacy Policy will apply to you.

2. Controller and contact details

2.1. The controller of personal data processing is SIA “CUBE aģentūra”, unified registration No. 44103066717, registered office: Mūkusalas iela 29B, Riga, LV-1004, e-mail: hello@cube.lv.

2.2. For questions or concerns regarding this Privacy Policy or the processing of personal data, please write to: dpo@cube.lv.

3. Legal basis for processing personal data

3.1. Data subjects’ personal data is processed:

3.1.1. to conclude and perform a contract with the data subject, including to conclude a contract at the data subject’s request and to ensure its performance;

3.1.2. to fulfil legal obligations, for example in the fields of tax and accounting;

3.1.3. on the basis of consent given by the data subject;

3.1.4. to pursue the legitimate interests of SIA “CUBE aģentūra” or of third parties.

3.2. The legitimate interests of SIA “CUBE aģentūra” are:

3.2.1. to conduct commercial activity;

3.2.2. to verify the data subject’s identity before starting a collaboration or concluding another type of contract;

3.2.3. to retain data subjects’ applications, submissions, e-mails and other recorded information about an expressed interest in collaborating, for example on a specific project;

3.2.4. to ensure the performance of contractual obligations;

3.2.5. to protect its lawful interests in court and before other state institutions, and when obtaining legal assistance;

3.2.6. to advertise its services and carry out other marketing activities, including sending commercial communications;

3.2.7. to organise professional-field events and to document them with photos and video;

3.2.8. to manage the company’s websites and social media accounts;

3.2.9. to create and preserve records of the projects created by SIA “CUBE aģentūra”, their development and events in the company’s history.

4. Scope of personal data

4.1. Categories of personal data processed by SIA “CUBE aģentūra”:

4.1.1. identity and contact data:

4.1.1.1. first name, surname;

4.1.1.2. personal identity number / date of birth;

4.1.1.3. declared address of residence;

4.1.1.4. telephone number and e-mail address;

4.1.1.5. identity document data.

4.1.2. data arising from the respective form of collaboration:

4.1.2.1. data of the concluded collaboration agreement;

4.1.2.2. data on the performance of the contract;

4.1.2.3. documentation and correspondence within the respective project (for example project clarifications, additional work assignments, deadlines and other communication related to the performance of the contract).

4.1.3. other personal data logically and reasonably arising from the respective project.

5. Processing, protection and storage of personal data

5.1. Personal data is processed only for the purposes originally intended and to the extent originally defined.

5.2. Data subjects’ personal data is processed using the capabilities of modern technology, taking into account existing privacy risks and the reasonably available organisational, financial and technical resources. Within all these measures, an appropriate level of information protection is ensured that prevents unauthorised access to the data subject’s personal data.

5.3. Personal data is stored only for as long as necessary to achieve the purposes set out in this Privacy Policy, unless longer storage is required or permitted by applicable laws and regulations. The following criteria are used to determine the data storage period:

5.3.1. for as long as a legal basis for the data processing exists;

5.3.2. for as long as the contract or collaboration agreement concluded with the data subject, from which the personal data processing arises, is in force;

5.3.3. for as long as SIA “CUBE aģentūra” or the data subject can exercise their legitimate interests in the manner prescribed by external laws and regulations (for example, handling of claims, protection of rights, resolution of issues, etc.);

5.3.4. for as long as the data subject’s consent to the respective personal data processing is in force;

5.3.5. for the preservation of the archive and historical records of projects created by SIA “CUBE aģentūra”.

5.4. The personal data storage period is determined in accordance with the requirements of laws and regulations, for example:

5.4.1. to comply with the storage periods set out in the laws and regulations governing accounting, accordingly five to ten years;

5.4.2. to protect its fulfilled obligations and preserve evidence in accordance with the limitation periods for claims set out in laws and regulations: 10 years under the Civil Law; 3 years under the Commercial Law; 5 years under the Personal Data Processing Law, and other periods, additionally taking into account the time limits for bringing claims set out in the Civil Procedure Law.

5.5. Personal data processing does not involve profiling of data subjects or automated decision-making that would produce legal or other effects for the data subject.

6. Recipients of personal data

6.1. Data subjects’ personal data is not disclosed to third parties without a legal basis, except:

6.1.1. where the data must be transferred to the respective third party within the framework of a concluded contract in order to perform that contract;

6.1.2. to public administration institutions authorised by law, for example the State Social Insurance Agency, the State Revenue Service, the State Police, the Emergency Medical Service, etc.;

6.1.3. where the data subject has given consent to the data processing and onward transfer of the data;

6.1.4. in cases provided for by laws and regulations, to protect the lawful interests of SIA “CUBE aģentūra”;

6.1.5. where the transfer of data is necessary to secure the legitimate interests of SIA “CUBE aģentūra” or of third parties.

6.2. Within the framework of a collaboration agreement or a specific project, in order to perform a particular function, the data subject’s personal data may be transferred to other companies of the CUBE group.

6.3. Data subjects’ personal data is not transferred to or processed outside the EU or the EEA.

7. Rights and obligations of data subjects

7.1. The data subject may give consent to personal data processing either in person at the venue of the specific project or electronically, by signing it with a secure electronic signature.

7.2. The data subject has the right to withdraw consent to data processing at any time, in the same manner in which it was given.

7.3. Withdrawal of consent does not affect data processing carried out while the data subject’s consent was in force.

7.4. Withdrawal of consent cannot stop data processing carried out on other legal bases.

7.5. The data subject has the right to receive the information prescribed by laws and regulations regarding the processing of their data, to request rectification of the data, or to object to the processing of personal data.

7.6. The data subject may submit a request to exercise their rights in writing in person, presenting an identity document, or by e-mail signed with a secure electronic signature.

7.7. When processing a data subject’s request to exercise their rights, SIA “CUBE aģentūra” verifies the data subject’s identity, assesses the request and fulfils it in accordance with laws and regulations.

7.8. SIA “CUBE aģentūra” ensures compliance with data processing and protection requirements in accordance with laws and regulations. In the event of a complaint by the data subject, SIA “CUBE aģentūra” will take all necessary steps to resolve it; if this is unsuccessful, the data subject has the right to contact the supervisory authority, the Data State Inspectorate of Latvia.

8. Final provisions

8.1. Data subjects’ submissions and requests for information are handled free of charge. Handling of a submission may be refused, or a reasonable fee may be charged for it, if the submissions are manifestly unfounded or excessive, as well as in other cases provided for by laws and regulations.

8.2. The data subject is obliged to read this Privacy Policy and to make it known to every person who is related to the data subject and whose interests may thereby be affected in the processing of this person’s data.

8.3. The Privacy Policy is freely available on the SIA “CUBE aģentūra” website www.cube.lv.