INFORMATION ON PERSONAL DATA PROCESSINGPERSONAL DATA PROCESSING
ADVSR LLC (hereinafter - ADVSR) processes your personal data in connection with the operation of ADVSR as a legal and accounting services office and providing assistance to its clients.
Your personal data is also processed when you visit our website, ADVSR profiles on social media, sign up to receive our news or show interest in a vacancy at ADVSR, contact us or attend our events.
ADVSR implements appropriate technical and organizational measures in order to ensure the security of personal data processing against accidental or illegal destruction, loss, alteration, unauthorized disclosure or access to transmitted, stored or otherwise processed personal data.MANAGER CONTACT INFORMATION
ADVSR operates in compliance with the rights specified in the Commercial Law, therefore, when processing your personal data and providing legal and accounting assistance, ADVSR mainly acts as a personal data controller.
In case you have questions regarding the processing of your personal data by ADVSR or you want to exercise your data subject rights provided for in the Regulation, please contact us in the most convenient way for you:
Registration number: 50203182771
Lielirbes street No. 17a-17, Riga, LV 1046
Phone number: +371 28033433
E-mail: firstname.lastname@example.orgLEGAL BASIS OF PERSONAL DATA PROCESSING, PURPOSE OF PROCESSING AND TYPES OF PERSONAL DATA
The following legal bases for the processing of your personal data exist in the ADVSR:
• activities related to the provision of pre-contractual consultation and familiarization with the client's file and documents at the client's request, as well as measures for concluding the contract;
• Fulfillment of legal obligations imposed by ADVSR (fulfilment of legal requirements);
• protecting the vital interests of the client or another natural person or performing a task in the public interest;
• respecting and defending the legitimate interests of ADVSR;
• consent given by the data subject to the processing of personal data for a specific purpose.
• Provision of pre-contractual consultation and measures for concluding the contract
In order to provide legal assistance and evaluate future cooperation, we process personal data both when we provide pre-contractual consultations and familiarize ourselves with the case, and when we draw up a relevant cooperation agreement or agreement on the provision of legal assistance or accounting services.
In this regard, ADVSR may process the following personal data:
Personal identification data (name, surname, contact information), in case the client represents a legal entity or organization: data about this legal entity or organization (and data about the directly or indirectly controlled capital share or share of the client owned by the person), the customer controls to be implemented type and related supporting documents; personal data resulting from the submitted case materials, incl. third party data; correspondence and any communication with the client, incl. information received and notes made during face-to-face meetings, telephone conversations, videoconference communication;
The legal basis for such processing of personal data is subparagraph b) of the first part of paragraph 6 of the Regulation, which provides for the right of ADVSR to process personal data if the processing is necessary for the performance of a contract to which the data subject is a contracting party or for taking measures at the request of the data subject before concluding the contract ; Clause c) of the first part of the Regulation, subparagraph f) of the first part of paragraph 6, which provides that data processing is necessary for the legitimate interests of the manager or a third party - for example, the legitimate interests of ADVSR to protect the safety of its property and employees, as well as to check the customer's solvency data on the customer's payment procedures. Personal data of the special category are processed on the basis of the second part of Article 9 of the Regulation.Compliance with ADVSR's legal obligations regarding customer research and identification
Taking into account the requirements of the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing, ADVSR conducts customer research and identifies the customer in certain cases, and in this regard may process the following personal data:
• Personal identification data (name, surname, contact information), photo, passport data, country of permanent residence;
• In case the client represents a legal entity or entity: data on this legal entity or entity and data on the client's capital share or shares directly or indirectly controlled by a specific person, the type of client control to be implemented and related supporting documents;
• Information about a person from the relevant lists of persons suspected of involvement in terrorist activities or in the production, storage, transfer, use or distribution of weapons of mass destruction; or information from the list of sanctions subjects compiled by the Cabinet of Ministers on the basis of Law on International Sanctions and National Sanctions of the Republic of Latvia;
The legal basis for such processing of personal data is subparagraph c) of the first part of paragraph 6 of the Regulation, which provides for ADVSR's right to process personal data if it is related to the fulfillment of ADVSR's legal obligation. In special cases, based on Article 34 of the Personal Data Processing Law, data on a person's conviction in the field of criminal law may be processed.Execution of the contract
In connection with the execution of the client's task, ADVSR processes various categories of personal data and the personal data to be processed depends on the subject of the specific case and the task given to ADVSR.Marketing and advertising
ADVSR can process personal data in connection with its marketing and advertising activities, for example, to inform about events organized by ADVSR, about news published on the website, etc. Also, ADVSR may publish information about a successfully resolved client case for advertising purposes. Processing may also be necessary to provide services to persons who have expressed an interest in receiving them.
In this regard, ADVSR can process such data as name, surname, contact information, information about interests regarding specific news (topics), as well as language;
The legal basis for such processing of personal data is ADVSR's legitimate interests in promoting its services and addressing existing and potential clients, as provided for in Article 6, Part One, Clause f) of the Regulation;
ADVSR news or other advertising materials (direct marketing) are sent by e-mail only if a specific person's consent has been received, which can be revoked by following the instructions in the e-mail;
In the event that information about a successfully resolved client's case was published on the ADVSR website, the specific publication and the personal data contained in it are always coordinated with the client and, if necessary, the data subject's consent to the publication of such information is requested, which the data subject has the right to withdraw.ADVSR's interests as a performer of economic activities
Taking into account the fact that ADVSR, by providing legal assistance and accounting services, also carries out its economic activity, personal data resulting from ADVSR's cooperation with other service providers and partners, from the administration of contracts and invoices concluded with clients, may also be processed, as are also related to the defense of ADVSR's legitimate interests.
In this regard, such personal data may be processed, such as: name, surname, place of work and position, contact information, information necessary for the preparation of invoices, as well as information on the payment of invoices, information on services provided by ADVSR or received by ADVSR (i.e. see the tasks performed in the interest of the client, the time taken for the performance and the applied rates), any kind of correspondence or communication, notes made during the provision or receipt of services;
The legal basis for the processing of such information is the legitimate interests of the ADVSR to provide legal assistance services and perform economic activity, as provided for in Article 6, paragraph one, subparagraph f) of the Regulation, as well as to fulfill the contract concluded with the client in accordance with Article 6, paragraph one, subparagraph b) of the Regulation, or to comply with the law the legal obligations of ADVSR in accordance with Article 6, paragraph one, subparagraph c) of the Regulation.
Likewise, ADVSR can also process the following personal data of a potential employee or a person who has applied for an internship at ADVSR:
Personal identification data (name, surname), contact information, acquired education, qualifications, skills, language skills, work experience, incl. previous work experience, references from previous employers, desired salary, other professional and personal characteristics included in the CV and/or required in the personnel selection process or any of its stages, incl. taking notes during the job interview and completing the test task.
The legal basis for the processing of such information is the legitimate interest of the ADVSR provided for in point f) of the first part of Article 6 of the Regulation, to employ employees who correspond to a specific position;
In the case of successful recruitment, personal data is processed at the request of the selected applicant in order to take the necessary measures with the aim of concluding and fulfilling the concluded contract, based on Article 6, paragraph one, subparagraph b) of the Regulation, while in case of unsuccessful recruitment, personal data is processed in order to provide the applicant response, as well as to defend their legitimate interests in case of possible claims, based on the legitimate interests of ADVSR provided for in subparagraph f) of the first part of Article 6 of the Regulation. There may be cases when the processing of the data of specific persons is required by law - for example, to check whether the person meets the requirements set by law regarding the employee's state of health.ADVSR homepage
When you visit the ADVSR website, ADVSR collects and processes information in the form of cookies. We use this information for marketing purposes, as well as to optimize the operation of the website and provide you with a better experience of using it.
We process information about your IP address in connection with the cookies used. Also, in aggregated form (i.e. without identifying the specific person), we can process the following data: demographic information, including gender and age, interests, information about your browser and its geographical location (login), the device from which the connection is made and the connection service provider. This data is processed to collect statistical data and, by analyzing the use of the website, to optimize its operation;
The legal basis for the processing of such data is the legitimate interests of ADVSR to collect statistical data and, by analyzing the use of the website, to optimize its operation, as provided for in the Regulation, provided for in Article 6, paragraph one, subparagraph f) of the Regulation.Social media
ADVSR has profiles on social media such as LinkedIn, Facebook and Instagram, and when you interact with ADVSR on these platforms (for example, you react to or share our publication), ADVSR receives information about it. It should be noted that the information we receive through these social media is also processed by the media themselves, therefore ADVSR and the respective platform are considered joint controllers with respect to this information.
The information we can receive about you is that which is available on social media, incl. Your profile information, photo, as well as information about your interactions with ADVSR.
The legal basis for such processing of personal data is the legitimate interests of ADVSR to advertise its services and address existing and new customers, provided for in Article 6, Paragraph One, Subparagraph f) of the Regulation.
On the other hand, in cases where ADVSR publishes news about a successfully resolved client's case, the specific publication and the personal data contained in it are always coordinated with the client and, if necessary, the data subject's consent to the publication of such information is requested, which the data subject has the right to withdraw.SOURCES OF PERSONAL DATA
In connection with the provision of pre-contractual consultation and measures for concluding a contract, as well as when executing a contract concluded with a client, ADVSR mostly obtains personal data directly from its client, or from publicly available resources (databases), from public institutions or third parties (for example, other contractual parties).
The data processed in connection with the fulfillment of ADVSR's legal obligations regarding customer research and identification are obtained from the customer, publicly available resources (databases) and other persons specified in the applicable legislation.
Data that is processed for marketing and advertising purposes is obtained from you as a data subject, or from a company that is a client of ADVSR and where you are employed.
Data processed in the interests of ADVSR as an economic operator are most often obtained from a customer with whom a contract has been concluded (including from the employer of the data subject with whom ADVSR has a contract) or directly from the data subject (e.g. from a potential employee's application letter and CV, or during an interview).
Your personal data may be disclosed and transferred to third parties only if it is related to the provision of legal assistance or accounting services, pre-contractual consultations, contract preparation or performance of the contract concluded with ADVSR, as well as if ADVSR has such a legal obligation in accordance with the applicable laws, or your consent to the disclosure and transfer of such data to third parties has been received, or it corresponds to the legitimate interests of ADVSR. Personal data may also be disclosed to the following persons:
• To parties or persons related to a contract or a specific client matter;
• For public institutions, courts, sworn notaries, sworn bailiffs, interpreters,
• credit institutions, insurers, accountants, appraisers, auditors, experts, etc. ;
In addition, ADVSR may disclose and transfer your personal data to such personal data processors with whom ADVSR cooperated and/or who provide support in the provision of legal assistance to ADVSR, such as accountants, IT specialists and cooperation partners - such as recruitment companies.
In most cases, ADVSR will not transfer your personal data outside the EU/EEC borders, however, in rare cases, this may happen if you are in a third country as a customer or customer representative, or a party related to the case (customer task). In such a case, the ADVSR shall apply subparagraphs a), b) or e) of the first part of Article 49 of the Regulation, according to which the transfer takes place if the data subject has expressly consented to the proposed transfer after being sufficiently informed of the possible risks, if the transfer is necessary, to fulfill the contract between ADVSR and the data subject or to implement pre-contractual measures taken at the request of the data subject, or if the transfer is necessary for the establishment, exercise or defense of legal claims.
In certain cases, ADVSR can also directly or indirectly use such services, whose providers - data processors are located outside the EU/EEC.CONFIDENTIALITY
ADVSR employees are subject to strict confidentiality requirements, including when processing personal data.DATA STORAGE AND ERASURE
ADVSR processes personal data until the purpose that is the basis for processing personal data is fulfilled. ADVSR has developed a data erasure policy and each category of personal data has a storage period, after which the personal data is permanently erased.
The storage of personal data depends on the type of document: for example, electronic documents are stored in the e-mails of responsible employees, work computers and/or internal systems of ADVSR, while documents in paper: in internal closed archives. ADVSR applies the developed technical and organizational measures to ensure the security and inaccessibility of personal data to third parties.PROVISION OF PRE-CONTRACT CONSULTATION, CONTRACT PERFORMANCE AND FULFILLMENT OF LEGAL OBLIGATIONS REGARDING CUSTOMER RESEARCH AND IDENTIFICATION
ADVSR mainly stores such personal data as are necessary to protect the legitimate interests of ADVSR and to provide evidence in case of legal proceedings. ADVSR stores such personal data until the expiry of the limitation period specified in the applicable laws and regulations (usually three or ten years), or for no longer than is necessary.
Personal data that was processed solely on the basis of your consent will be processed until this consent is withdrawn.
In the event that cooperation was not established and personal data about you were stored only in relation to possible cooperation, this information will be stored for one year from the moment of the last correspondence, unless there is another legal basis for storing this information longer.
Personal data resulting from the fulfillment of the legal obligation regarding customer research and identification will be stored for five years after the termination of the business relationship or the execution of an occasional transaction.ADVSR's interests as a performer of economic activities
Information resulting from accounting data is stored in accordance with the terms specified in the Accounting Law while other information about ADVSR contracts with service providers and cooperation partners is stored until the limitation period specified in the applicable regulatory acts expires (usually three or ten years ), for the protection of legitimate interests of ADVSR and provision of evidence in case of legal proceedings.
The data of potential employees are stored for three months from the day when the refusal to establish employment legal relations is announced, but if legal proceedings have been initiated, until the execution of the final court judgment.
Marketing and website
ADVSR stores the data until the consent of the data subject is withdrawn (if the processing is based on consent). If the business relationship continues (without direct marketing), the general storage period based on the limitation period specified in the applicable regulatory acts (usually three or ten years) applies to the rest of the personal data.
As a data subject, you have the rights provided for in the Regulation regarding the personal data being processed.
You can exercise your data subject rights at any time, however ADVSR has the right to deny you the exercise of these rights in whole or in part if there are reasons based on the Regulation or other regulatory enactments.
The right to access your personal data
The data subject has the right to receive confirmation from ADVSR as to whether or not the data subject's personal data is being processed.
If ADVSR processes the personal data of the data subject, then the data subject has the right to access his personal data and receive information about what personal data is processed, the purpose of processing, recipients of personal data, other information specified in Article 15, Clauses 1 and 2 of the Regulation.
ADVSR can provide the data subject with a copy of the personal data being processed, however, in certain cases, if such a request requires disproportionate resources, ADVSR has the right to request payment for the preparation of the information, or to refuse to provide such information to the data subject.
The right to have PERSONAL data rectified
The data subject has the right to have the ADVSR rectify inaccurate personal data without undue delay, as well as, taking into account the purposes of the processing, to supplement incomplete personal data, including by providing an additional statement. However, if the ADVSR reasonably believes that such a request by the data subject is not justified and the ADVSR will not be obliged to have them rectified, the ADVSR may note that the data subject considers the personal data to be inaccurate.
The right to erasure of personal data (the right to be forgotten)
The data subject has the right to obtain from ADVSR the erasure of personal data without undue delay, and ADVSR is obliged to erase personal data without undue delay if one of the following conditions exists:
• personal data is no longer necessary in relation to the purposes for which it was collected or processed;
• the data subject withdraws consent to the processing of his personal data and there is no other legal basis for the processing;
• the data subject, based on his special situation, objects to the processing of his personal data based on (i) public interest; (ii) the exercise of official powers legally granted by the controller, (iii) the legitimate interests of the controller or a third party and the aforementioned processing of this personal data does not have a more important legitimate basis, or (iv) direct marketing (direct marketing), which includes profiling;
• personal data has been illegally processed;
• personal data must be erased in order for ADVSR to fulfill a legal obligation defined in legislation;
• personal data processed in connection with the provision of the information society service to the child on the basis of consent.
However, in the event that ADVSR reasonably indicates another legal basis for personal data processing, which requires the continued processing of personal data, or which is considered more important than this data subject's right, ADVSR has the right not to fulfill the data subject's request for the erasure of personal data (for example, personal data may be processed to ensure ADVSR's right to bring or maintain a lawsuit in the future and personal data could serve as evidence in legal proceedings).RIGHT TO RESTRICT THE PROCESSING OF PERSONAL DATA
The data subject can request to limit the processing of his personal data (not to make any changes to the relevant data) if:
• the data subject contests the accuracy of personal data (processing is temporarily limited until the data verification is completed, unless the law stipulates the obligation of ADVSR to process personal data);
• the processing of personal data is illegal (the data subject, however, opposes the erasure of data, but instead requests restriction of processing);
• personal data is no longer necessary for the implementation of the purpose of processing, but the data subject requires his personal data to bring, exercise or defend legal claims;
• the data subject has objected to the processing based on the legitimate interests of ADVSR or a third party until the completion of the examination of the data subject's objections.
If the processing was restricted, ADVSR processes this personal data, except for storage, only:
• with the consent of the data subject;
• to bring, exercise or defend legal claims (eg in court);
• to defend the rights of another natural or legal person;
• in significant public interest.
The right to personal data portability
The right to personal data portability applies to personal data submitted to the ADVSR as the controller by the data subject himself on the basis of consent or contractual relationship (including at the stage of preparation for the conclusion of the contract), if the processing of this data takes place by automated means.
The data subject has the right to receive his personal data in a structured, generally accepted and machine-readable format and to transfer this personal data to another controller.
The transmission of personal data to the data subject must be properly ensured and protected by implementing the necessary technical measures to ensure correct and secure transmission, as well as the confidentiality and integrity of personal data.
The use of data portability does not affect other rights, such as the right to information. The realization of the right to personal data portability does not affect the rights and obligations of ADVSR to continue processing personal data after their transfer, if there is a legal basis for such further processing.
The right to object to the processing of personal data
The data subject can object to the processing of his personal data in the following cases:
• for direct marketing purposes (including profiling to the extent related to direct marketing);
• processing on the basis of legitimate interests (including profiling based on their rules), public interest or in the exercise of official powers by ADVSR, if such are granted to ADVSR;
• processing for scientific or historical research or statistical purposes.
The data subject must justify the right to object to the processing of his personal data with his specific situation, except for objections to the processing of his personal data for direct marketing, which do not need to be justified.
The right not to be the subject of a decision based solely on automated processing, including profiling
Please note that ADVSR does not perform such automated processing.
The right to withdraw your consent
As long as the processing of your personal data is carried out on the basis of your consent, you have the right to withdraw it at any time or stage of processing.RIGHT TO COMPLAINT
In any case, if you have questions about how your personal data has been processed, please contact us by e-mail: email@example.com
We are committed to working with you to achieve a fair resolution of any issue regarding the processing of personal data.
If you feel that we have not been able to help you in your matter and you are not satisfied with the ADVSR's action with your personal data, you have the right to lodge a complaint to the Data State Inspectorate of the Republic of Latvia, tel. no.+ 371 67223131: e-mail: firstname.lastname@example.org
ADVSR regularly reviews its internal procedures and makes changes to documents related to the processing of personal data in order to comply with regulatory enactments and to protect the interests of the data subject as much as possible.
Last changes: 11.01.2023.