Processing of personal data
Second Wind, represented in Latvia as SIA SANDERLINK (registered office: Rīga, Puškina iela 22 – 8, LV-1050) is designated as the data controller which determines the purposes of the processing of personal data (‘personal data’ means any information relating to private persons). The purposes of the processing of personal data are as follows: client record-keeping; provision, supply and maintenance of services, personnel recruitment.
The processing of personal data is carried out in accordance with the Personal Data Processing Act of the Republic of Latvia (Article 25).
Full version: Privacy Protection Rules
Privacy Protection Rules
INFORMATION ABOUT DATA CONTROLLER
Second Wind, represented in Latvia as SIA SANDERLINK(hereinafter also referred to as the Company),
Registration Number:40203391774,
Registered Address: Rīga, Puškina iela 22 – 8, LV-1050.
You may contact us as follows:
by calling (+371) 25 893 775;
by e-mailing to: info@sanderlink.com
WHAT KIND OF YOUR PERSONAL DATA DO WE PROCESS?
For the purposes specified in the Rules and within the scope of the intended purposes, we process your Personal Data sets (categories) as follows:
Your identification data
First name, surname, identity number, date of birth, information specified in your identification document (passport or ID card).
Your contact information
Information to contact you, residential address, correspondence address, telephone number, email address.
Your financial information
Your bank account number, cash flow, i.e. incoming and outgoing payments and information included thereof, transaction history, loan obligations and other obligations; personal and real property owned by you, financial experience, choice and purposes of investment services, trade requests, executed transactions in financial instruments.
Information relating to your immigration residence
Your country of birth, residence, taxpayer number, nationality, place of tax residence.
Information relating to your education and family
Information about your education, family status and family members.
Information relating to your professional activity
Your place of work, profession, position, occupation, trade union membership, length of service.
HOW DO WE OBTAIN YOUR PERSONAL DATA?
We obtain your Personal Data:
when you provide it to us:
- while applying for products and services;
- while addressing us by mail, email, over the phone;
- when you use our products and services,
- while visiting our homepages and using remote services
when third parties provide it to us:
- our counterparties which provide to us information relating to you, conduct market research, provide services within the framework of loyalty programmes.
FOR WHAT PURPOSES AND ON WHAT GROUNDS DO WE PROCESS YOUR PERSONAL DATA?
- Provision of marketing activities
Within the scope of this purpose, we could send you commercial messages, ensure your participation in our marketing activities by sending you information about the services and products that we think may be of interest to you as well as publish materials from our public events. For this purpose, we may need your contact information. The main legal basis for the fulfilment of the above purposes are as follows: – consent of the data subject (Article 6 (1)(a) of the General Data Protection Regulation); – entry into and performance of a contract with the data subject (Article 6(1)(b) of the General Data Protection Regulation); – legitimate interests of the data controller (Article 6 (1)(f) of the General Data Protection Regulation), for instance, to ensure communication, sending of information about the most recent services and products. - Proper provision of services
Within the scope of this purpose, we would need to maintain and improve the technical system and IT infrastructure ensuring proper provision of services. For this purpose, we may need to process any of your personal data referred to in Subclause a) of this Notice in accordance with the need for the processing thereof. The main legal basis for the fulfilment of the above purposes are as follows: – legitimate interests of the data controller (Article 6 (1)(f) of the General Data Protection Regulation).
FOR HOW LONG DOES THE COMPANY STORE YOUR PERSONAL DATA?
According to the general procedure, the Company is entitled to store your personal data for 10 years as from the moment of termination of business relationships unless the laws and regulations set other time-limits for storing the data. The Company complies with this general time limit for storing the client’s personal data:
- to respond to questions or complaints or demonstrate that the Company has fulfilled its obligations towards you in good faith;
- to meet the requirements of the laws and regulations that provide for storage of various types of documentary information.
IMPORTANT: Upon expiry of the data storage period, your personal data are being destroyed in a secure way.
WHO PROCESSES YOUR PERSONAL DATA?
We implement the respective measures to process your personal data in accordance with the applicable legislation and ensure that your personal data is not accessed by third parties who do not have the appropriate legal basis for the processing of your personal data.
If necessary, your personal data may be accessed by:
- our employees or directly authorised persons who need it to perform their official duties;
- third parties who guarantee the customer’s obligations, for instance, immigration lawyers, regional centers, economists, corporate lawyers and others whose involvement is required to perform the services requested;
- supervisory authorities in the cases specified by the legislation;
- third parties upon thorough assessment of whether such data transfer has an appropriate legal basis: law enforcement authorities, tax authorities, sworn bailiffs, investigation bodies in the cases specified in the legislation; sworn notary offices; courts, out-of-court dispute resolution bodies, bankruptcy or insolvency administrators.
WHOM CAN YOUR PERSONAL DATA BE TRANSFERRED TO?
The Company may forward your personal data (incl. other information) to external organisations to ensure provision of the Company’s services, to manage the Company business.
The Bank may forward your personal data (incl. other information) to the following external organisations:
- public institutions – depending on the legal obligation the Company must fulfil;
- persons or organisations involved in the provision of immigration services – depending on your chosen Company’s services or products, e.g. to the Company’s representatives, intermediaries, contractors or other third parties such us immigration Lawyers, Regional centers, economists;
ARE YOUR PERSONAL DATA BEING COMMUNICATED BEYOND EUROPIAN UNION OR THE EUROPEAN ECONOMIC AREA?
The Bank may pass your personal data (incl. information on you) beyond the European Union or the European Economic Area in the following cases:
- based on your service request – e.g. in cases where services to be performed by US immigration Lawyers, Regional centers, economists and other consultants involved in service performance ;
- to fulfil a legal obligation applicable to the Company.
WHAT ARE YOUR RIGHT IN RELATION TO THE PROCESSING OF YOUR PERSONAL DATA?
Personal data updating
If there are changes in the personal data you have provided to us, for instance, changes in your identity number, identification document data, contact address, telephone number or e-mail, you may at your full discretion contact us and provide us with the up-to-date data.
To access and rectify your personal data In accordance with the provisions of the General Data Protection Regulation you are entitled to request that we ensure access to your personal data at our disposal, request its:
- rectification,
- erasure,
- processing restriction,
- object to processing of your personal data,
- portability in the cases and under the procedure specified in the General Data Protection Regulation.
We respect your right to access your personal data and to control it, therefore, upon receipt of your request, we will reply to it within the terms defined by laws and regulations (usually, latest within one month, unless this is a special request where more time is needed for preparing a reply), and, if this is possible, we will update or erase your personal data accordingly.
Withdrawal of the consent
If your personal data processing of is based on your consent, you are entitled to withdraw it at any time, and we will not further process your personal data which we were processing based on your consent for that purpose.
You may also object to the processing of your personal data if personal data processing is based on legitimate interests or is used for marketing purposes (for instance, sending of commercial notices).
Submission of a request You can obtain information about your personal data available to the Bank or exercise your other rights as the data subject in one of the following ways:
- by sending the respective application to us by post to the following address: Rīga, Puškina iela 22 – 8, LV-1050; 3) by sending the respective application (signed with a secure electronic signature) to us electronically to our e-mail: info@sanderlink.com
Upon receipt of your application, we will evaluate its content and the possibility of identifying you. Depending on the situation, we reserve the right to ask you to additionally identify yourself to ensure the security of your data and its disclosure to the respective person.
If you believe that we were not able to resolve the issue and you believe that we are violating your right to the protection of personal data, you are entitled to file a complaint with the State Data Inspectorate. Sample applications for the State Data Inspectorate and other related information may be found on the State Data Inspectorate’s website (http://www.dvi.gov.lv/lv/datu-aizsardziba/privatpersonam/iesniegumu-paraugi/).