Joint venture limited liability company – Kopuzņēmums sabiedrība ar ierobežotu atbildību “UNICO”

joint registration number 50003419791

PRIVACY POLICY

This document is effective since June 14, 2021.

This is the Privacy policy of Kopuzņēmums sabiedrība ar ierobežotu atbildību “UNICO”, hereinafter – “the Company”, applicable to the Company and any natural person the Company deals or cooperates with.

This Privacy policy may be made available in several languages; all versions are legally binding, but in the event of inconsistency between Latvian version and a translated version, Latvian version prevails.

This Privacy policy describes how personal data (identifiable information) of natural persons will be collected, used and shared by the Company, including information collected on its website: www.deglavarezidence.lv. This Privacy policy also describes natural person’s options and rights for using, accessing and correcting or deleting his/her personal data.

CONTENT

The headings are for reference only and do not affect content and interpretation.

1. Definitions
2. About the Company
3. Scope of this Privacy policy
4. Collection of personal data
5. Purpose and legal basis for processing personal data
6. Personal data that the Company may process and groups of the personal data
7. Disclosure of collected personal data
8. Transfer of personal data to other countries
9. Retaining collected personal data
10. Your rights
11. Your consent and how to withdraw it
12. If You choose not to give personal data
13. Changes to this Privacy policy
14. Contacting the Company. Correction of Your personal data
15. Personal data protection breaches
16. Legal background

1. Definitions

“EEA” – the European Economic Area.

“Company“ – Kopuzņēmums sabiedrība ar ierobežotu atbildību “UNICO”, a limited liability company registered in the commercial register of the Republic of Latvia with joint registration number 50003419791 and registered address at 12 – 123 Ropazu Street, Riga, LV-1039, Latvia.

“non-personal data” – information on which basis an individual is not distinguishable from other individuals, including anonymised personal data.

“personal data“ – means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, surname 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.

“process” or “processing“ – means collecting, recording, storing, using, adapting, disclosing, transferring or deleting personal data and/or non-personal data.

“Privacy policy“ – this Privacy policy concerning the Company and any natural person the Company deals or cooperates with, as may be amended from time to time.

“sensitive personal data” – personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.

“You“, “Your“ or “Yourself“ – a natural person who is asked or who chooses to submit to the Company his/her non-personal data or personal data, for example, a buyer of the Company’s property, a potential or current employee or representative of the service provider.

2. About the Company

2.1. Personal data is processed by the Company – Kopuzņēmums sabiedrība ar ierobežotu atbildību “UNICO”, a limited liability company registered in the commercial register of the Republic of Latvia with joint registration number 50003419791 and registered address at 12 – 123 Ropazu Street, Riga, LV-1039, Latvia.

2.2. The Company is the data controller responsible for Your personal data. The Company processes Your personal data in the line with applicable data and privacy laws and regulations. Your personal data will be used only for the purposes and in the manner, as set forth in this Privacy policy.

3. Scope of this Privacy policy

3.1. This Privacy policy lets you know how the Company will look after and manage Your personal data. In particular, this Privacy policy:

• Contains information on the personal data the Company collects about You.
• Describes how the Company processes Your personal data.
• Informs You about persons with whom Your personal data might be shared with.
• Informs You about Your rights and how to exercise them.

3.2. This Privacy policy does not affect any right that the Company may have under applicable law in connection with collection, use and/or disclosure of Your personal data.

3.3. If You have concluded any agreement with the Company, then this Privacy policy forms an integral part of the agreement. In the event of any conflict or inconsistency between the provisions of this Privacy policy and the agreement You concluded with the Company, the provisions of this Privacy policy shall prevail.

3.4. If You have any question about the Company’s practices concerning personal data protection that are not addressed in this Privacy policy, please contact the Company by sending a respective e-mail to: sales@deglavarezidence.lv or a written application to the address at: Kopuzņēmums sabiedrība ar ierobežotu atbildību “UNICO”, 12 – 123 Ropazu Street, Riga, LV-1039, Latvia.

3.5. By submitting personal data to the Company, You agree to their transfer, storing and processing as stated in this Privacy policy.

4. Collection of personal data

The Company may collect information about You from these sources:

4.1. You give personal data to the Company:

• When You submit or send to the Company letters, emails, applications or consents.
• When You and the Company conclude any agreement.
• When You respond to the Company’s requests for additional personal data.
• When You ask to be included in an email or other mailing list.
• In communications between You and the Company by using telephone, email, SMS or other means of communications.
• When You submit Your personal data to the Company for any other reason.
• When You submit Your personal data to a third party to be shared with the Company.

4.2. The Company may receive Your personal data from:

• State Revenue Service, Social Security Agency, courts, prosecutors, police, State Probation Service, Custody Courts and other state and municipality institutions and law enforcement agencies according to competence of these institutions and agencies set forth by legal acts.
• Social networks.
• Third parties recommending or introducing You as the Company’s potential employee, service provider, seller, cooperation partner or buyer of the Company’s property.

4.3. The Company may also obtain Your personal data from:

the Company’s video surveillance cameras, which are set up in the territory or premises owned by the Company, due to safety reasons – to prevent or detect criminal offences and to protect Your and other individuals’ vitally important interests.

5. The purpose and legal basis for processing personal data

5.1. The Company is processing Your personal data for the following purposes:

• Conclusion and signing of any agreement with You.
• Fulfilment of any agreement the Company has with You.
• Relationship establishment with the Company’s potential employees, service providers, sellers, cooperation partners or buyers of the Company’s property.
• Relationship establishment with potential buyers of the Company’s property and analysis of such relations within the context of advertising and marketing activities.
• Provision of advertising and marketing activities: informing, communication, sending of notifications, which are connected with products, services and properties traded by the Company.
• Processing of transaction data in accordance with the Law on Accounting and the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing.
• For improving the client service quality.
• When it is the Company’s legal obligation to do so (processing of Your personal data is necessary for the Company to comply with the applicable law).
• When it is in the Company’s legitimate interests. This is when the Company has a commercial reason to use Your personal data. However, when the Company processes Your personal data for its legitimate interest, such processing must not unfairly go against what is right for You or is in Your interests.
• Where You consent to it.

5.2. The Company may use Your personal data in the following ways:

• To obtain referrals.
• To communicate with You and comply with Your instructions.
• Publishing on the Company’s websites, social network profiles and other purposes related to its marketing and advertising activities (if Your explicit written consent about it has been received).
• Responding to Your queries and requests.
• Managing the Company’s business operations and complying with internal policies and procedures.
• Facilitating business asset transactions (this may extend to any merger, acquisition or asset transfer, purchase or sale) involving the Company.
• Using of any of Your personal data for analytical and statistical studies concerning the Company’s business processes.
• Preventing, detecting, reporting and investigating cases on failure to fulfil obligations deriving from any agreement the Company has with You.
• Protecting and enforcing the Company’s contractual and legal rights and obligations.
• Assisting in any investigation by a law enforcement agency where it has a suspicion of crime committing.
• Complying with legal obligations and regulations, and to provide information to State Revenue Service, Social Security Agency, courts, prosecutors, police, State Probation Service, Custody Courts and other state and municipality institution and law enforcement agencies according to competence of these institutions and agencies set forth by the applicable law.
• Any other ways of use set out in this Privacy policy or applicable law.
• Any other ways of use the Company deems necessary for protection of the Company’s legitimate interests.

5.3. You should ensure that all personal data submitted by You to the Company is complete, accurate, true and correct. Failure on Your part to do so may result in delay or inability to process Your letter, email, application or request or to conclude an agreement with You by the Company or to fulfil any agreement the Company has with You.

6. Personal data that the Company may process and groups of the personal data

6.1. The Company may process different kinds of personal data. It gathers personal data in the following groups:

Group and type of personal data that could be included within the group

Financial data

• Details about Your payment accounts and related information.

Contacts

• First name, last name, other names.
• Date of birth.
• Country of tax residence.
• E-mail address.
• Residence and postal addresses.
• Phone numbers.
• Any other contact information You provide.

Contractual

• Information about fulfilment of any agreement the Company has with You.

Communications

• Information and Your comments and opinions disclosed in Your communications, for example, content of a complaint or question submitted to the Company.

Social relationships

• First name, last name, other names.
• Personal ID.
• Place of the birth.
• Date of birth.
• Details of passport or other identification document.
• E-mail address.

Open data and public records

• Public records and information.

Documentary data

• Details of passport or identity card.

Special types of data

• Your criminal convictions and offences (if You reveal it to the Company or it is publicly available information, or it is legally provided to the Company by third parties).
• Verification of Covid-19 negative test or vaccination or similar as set by applicable laws.

Consents

• Any permissions, consents or preferences that You give to the Company.

6.2. The Company might only use Sensitive personal data, when it is necessary:

• For detection and prevention of crime, including fraud.

For preparation, exercising or defending legal claims.

7. Disclosure of collected personal data

7.1. Personal data will be protected and kept confidential, but, for the Company to fulfil its contractual obligations, to use its rights or to fulfil requirements of the applicable laws, Your personal data may be disclosed or transferred to the following persons (as applicable):

• Companies within the same group of companies as the Company and other companies related to the Company.
• The Company’s suppliers, cooperation partners, sales agents, distributors or service providers that provide services to the Company such as telecommunications, information technology, payment processing, storage and archival, and other.
• Companies providing services in relation to insurance and/or reinsurance to the Company.
• Banks and other payment services providers that provide financial services to the Company.
• The Company’s clients and clients of the Company’s clients to which the Company provides services or sells goods directly or indirectly to the extent required for fulfilment of the Company’s obligations;
• Anyone to whom the Company transfers or may transfer its rights or duties.
• the Company’s professional advisors such as sales agents, evaluators, accountants, auditors, lawyers, etc.
• The Company’s business partners, sub-contractors and other persons providing services to it or its clients.
• The Company’s business partners, investors, assignees or transferees and/or their advisers (actual or prospective) to facilitate business asset transactions in which the Company is involved and which may be any type of merger, acquisition or asset transfer, purchase or sale. If the transaction goes ahead, the buyer, seller, transferee or merge partner may process Your personal data in the same way as set in this Privacy policy.
• Persons to whom You ask to share Your personal data with.
• The Company’s websites, social network profiles and other marketing and advertising materials (if Your explicit written consent about it has been received).
• Any judicial, governmental and law enforcement authorities or any other institution or agency having jurisdiction over the Company.
• Any other person in connection with the purposes set forth in this Privacy policy or applicable law.

7.2. Where a third party process Your personal data on the Company’s behalf, it is subject to strict security and confidentiality rules consistent with this Privacy policy and applicable laws. The Company will take all steps reasonably necessary to ensure that the said third party processes Your personal data securely and in accordance with this Privacy policy and applicable laws.

7.3. Third parties to which the Company discloses Your personal data are governed by a contract and applicable laws and are not permitted to use Your personal data for a secondary purpose (namely, otherwise as provided in this Privacy policy). Processing of personal data by such third parties for their own purposes is subject to their respective privacy policies and applicable laws.

7.4. The Company will not sell or rent any of Your personal data to third parties. It does not share Your personal data with third parties for their marketing purposes without Your consent.

8. Transfer of personal data to other countries

8.1. The Company may only send Your personal data outside of the European Economic Zone (“EEA”), to:

• Follow Your instructions.
• Fulfil the Company’s obligations.
• Work with the Company’s clients.
• Work with the Company’s suppliers, subcontractors, sales agents, distributors, service providers and professional advisers.
• Report to the Company’s shareholders on its activities.

8.2. If the Company does transfer Your personal data outside of the EEA, it will make sure that the personal data is protected in the same way as if it was used in the EEA. The Company will take all steps reasonably necessary to ensure that Your personal data is treated securely and is processed in accordance with this Privacy policy. If the Company transfers Your personal data outside of the EEA, it will make sure that one of the following safeguards is put in place:

• Personal data is transferred to recipient located in a country outside EEA, but in which effective privacy laws give the same protection as in the EEA.

A contract is concluded with the recipient according to which the recipient is obliged to protect personal data according to the same standards as in the EEA, or You provided Your consent.

9. Retaining collected personal data

9.1. The Company will retain Your personal data for 5 (five) years after legal relations the Company has with You are terminated or in case no legal relations were established – 5 (five) years from receipt of Your personal data or for a longer term if it is necessary for the Company to comply with its legal obligations or applicable laws.

9.2. The Company is entitled to continue keeping Your personal data for up to 10 (ten) years for the following purposes:

• To respond to an application, question or complaint.
• To show that the Company treated You fairly.
• To establish, exercise or defend legal claims.
• To maintain records required by the applicable law.
• For the Company’s legitimate interests.
• To comply with the applicable law.

9.3. The Company may also keep Your personal data for longer than 10 (ten) years for legitimate interests, research or statistical purposes or if so determined by applicable laws. If the Company does so, it will make sure that the privacy of Your personal data is protected and that Your personal data is only used for afore-mentioned purposes.

10. Your rights

10.1. You have certain rights that may be exercised regarding processing of Your personal data. To exercise Your rights mentioned below, please contact the Company by sending a respective e-mail to: sales@deglavarezidence.lv or a written application to the address at: Kopuzņēmums sabiedrība ar ierobežotu atbildību “UNICO”, 12 – 123 Ropazu Street, Riga, LV-1039, Latvia.

10.2. Accessing Your personal data. You may have the right to access personal data the Company holds about You and to require it to provide certain information regarding its processing of Your personal data. The Company may request to prove Your identity before it discloses any information to You. This is known as the ‘right of access’.

10.3. Letting the Company know if Your personal data is incorrect. You have the right to question any information the Company has about You that You think is wrong or incomplete. If You do, the Company will take reasonable steps to check accuracy of information and correct it, if necessary. This is known as the ‘right to rectification’.

10.4. Requiring not processing Your personal data. You have the right to ask the Company to delete, remove or stop using Your personal data, if there is no need for the Company to keep it. Even if You object to the use of Your personal data, the Company may still process it due to legal or other official reasons, such as legal claims, or to exercise its legal rights. However, please tell the Company if You think that it should not be using Your any personal data. This is known as the ‘right to erasure’ or the ‘right to be forgotten’.

10.5. Restricting processing of Your personal data. You have the right to restrict processing of Your personal data. In this situation the Company would not use or share Your personal data while it is restricted, except if the Company needs to use it for certain things, such as legal claims or exercising its legal rights. This is known as the ‘right to restriction of processing’.

10.6. You can ask the Company to restrict use of Your personal data if:

• It is not accurate.
• It has been used unlawfully; however, You do not want the Company to delete it.
• It is not relevant any more, however, You want the Company to keep it for use in case of legal claims or other purposes.
• You already asked the Company to stop using Your personal data, but You are waiting for the Company to tell You if it is or is not permitted to continue using it.

10.7. Receiving Your personal data. You have the right to receive Your personal data that the Company processes by automated means on the basis of Your written request. In this situation the Company will provide Your personal data to You in a format that can be easily re-used. You can also ask the Company to pass on Your personal data in this format to other persons, and, if technically feasible, the Company will do so. This is known as the ‘right to data portability’.

10.8. Objecting to processing of Your personal data. You have the right to object to processing of Your personal data by the Company. Even if You object to processing of Your personal data by the Company, it may still process Your personal data due to legal or other grounded reasons, such as legal claims, its legitimate interests or exercising its legal rights. However, please tell the Company if You think that it should process Your personal data. This is known as the ‘right to object’.

11. Your consent and how to withdraw it

11.1. The Company may ask You to issue consent in a form of a separate written or electronic format for processing of Your personal data for purposes for which the Company shall receive Your consent under this Privacy policy or applicable laws. You will decide at Your discretion either to issue such consent or not, by making respective marks in the document prepared by the Company.

11.2. You can withdraw Your consent to process Your personal data for the specific purpose at any time. If You want to do so, please contact the Company by sending a respective e-mail to: sales@deglavarezidence.lv or a written application to the address at: Kopuzņēmums sabiedrība ar ierobežotu atbildību “UNICO”, 12 – 123 Ropazu Street, Riga, LV-1039, Latvia.

12. If You choose not to give personal data

12.1. If You choose not to give the Company Your personal data, the Company may be unable to conclude an agreement with You or to commence any other legal relation with You.

13. Changes to this Privacy policy

13.1. The Company may from time to time update this Privacy policy to ensure that it is consistent with the Company’s future developments, technology improvements and/or any changes in legal or regulatory requirements.

13.2. If You and the Company have an effective agreement, then any changes to this Privacy policy will be notified to You by using Your contact information or in person. In other cases the updated version of this Privacy Policy will be published on the Company’s website.

14. Contacting the Company. Correction of Your personal data

14.1. If You have any questions or complaints relating to processing of Your personal data, or You would like to make corrections or get a copy of Your personal data records, please contact the Company, by calling at: +371 24778822, or by sending e-mail: sales@deglavarezidence.lv or by sending a document to the address: Kopuzņēmums sabiedrība ar ierobežotu atbildību “UNICO”, 12 – 123 Ropazu Street, Riga, LV-1039, Latvia.

15. Personal data protection breaches

15.1. In the case of a personal data breach, the Company shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority, unless the personal data breach is unlikely to result in a high risk to Your rights and freedoms.

15.2. When the personal data breach is likely to result in a high risk to Your rights and freedoms, the Company shall communicate the personal data breach to You without undue delay, unless:

15.2.1. The Company has implemented appropriate technical and organisational protection measures, in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption or

15.2.2. The Company has taken subsequent measures which ensure that the high risk to Your rights and freedoms referred to is no longer likely to materialise.

15.3. The third party, which processes Your personal data on the Company’s behalf, shall notify the Company without undue delay after becoming aware of a personal data breach.

15.4. The Company shall document any personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken.

16. Legal background

16.1. This Privacy policy is based on 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) and provides appropriate protection for the processing of your personal data in accordance with the General Data Protection Regulation and other laws and regulations applicable in the Republic of Latvia.