Privacy policy

Processing of client personal data.

We want to offer you the most suitable products and services. To do so, we process your personal data. Process transparency and data privacy are important to us, so we want you to know how and why we collect and analyse your data.

How do we process personal data?

We collect various data necessary to provide our services. We collect it when you apply for our services and products, already use them, or contact us.

We process your data, for example, to provide our services, meet regulatory requirements or improve our products and services. We usually do not store your data longer than necessary for providing our services. In most cases we must comply with laws and regulations governing retention of specific data collected.

You own your personal data, and we want you to know that we respect your privacy. That is why we have updated our Privacy Policy. You can contact us at any time if you have questions.

SIA "Imperum" and SIA "Libera" (hereinafter also "we", "our", "Imperum", "Libera" or "us"), when processing personal data, undertake to protect the privacy of personal data. Our personal data processing is subject to the European Union General Data Protection Regulation (GDPR) and relevant national legislation. This Privacy Policy generally describes how we collect, share and protect personal data. Additional information on personal data processing is included in contracts and other documents related to service provision.

Definitions

Controller — the Controller of your Personal Data is Imperum and/or Libera to which you have submitted your personal data based on contractual or pre-contractual relations, or whose Services you (or the legal entity or arrangement of which you are the beneficial owner) intend to use. Client — a natural person who uses or has expressed intent to use the Service. GDPR — Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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).

Imperum — any legal entity or branch belonging to Imperum.

Libera — any legal entity or branch belonging to Libera.

Personal data — any information relating directly or indirectly to an identified or identifiable Client or other natural person whose data is processed in accordance with this Privacy Policy and applicable law (for example, the beneficial owner of a client that is a legal entity).

Processing — any operation performed on Personal Data (including collection, recording, storage, modification, providing access, requesting, transfer, etc.)

Service — any service provided by Imperum or Libera.

General information

When does this Privacy Policy apply?

This Privacy Policy applies when you use, have used or expressed intent or interest in using Imperum or Libera services. It also applies when a relationship was established before this Privacy Policy took effect, and if you have provided and/or Imperum or Libera obtains your Personal Data.

What Personal Data of mine is processed?

The exact set of Personal Data processed depends on the type of Services and the relationship with Imperum or Libera.

Imperum's core activity is related to procurement monitoring, procurement announcement, legal support and consultancy in public and private procurements.

Libera's core activity is related to journal publishing and organising seminars and conferences.

We process your Personal Data to provide and improve these Services. In addition, Imperum and Libera process personal data of representatives of their corporate, private clients and suppliers. Our collected and processed Personal Data includes: identification data such as name, surname, middle name, taxpayer identification number, phone number (for example, landline and mobile), email address, communication language.

How do Imperum and Libera collect my Personal Data?

Primarily Imperum and Libera obtain Personal Data directly from the person to whom it relates. For example, if you:

• apply to receive Services;
• contact Imperum or Libera (for example, visit our website), or provide Imperum or Libera with your contact information for other reasons;
• when signing various contracts where the other contracting party or representative may not be the Client (for example, a contract or agreement concluded with a legal entity specifying contact person or representative data).

Within the Imperum and Libera undertaking, all Imperum and Libera structural units have access to Personal Data disclosed to Imperum or Libera insofar as such access is necessary for administrative purposes or Imperum and Libera legitimate interests. We obtain your Personal Data from other external sources, such as public and private registers, other companies and state institutions, if it is in our legitimate interests or in cases provided by applicable law.

Why do Imperum and Libera collect and process my Personal Data?

First and foremost, your Personal Data is necessary for us to provide Services to you. Certain Personal Data will always be required regardless of the Service you choose, for example your identification data or contact information, choice of communication language, etc. However, some Services, due to their nature, will require additional information.

Security provision — financial services are threatened by criminal activity. To mitigate these risks we process data — monitor transactions and ensure security of our IT systems.

Advertising and direct marketing

Who receives Imperum and Libera advertising and direct marketing notices?

Our advertising and direct marketing messages (for example, about our Services and related campaigns) are sent to Clients who have agreed to receive direct marketing and advertising offers from Imperum or Libera. Such Clients receive Imperum and Libera offers and direct marketing messages via chosen communication channels. Imperum and Libera may offer their Services to existing Clients based on legitimate interests.

How can I give consent to receive advertising and direct marketing messages?

Clients can give consent to receive advertising and direct marketing messages by signing a direct marketing consent form or requesting direct marketing messages under a contract concluded with us. Clients who already receive direct marketing messages from us will continue to receive such messages after GDPR took effect.

What types of advertising and direct marketing activities do Imperum and Libera carry out?

Imperum and Libera send offers and direct marketing messages. Services and products may also be advertised at various client events organised by Imperum and Libera.

Can I object to use of my Personal Data for direct marketing purposes?

Clients have the right at any time to object free of charge to processing of their Personal Data for direct marketing purposes. To exercise this right, please contact the Imperum or Libera unit whose direct marketing materials you no longer wish to receive. Clients can opt out of our offer and any other advertising and direct marketing messages using the link provided in the email or by following other instructions given in the direct marketing message.

Sharing and protection of personal data

Who can access my Personal Data?

Within Imperum and Libera, only persons authorised to do so may access your Personal Data; Imperum and Libera engaged third parties may also access your Personal Data, as well as other persons whose access is determined or permitted by regulations. If Processing of Personal Data is carried out by third parties on behalf of Imperum or Libera, we engage only third parties that provide sufficient guarantees of implementing technical and organisational measures so that Processing complies with GDPR and applicable law and ensures protection of your rights. Processing operations performed by processors (third parties) are always governed by a Privacy and Data Processing Agreement or other specific conditions agreed between Imperum, Libera and such processor.

How do Imperum and Libera protect my Personal Data?

To protect your Personal Data from unauthorised access, unlawful Processing or disclosure, accidental loss, alteration or destruction, we implement appropriate measures to comply with applicable law. Such measures include technical measures, for example appropriate computer system selection and configuration, securing relevant connections, data and file protection, as well as organisational measures, for example restricting access to such systems, files and objects.

Your rights regarding personal data processing

What are my rights?

We want to ensure that Personal Data Processing is fair and transparent, and that all rights arising from applicable law are always exercisable. In particular you have:

• the right to access your Personal Data that we process. Upon your request Imperum or Libera will: confirm whether Personal Data relating to you is being processed and provide information on processing purposes, categories of Personal Data and recipients or categories of recipients to whom Personal Data has been disclosed; inform you of Personal Data being processed and available information on its sources; provide information on the logic of automated processing of Personal Data in automated decision-making cases.
• the right to request correction of inaccurate Personal Data; if Processing is based on consent, you have the right to withdraw such consent at any time without affecting the lawfulness of Processing based on consent before withdrawal;
• the right to receive Processed Personal Data in a structured, commonly used and machine-readable format, and under certain conditions the right to transmit Personal Data to another Controller;
• under certain conditions the right to request erasure of your Personal Data or restriction of Processing;
• the right to object to Processing of Personal Data for certain purposes and under certain conditions;

You also have the right to lodge a complaint with the supervisory authority — the Data State Inspectorate in Latvia.

How long do Imperum and Libera retain Personal Data?

Personal data is retained in accordance with applicable law and no longer than necessary. The retention period is determined by Imperum and Libera and depends on the relevant contract and the basis for Personal Data Processing. For more information on retention period and principles by which we determine retention of processed Personal Data, please contact us.

Final provisions

Legal confirmation and validity — this Privacy Policy is not a legally binding agreement between Imperum, Libera and the Client; it is our personal data protection guidelines. As we continuously improve and develop our Services and websites, we may from time to time amend our Privacy Policy. Such amendments will not reduce your rights. In case of material changes and if we consider it binding, we will inform you of changes no later than 1 (one) month before they take effect, via our website, postal services, email, messages or other means we choose. The Privacy Policy is also available on request at our client service locations. Have questions? If you have questions or concerns regarding processing of your Personal Data or wish to exercise any of your rights, please call +371 25113311 or write to info@iepirkumi.lv

Effective from 25 May 2018