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ConTrans LLC (ConTrans SIA) Reg. No: 40103688183 Approved in Riga on 02 August 2021 The aim of this Privacy Policy is to provide the Data Subject (natural person) with information about the purposes and extent of personal data processing and protection, and periods of data processing and storage. As part of the fulfilment of business-related tasks of ConTrans SIA (hereinafter: the Company), and in compliance with the requirements of the Commercial Law of the Republic of Latvia, the Law on the prevention of money laundering and terrorism and proliferation financing, and the General Data Protection Regulation (GDPR) – Regulation (EU) No 2016/679 of the European Parliament and of the Council, a natural person may be requested to provide personal information like name, surname, date and place of birth, passport details, personal identity number, home address, telephone, email address, and any other sensitive data. Data Controller and its contact details The personal data controller is ConTrans SIA, Unified registration No 40103688183, registered office: Strelnieku street 9-7, Riga, Republic of Latvia, LV-1010. The Company can be contacted on issues related to personal data processing via email: sr@contrans.lv or in person at the Company’s registered office address. Scope of application of the Privacy Policy Personal data are any information related directly or indirectly to an identified or identifiable natural person (the Data Subject). The Privacy Policy applies to the protection of privacy and personal data of the following categories of natural persons: • customers, customer representatives, potential customers; • agents, agent representatives, potential agents; • contractors, contractor representatives, potential contractors; • any other cooperation partners of the Company; • representatives of governmental, municipal and judicial bodies; and • any other natural persons directly or indirectly related to the Company’s business activity. No data shall be processed, used or transferred to a third party for other purposes than specified in the Company’s Articles of Association. The Company takes care of the Data Subject’s privacy and personal data protection, observes the Data Subject’s right to the lawfulness of personal data protection in accordance with the applicable legal acts: the Personal Data Protection Law, Regulation (EU) No 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 (hereinafter: the Regulation), and other applicable legal acts in the field of privacy and data processing. This Privacy Policy applies to data processing regardless of the form and environment in which the Data Subject provides personal data (through the Company’s websites, via email, by phone or in person), and in which systems of the Company or in paper format they are processed. Purposes of personal data processing The Company processes personal data for the following purposes: • for the performance of the Company’s business operations, including, but not limited to: • person identification; • execution and signing of contracts and/or invoices; • provision of services; • fulfilment of obligations; • reviewing and processing of statements, complaints and other documents; • administration; • receiving applications for registration on the Company’s website; • other purposes related to the Company’s business operations; • for the submission of information to governmental, municipal and judicial bodies and operational entities in such cases and extent as specified in the applicable legislation; • other specific purposes of which the Data Subject is informed at the time of submission of relevant data to the Company. Processing of personal data The Company processes personal data using the options provided by modern technologies, taking into account the existing privacy risks and the available organizational, financial and technical resources. Processing of personal data through social media If the Data Subject chooses to access the Services through his/her social media account (e.g. Facebook, Twitter, Google + or YouTube), on social networks (for example, Facebook, Twitter, Google + YouTube), or clicks on one of the connect buttons or links on social networks (e.g. the Facebook “Like” button) that are available on the Services, the content and personal information will be shared with social networks. The Data Subject is aware of and agrees to the fact that the use of his/her data, including the information he/she transmits via the Services on social networks, is governed by their respective privacy policies. Categories of recipients of personal data The Company shall not disclose to third parties any personal data or information obtained in the course of cooperation, except in the following cases: • if personal data are to be transferred to a specific third party under a contract for the performance of any function necessary for the fulfilment of the contract or any function delegated by law; • in cases referred to in the applicable regulations, upon a reasonable request from relevant persons, and in observance of the established procedure and extent; • in the cases referred to in the applicable regulations to protect the legitimate interests of the Company, e.g., by applying to court or other state bodies against a person who has infringed upon the Company’s legitimate interests. Data processing/retention periods Personal data processing periods shall be subject to the Contract entered into with the Data Subject, and will depend on the period of fulfillment of obligations in accordance with the Data Subject’s order for the provision of services, the limitation period, the storage periods for documents in accordance with the applicable regulations, other legal requirements, and the validity period of the Data Subject’s consent to the processing of personal data. Upon the expiration of the above-mentioned periods, personal data shall be archived, deleted or removed. Access to personal data and other rights of the Data Subject The Data Subject shall make a decision to provide his/her personal data to the Company and give consent to data processing of his/her own free will, without coercion, and acting in his/her own interests. Consent to data processing may be given by the Data Subject or his/her representative in any form that allows to confirm the fact of receipt. Normally, such consent is given when sending requests to the Company or entering into contracts/agreements with the Company, or through implicative actions performed by the Data Subject on the Company’s webpages, or when contacting the Company for services via email, by phone or in person. The Data Subject has the right to receive information specified in the applicable laws and regulations regarding the processing of his/her personal data. Besides, in accordance with the applicable laws and regulations, the Data Subject has the right to request from the Company access to his/her personal data, and may also request supplementation, correction or deletion thereof, or request restriction of the extent of data processing with regard to the person, or object against data processing (incl. processing of personal data based on the lawful (legitimate) interests of the Company), and has also the right to withdraw his/her consent to the data processing. The Company may continue data processing without the Data Subject’s consent on such grounds as referred to in the Law. The Data Subject may submit a request to exercise his/her rights in either of the following ways: • in writing: by sending a relevant request to the mail address of the Company’s registered office; or • via email: in the form of a letter sent to the Company’s email address and signed using a secure electronic signature. Upon receipt of the Data Subject’s request to exercise his/her rights, the Company shall verify the Data Subject’s identity, review the request and execute it in accordance with the applicable laws and regulations. The Company shall send a reply to the Data Subject by registered mail to the Data Subject’s indicated contact address or via email, taking into consideration, where possible, the Data Subject’s instructions regarding the replying method. The Company ensures the compliance of data processing and protection with the requirements of laws and regulations, and in case of the Data Subject’s complaint, takes reasonable steps to resolve the complaint. However, if this fails, the Data Subject shall be entitled to apply to the supervisory authority – the Data State Inspectorate. Communication with the Data Subject The Company shall communicate with the Data Subject using the contact details provided by the latter (phone number, email address, postal address). Communication regarding the fulfilment of the contractual obligations shall be carried out by the Company on the ground of a signed. Intellectual and industrial property All content represented on the webpages of the Company (texts, graphics, photographs, logotypes, figures, sources, audiovisual or sound elements, etc.) shall be deemed as the Company’s intellectual and/or industrial property. Any use of all or part of the content of the webpages, made in any way or manner (electronically, mechanical or otherwise) is strictly prohibited. Violation of such rights may lead to the commencement of judicial, civil or criminal action. No link to webpages may be installed without prior express consent of the Company. Other provisions The Company has the right to make additions to the Privacy Policy and publish an updated version hereof on the Company’s website.