Limited liability company “C.T.CO”
joint registration number 40003444513

PRIVACY POLICY

This document was prepared and approved on February 12, 2019.

This is LLC “C.T.CO” Privacy policy applicable to LLC “C.T.CO” and its employees, as well as its potential employees, and this document should be read and interpreted accordingly.

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

CONTENT

The headings are for reference only and do not affect construction 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. Cookie Policy

1. Definitions

EEA” – the European Economic Area.
Company” – LLC “C.T.CO”, a limited liability company registered in the commercial register of the Republic of Latvia with joint registration number 40003444513 and registered address at 33 Meistaru Street, Valdlauci, Kekavas district, Kekavas area, LV-1076, 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, 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.
“Potential employee” – a person is considered to be a Potential employee from the moment when the person engages the recruitment process (for example, sends his/her Personal data to the Company or the Company receives his/her Personal data from other persons or from publicly available sources etc.) until when it becomes clear that an offer of employment will not be made or is not accepted by the Potential employee, and such person’s Personal data are eliminated from the Company’s electronic and paper files, or when the offer is made and is accepted by the Potential employee, in which case such person becomes the Company’s current employee.
“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 its employees, as well as its Potential employees, 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.
“Terms and conditions” – the Employment contract and other general and special terms and conditions, covenants, provisions, requirements, instructions, procedures and standards, including this Privacy policy applicable to Your and the Company employment relationships.
“You”, “Your” or “Yourself” – an individual who is a Potential employee, current employee or former employee of the Company.
“Employment contract” – an employment contract concluded between You and the Company, including all its appendixes and amendments.

2. About the Company

2.1. Personal data is processed by the Company - LLC “C.T.CO”, a limited liability company registered in the commercial register of the Republic of Latvia with joint registration number 40003444513 and registered address at 33 Meistaru Street, Valdlauci, Kekavas district, Kekavas area, LV-1076, Latvia.

2.2. The Company are 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 supplements, but does not supersede or replace any other consent which You may have previously provided to the Company. This Privacy policy does not affect any right that the Company may have at law in connection with collection, use and/or disclosure of Your personal data. Please note that this Privacy policy relates only to processing of Your personal data in connection with Your Potential or actual employment with the Company.

3.3. If You are a current employee of the Company, this Privacy policy forms a part of the Terms and Conditions applicable to the Company and Your employment relationships. In the event of any conflict or inconsistency between the provisions of this Privacy policy and other Terms and Conditions applicable to the Company and Your employment relationships, the provisions of this Privacy policy shall prevail.

3.4. For current employees it is recommended that You keep a copy of this Privacy policy and store it for future reference.

3.5. 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: [email protected] or a written application to the address at: LLC “C.T.CO”, 33 Meistaru Street, Valdlauci, Kekavas district, Kekavas area, LV-1076, Latvia.

3.6. 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 applications to the Company.
- When You submit requests to the Company.
- When You and the Company sign the Employment contract.
- When You submit it to the Company during performance of obligations and use of rights set forth in the Employment contract.
- 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 to the Company Your medical check results, sick leaves, child care applications and other applications and their annexes containing Your or Your relatives or family members’ personal data.
- When You respond to the Company’s initiatives.
- When You submit Your personal data to the Company for any other reason.

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.
- Recruitment agencies.
- Social networks.
- Third parties recommending You as Our Potential employee.

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 leased by the Company, due to safety reasons - to prevent or detect criminal offences and to protect Your and other individuals’ vitally important interests.
- the Company’s call recording devices, which may be used to record conversations between You and the Company’s clients and other persons for client service control purposes.
- Checking and viewing e-mails received or sent from e-mail addresses assigned by the Company.
- Screening and checks of a computer and other electronic devices provided by the Company to You.

4.4. In the Company’s leased territory and premises and at the Company’s leased territory and premises You are not permitted to take photos or make videos of other persons, or make other person’s voice recordings. Only persons authorized by the Company are permitted to take photos or make videos of other persons, or make other person’s voice recordings in the Company’s leased territory and premises and at the Company’s leased territory and premises, if the persons, which are being photographed or filmed or whose voices are recorded, have agreed on that in writing.

4.5. You are not permitted to gather and process personal data of other employees of the Company or persons, which are the Company’s clients or employees, customers or representatives of the Company’s clients, suppliers, subcontractors, agents, distributors, service providers and professional advisers, unless it is explicitly an activity directly related to fulfilment of Your work duties as the Company’s employee.

5. The purpose and legal basis for processing personal data

5.1. The Company is processing Your personal data for the following purposes:
- To fulfil the Employment contract or other contracts the Company has with You.
- 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. If You give the Company Personal data, including Sensitive personal data about Yourself or other individuals (like Your relatives or family members), You agree and confirm that these individuals have agreed that the Company can process the said information in the way set out in this Privacy policy.

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

- To manage Your recruitment process (including evaluation and assessment of Your suitability for hiring for particular positions, assessing Your performance, education, experience, etc.).
- To manage short listing.
- To obtain referrals.
- To communicate with You and comply with Your instructions.
- Consideration of a salary amount, bonuses, promotion, supplemental payments, training, sending for a business trip or posting to work in another country.
- Considering and processing applications for continuing skill development and training, including organisation of staff training.
- Providing You with resources and assistance in connection with the performance of Your work duties with Us (including, but not limited to, organizing business-related travel arrangements and business trips).
- Consideration of eligibility for benefits and entitlements.
- Conducting internal investigations and checks, in order to check if the Company’s activities correspond to applicable laws and contractual obligations undertake by the Company and its internal policies and procedures.
- Publishing on the Company’s websites, social network profiles and other purposes related to its marketing and advertising activities (if Your 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 the Employment contract or crime, including screening a computer and other electronic devices and e-mail communication performed by use of an e-mail address provided by the Company to You to prevent theft, fraud and any other crime, and analysing and managing the Company’s commercial risks and reviewing Your compliance with work duties under the Employment contract.
- 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.
- Managing or terminating Your employment relationship with the Company.
- 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.

5.4. 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 application or request, use of Your rights, receiving of Your benefits and advantages, as the case may be.

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
- Financial information (wage, salary, bonus, supplemental payments, pension, benefits, business travel expenses, compensations of other expenses).
- Details about Your payment accounts and tax payments.

Contacts
- First name, last name, other names.
- Date of birth.
- Citizenship.
- Country of tax residence.
- E-mail address.
- Residence and postal addresses.
- Phone numbers.
- Photography.
- Phone number, name and surname of a person to be contacted in case of an emergency situation involving You;
- Any other contact information You provide.

Contractual
- Information about fulfilment of the Employment contract, including working time schedules, performed work reports, information about business trips, courses, etc.

Professional
- This includes details about Your work and occupation, education, experience, skills, languages You know and qualifications.

Behavioural and technical
- Details about how You act in the workplace, including performance and disciplinary action.
- Details on the devices and technology You use.

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.
- Father and mother’s name.
- Details of passport or other identification document.
- Date of birth.
- Country of tax residence.
- Citizenship.
- E-mail address.
- Visas, residence permits.

Open data and public records
- Your comments, opinions and photos made on social network sites (i.e. LinkedIn, Facebook, Instagram or Twitter).
- Public records and information.

Usage data
- Other data about how You use the Company’s material and technical resources, property and other items, as well as benefits assigned by the Company to You.

Documentary data
- Officially issued photos for Your identification.
- Details of passport/identity card/drivers licence or birth certificate of You.
- Birth dates of current employees’ children.
- Details of visa or residence permit in case if You are not a citizen of Latvia.

Special types of data
- Your trade union membership (if You reveal it to the Company or it is publicly available information).
- Your health data.
- Your gender.
- 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).

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 reasons of substantial public interest.
- For employment purposes, including calculation of salaries and taxes due to submission of Your sick leaves, gathering and processing of medical checks and Your health issues or accidents at work.
- 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, agents, distributors or service providers that provide services to the Company such as telecommunications, information technology, recruitment, payment processing, training, 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 customers 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 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 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.
- Your former employers, referral providers and other persons (if Your consent about it has been received).

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, agents, distributors, service providers and professional advisers.

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.
- Personal data is transferred to a recipient, which is located in a country participating in the “Privacy Shield” (a framework that sets privacy standards for information sent between the US and EU countries).

9. Retaining collected personal data

9.1. The Company will retain Your personal data as long as the Company considers You as its Potential employee or You are the Company’s employee and at least for the period necessary for the Company to comply with its legal obligations, applicable laws and for its business purposes.

9.2. Ending reviewing of Your suitability for employment at the Company or ending employment relationships with You for any reason does not mean that the Company deletes personal data that it holds on You. 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: [email protected] or a written application to the address at: LLC “C.T.CO”, 33 Meistaru Street, Valdlauci, Kekavas district, Kekavas area, LV-1076, 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 not 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. Please contact the Company by sending a respective e-mail to: [email protected] or a written application to the address at: LLC “C.T.CO”, 33 Meistaru Street, Valdlauci, Kekavas district, Kekavas area, LV-1076, Latvia, if You want to do so.

11.3. If You are the Company’s Potential employee, then, if You withdraw Your consent, the Company may be unable to assess Your suitability for the vacancy and to conclude an employment contract with You.

11.4. If You are the Company’s current employee, then, if You withdraw Your consent, You may be unable to use Your certain rights, receive benefits or advantages, go on business trips or participate at social or marketing events. If so, the Company will tell You.

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 employment contract with You or You may be unable to use Your certain rights, receive bonuses, supplemental payments, allowance or advantages, go on business trips or participate at social or marketing events.

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.Any changes to this Privacy policy will be notified to You, the current employee, by using Your contact information or in person.

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 66952000, or by sending e-mail: [email protected] or by sending a document to the address: LLC “C.T.CO”, 33 Meistaru Street, Kekavas district, Kekavas area, LV-1076, Latvia.

15. Personal data protection breaches

15.1.The Company’s employees shall inform it by sending e-mail to [email protected] about breaches of personal data processing, unauthorised access to personal data, loss or deletion of personal data, as well as cases of non-compliance or violations of this Privacy Policy.

15.2.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.

15.3. 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:

15.3.1. 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 15.3.2. 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.

15.4. 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.

15.5.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. Cookie Policy

16.1 A cookie is a small text file stored on your computer or mobile device when visiting our website. Cookies can be managed and deleted by setting your browser. However, this may prevent you from properly use certain features on our website.

16.2 By using our website, you consent to the use of those cookies that your browser accepts based on your browser settings. The default setting on most browsers is to accept all cookies. However, you may set your browser to notify you before cookies are accepted, to accept or reject only certain cookies, or to reject all cookies.

16.3 Cookies can be classified as it follows:

Session cookies – These cookies are automatically erased when you close your browser. Persistent cookies – These cookies remain on your device until they expire (in terms of minutes, days or years since the cookie creation/update). Third-Party cookies – These cookies are stored on behalf of third parties.

16.4 The following cookies are used on this website:

Cookie name Purpose Storage period Type of cookie
1P_JAR These cookies are set via embedded youtube-videos. They register anonymous statistical data on for example how many times the video is displayed and what settings are used for playback. 1 month Third-Party
CONSENT These cookies are set via embedded youtube-videos. They register anonymous statistical data on for example how many times the video is displayed and what settings are used for playback. 20 years Third-Party
IDE Doubleclick.net | These are publicity cookies used to improve advertising. Usually used to target publicity according to contents that are relevant for a user, improve performance reports of the campaign and avoid showing advertisements that the user has already seen 1 year Third-Party
NID The NID cookie contains a unique ID Google uses to remember your preferences and other information, such as your preferred language (e.g. English), how many search results you wish to have shown per page (e.g. 10 or 20), and whether or not you wish to have Google’s SafeSearch filter turned on 6 month Third-Party
_ga Used to distinguish users. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. 2 years First party
_gid Used to distinguish users. It stores and updates a unique value for each page visited. 1 day First party
_gat This cookie is a part of Google Analytics' analysis and monitoring service. session Third-Party
qtrans_front_language This cookie is used to display the website in chosen language 1 year ctco.lv