Your controller of personal data is Сonway Container Solutions SIA (hereinafter referred to as “Conway”, “we”, “us” or “our”) in accordance with applicable data protection legislation. Conway is responsible for ensuring that your personal data is processed in accordance with this Policy and applicable data protection laws. Contact details of the data controller: Conway Container Solutions SIA Legal address: Riga, Martas Rinkas Street 7 - 47, LV-1015 Registration number, date: 40203131241, 16.03.2018 Tel. +371 67885083 Contact details of the data protection officer or privacy officer: Address: Riga, Baznicas street 31 - 13, LV-1010, Latvia2. COLLECTION OF PERSONAL DATA
We may collect your personal information in a variety of ways, as set out below. In general, you provide us with the personal information we process when you rent equipment from us or when you otherwise cooperate with us (for example, by filling out our online forms or visiting our customer service centers). We may also collect personal data from external sources, such as publicly available sources. The personal data we collect includes, for example, the following categories of data:
• general personal data, such as name, surname, date of birth and personal identification number, identification document data, VAT number;
• Contact information, such as email address, address, and phone number. We may collect information from corporate clients related to your position and contact information in the company you represent, as well as information about your power of attorney (representation);
• information related to the customer relationship, such as customer communication, customer contact information and answers provided, feedback and research on the quality of our services, billing and credit information, information on rental equipment details of your contract;
• language settings;
• insolvency assessment and indebtedness data (including the start and end dates of indebtedness, the amount of debt, the address of the object and other data we receive from debt collection or credit information companies); and
• correspondence or other data created in the course of performance of the contract.3. PURPOSE AND LEGAL BASIS OF THE PROCESSING OF PERSONAL DATA
We process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC data protection Regulation): paragraph 1 (a) (consent of the data subject), point (b) (for performance of the contract or pre-contractual measures), point (c) (to fulfill the legal obligation of the controller) and (f) (in accordance with legitimate interests of the controller).
1. Service delivery and customer relationship management
The main purpose of collecting your personal data is to provide you with our services, perform a contract or prepare a contract, and manage and maintain the customer relationship between us and you / the company you represent as a manager, employee, representative or in any other way. In this case, the processing of personal data is based on an agreement between you and us, or on our legitimate interests if the agreement is between the company you represent and us. We are committed to processing your personal data in an appropriate, fair and efficient manner for this purpose.
We may send you emails to keep you informed of our services, ask for your feedback, or provide you with other relevant information about our services. In this case, the processing of personal data is based on our legitimate interest in providing you with relevant information about Conway and promoting our services, as well as improving our current business model. You can opt out of marketing communications at any time. If applicable law requires the processing of your personal data for the purpose of sending marketing communications, we will only process your personal data on the basis of your consent.
3. Service development and information security
We also process personal data to improve the quality of our services and to develop new services. In this case, the processing of personal data is based on our legitimate interest in ensuring that we have access to sufficient and relevant information to develop our services.
4. Invoice related data
We also process personal data to meet our obligations under applicable accounting and tax laws. In these cases, the processing of personal data is based on mandatory legal obligations that require us to store certain data for accounting purposes.
5. Data related to solvency assessment and debt recovery
We also process your personal data to assess the solvency of you or the company you represent. We also perform this assessment to manage information about your debt to us and your solvency potential. If our bills are not paid on time or our equipment is not returned on time, we may process personal data to publish relevant information in any debtors' register or database (for example, SIA “Lursoft” in the database “Customer Portfolio”, SIA “Balt Risk” riskNet database) to provide information to legal service providers in order to facilitate the debt recovery process. In such cases, the processing of personal data is based on our legitimate interest in ensuring that we have the opportunity to continue our business, as well as the protection of our business interests, and our legal interest in receiving payment for our services. 6. Data related to legal requirements If necessary, we may process personal data to secure our legitimate interests in establishing, enforcing or defending against legal claims arising from an agreement between us and you, or between us and the company you represent.4. TRANSFER AND DISCLOSURE OF PERSONAL DATA
We may disclose personal information to third parties:
• when permitted or required by law, for example to respond to requests from competent authorities or in connection with legal proceedings;
• when our trusted service providers provide us with services on our behalf and in accordance with our instructions. We will control and always be responsible for the use of your personal data;
• when necessary to facilitate the debt recovery process; please note that we have the right to transfer personal data to companies providing debt collection services from the moment you violate the terms of the agreement between us;
• if we are involved in the aggregation, acquisition or sale of all or part of our assets; and
• when we believe in good faith that disclosure is necessary to protect our rights, the safety of you or others, to investigate cases of fraud or to respond to a request from a governmental authority. In particular, we may disclose personal information:
• our employees who are responsible for working with customers and maintaining relationships, as well as those employees who perform accounting, IT maintenance, business analysis and business planning functions;
• our IT system vendors and managers, which we use to ensure the maintenance of our customer relationships;
• The State Revenue Service and other state institutions when the transfer of such data is required by law;
• our data controllers and other persons involved in the performance of the contract;
• persons who help us to exercise our rights under the terms of the agreement (persons providing debt collection and recovery services, legal entities, consultants, courts, credit information companies, etc.);
• potential parties to a merger, acquisition, or sale of all or part of our assets.5. TRANSFER OF PERSONAL DATA OUTSIDE THE EU / EEA
We do not transfer your personal data outside the European Union or the European Economic Area.6. COOKIES
Your personal data will only be kept for as long as is necessary to achieve the purposes set out in this Policy or in accordance with applicable law. Most of your personal information will be stored during the customer relationship with Conway. Some personal data may also be retained after the end of the customer relationship, if required or permitted by national law. For example, we will keep accounting documents, accounting supporting documents or documents proving the provision of our services for accounting purposes for 5 or even 10 years. (for example, a copy of the lease agreement, invoices), in accordance with the requirements of the Law “On Accounting”. When the retention of your personal data is no longer required by law or by any person's rights or obligations, we will delete your personal data.8. YOUR RIGHTS
You have the right to access your personal data that we process. You can access, edit, update, change or delete your personal data at any time. However, please note that certain information is absolutely necessary to achieve the objectives set out in this Policy and may be required by law. As a result, you will not be able to delete such personal data. You have the right to object to the processing of certain data. To the extent permitted by applicable data protection law, you have the right to restrict data processing. You have the right to data portability, ie the right to receive your personal data in a structured, frequently used and readable format and to transfer your personal data to another data controller to the extent required by applicable law. We respect your rights, not just the subject of decisions made as a result of automatic data processing, including profiling, because the final decisions are always made by a person on behalf of Conway. Please send us the above requests to https://www.conwaycs.com/lat. If you consider that the way we handle your personal data is inappropriate, you have the right to lodge a complaint with your national data protection authority in the EU / EEA. In Latvia, it is the Data State Inspectorate. Contact information of the Data State Inspectorate is available here: http://www.dvi.gov.lv/lv/.9. SECURITY
We take appropriate security measures (including physical, electronic and administrative) to prevent the loss, destruction, misuse or unauthorized access or disclosure of personal data. For example, we grant limited access to personal data only to authorized employees and contractors who need the information in the course of their work. Please note that while we strive to ensure that appropriate security measures are in place for personal data, no security system can prevent all potential security breaches.10. POLICY CHANGES
We reserve the right to change this Policy from time to time. If we make any changes to this Policy, we will notify you on our website at www.conwaycs.com, where you will be able to find the latest version of this Policy.11. CONTACT US
If you have any questions about this Policy or your personal data that we process, please contact us at: https://conwaycs.com/privacy-policy