Privacy policy

INFORMATION ON THE PROCESSING OF PERSONAL DATA

PERSONAL DATA PROCESSING

Please read this privacy policy before using the www.arnautovs.lv website. If you do not agree in whole or in part with this privacy policy, please do not use www.arnautovs.lv

SIA "DOKUMENTS" (hereinafter referred to as "SIA DOKUMENTS") processes your personal data in connection with the activities of SIA "DOKUMENTS" as a law firm and rendering legal assistance to its clients. Your personal data is also processed when you visit our website, social profiles of SIA "DOKUMENTS", sign up to receive news from us, express your interest in a vacancy at SIA "DOKUMENTS", communicate with us or attend our events.

The rules governing the processing of your personal data and your rights in this respect are set out further in this privacy policy statement, justified by the requirements of the Regulation of the European Parliament and of the Council of the European Union No 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the Regulation), as well as the laws and regulations of the Republic of Latvia.

SIA "DOKUMENTS" ensures adequate technical and organizational measures in order to protect personal data from accidental or unlawful destruction, loss, alteration, prohibited disclosure or access to transmitted, stored or otherwise processed personal data.

SIA "DOKUMENTS" CONTACT DETAILS

SIA "DOKUMENTS" will comply with the rights provided by the Act or the authorization given by you, including the right to collect evidence and request all documents necessary to provide legal assistance from state and municipal institutions as well as other institutions, organizations and business associations (companies) which in the manner and in the cases provided by law must provide such documents or copies thereof and provide to SIA "DOKUMENTS" the opportunity to examine them; the right to inspect information related to the provision of legal assistance. Therefore, when processing your personal data and providing legal assistance, SIA "DOKUMENTS" basically acts as the person who manages the processing of your personal data. If you have any questions regarding the processing of your personal data by SIA "DOKUMENTS" or wish to exercise your rights as a data subject pursuant to the Regulations, please contact us in the manner most convenient for you:

SIA "DOKUMENTS" registration, registered office: Kr. Valdemāra iela 149, LV-1013, Rīga, +371 288 58 997.

LEGAL BASIS AND PURPOSE OF PERSONAL DATA PROCESSING, TYPES OF PERSONAL DATA

As a general rule, SIA "DOKUMENTS" has the following legal basis for processing your personal data:

• actions related to the provision of pre-contractual advice, inspection of the client's case and documents at the client's request, and activities to conclude the contract;
• fulfilment of the legal obligations of SIA "DOKUMENTS" (fulfilment of contractual provisions);
• protecting the most important interests of a client or other natural person, or carrying out an assignment in the public interest;
• respecting and protecting the legitimate interests of SIA "DOKUMENTS";
• the consent given by the data subject to process personal data for a specific purpose.

Provision of pre-contract advice and events for the conclusion of the contract

In order to provide legal assistance and assess further cooperation, we process personal data when providing pre-contractual consultations and getting acquainted with a case and when drawing up a relevant cooperation agreement or an agreement for the provision of legal assistance. Therefore, SIA "DOKUMENTS" may process the following personal data:

• Identification data (name, surname, contact details), in case the client represents a legal person or an association: details of the legal person or association (including ownership, direct or indirect controlling interests or shares), the type of control exercised by the client and related supporting documents; personal data that follows from the case file provided, including personal data of third parties; correspondence and any communication with the client, including personal meetings, telephone calls
• The legal basis for processing such personal data is Article 6, Paragraph one, Subparagraph b) of the Regulation, which entitles SIA "DOKUMENTS" to process personal data, if the processing is required for performance of the contract to which the data subject is a party or for carrying out activities at the data subject's request before the contract is concluded; Subparagraph f) of Article 6, Paragraph one of the Regulation states that data processing is required for compliance with legal interests of the data controller or third person - for instance, legal and Personal data of special category shall be processed on the basis of Article 9 Paragraph two of the Regulation.

Performing the legal duties of SIA "DOKUMENTS" to research and identify the client

Complying with the requirements of the Money Laundering, Terrorist Financing and Proliferation Prevention Act, SIA "DOKUMENTS" carries out research and identification of the customer in certain cases. The following personal data may be processed in this regard:

• Identification data (first name, surname, contact details), photo, passport details, country of residence;
• If the customer represents a legal person or an association: details of the legal person or association, details of any capital interests or shares held or controlled directly or indirectly by the individual, the type of control and related supporting documentation;
• Information from lists of persons suspected of engaging in terrorist activities or manufacturing, possessing, transporting, using or distributing weapons of mass destruction; or information from the international list of sanctioned entities as well as the list of sanctioned entities compiled by the Cabinet of Ministers under the International and National Sanctions Law of the Republic of Latvia;
• The legal basis for such processing of personal data is Article 6 (1) (c) of the Regulation, which provides for the right of SIA "DOKUMENTS" to process the personal data, if such processing is related to the performance of legal duty of SIA "DOKUMENTS". In special cases, based on article 34 of the Personal Data Protection Act for natural persons, criminal conviction data may be processed.

Execution of the contract

In connection with the performance of a client order, SIA "DOKUMENTS" processes different categories of personal data and the personal data processed depends on the subject matter of the particular case and the order of SIA "DOKUMENTS".

Below are some of the possible personal data that SIA "DOKUMENTS" may process on behalf of the client or during the performance of the specific agreement with the client:

Category of the case:

Providing legal assistance and representation in commercial law; renting, buying and selling real estate; tax law; intellectual property law; family law; employment law; immigration law; relations with credit institutions; representation in court cases, etc.

Purpose of treatment:

Providing legal assistance to the client and formalising the client's right of representation if necessary

Personal data

·      Identification details - first name, surname, personal ID code, date and place of birth, copy of passport or ID card, telephone number, e-mail address;

·      Information on capital shares held, positions in capital companies, information on the right of representation, information on self-employment;

·      Data from the registers of the Register of Enterprises;

·      Data from the Land Registry;

·      Data from the Road Safety Directorate (CSDD) database;

·      Information on the payment of taxes;

·      Information on contracts entered into and their performance;

·      Information that is derived from the content of the video or audio;

·      Details of the property owned and the basis of ownership;

·      Data arising from contracts for the purchase and sale of real estate, real estate lease contracts, and public utility agreements;

·      Data on birth certificate, marital status and family relations;

·      Data on nationality and right to remain in the country;

·      Information on employment, including information on wages;

·      Information on solvency, tax debts;

·      Data that derives from communication with other parties to the transaction or opponents;

·      Financial and bank account information and information on the funds available in the bank accounts;

·      Information from the register of punishments or the register of residents;

·      Other information relating to the performance of the contract.

Special categories of data may also be processed, such as health or trade union membership data and criminal records.

Legal basis for processing

Performance of the contract (client's order) entered into with the client, performance of legal duties of SIA "DOKUMENTS", or protection of legal interests of SIA "DOKUMENTS" or the client (e.g. initiation of legal proceedings or protection of client's interests), subparagraphs b), c) and f) of the first paragraph of Article 6 of the Regulation;

Special category data are processed on the basis of subparagraph a) of paragraph two of Article 9 of the Regulation (consent of the data subject has been given); Subparagraph b) of Article 9 of the Regulation (processing is necessary for performance of obligations of the data controller).

Marketing and advertising

SIA "DOKUMENTS" may process personal data in connection with its marketing or promotional activities by informing about SIA "DOKUMENTS" events or news published on the site etc. SIA "DOKUMENTS" may also publish information about the successfully settled customer case for promotional purposes. The processing may be necessary to provide services to persons who have expressed an interest in receiving them. 

• In this regard, SIA "DOKUMENTS" may process data such as name, contact details, interests in specific news (topics) and language;
• The legal basis for processing such personal data is the legitimate interests of SIA "DOKUMENTS" to advertise its services and to contact existing and potential customers as specified in article 6, part one, subparagraph f) of the Regulation;
• News or other promotional material of SIA "DOKUMENTS" (direct marketing) will be sent by e-mail only if the consent of the individual has been obtained, which can be revoked following the instructions of the e-mail;
• If information concerning a successfully settled customer case is published on the SIA "DOKUMENTS" website, the particular publication and the personal data contained in the particular publication shall always be agreed with the customer and, if necessary, SIA "DOKUMENTS" shall obtain the consent of the data subject for publication of such information which the data subject shall be entitled to withdraw.

Interests of SIA "DOKUMENTS" as a business operator

Considering that while providing legal assistance SIA "DOKUMENTS" runs its business activities, personal data arising from cooperation of SIA "DOKUMENTS" with other service providers and partners, from the administration of contracts and contracts concluded with clients as well as personal data connected with the protection of lawful interests of SIA "DOKUMENTS" may also be processed:

• In this connection personal data such as: name, surname, occupation and position, contact information necessary for preparing invoices and also information about payment of invoices, information about the services provided by SIA "DOKUMENTS" or received from SIA "DOKUMENTS" (incl. the orders carried out for the customer, the time spent and the rates applied), correspondence and communication of any kind, notes made during the provision of services or receipt of services;
• The legal basis for processing such information shall be the statutory interest of SIA "DOKUMENTS" to provide legal assistance and perform business activities and fulfil the contract concluded with the customer pursuant to article 6 (1) (b) of the Regulation or fulfil legal obligations of SIA "DOKUMENTS" pursuant to article 6 (1) (c) of the Regulation.

SIA "DOKUMENTS" may also process the following personal data of a potential employee or a person who has applied for an internship at SIA "DOKUMENTS":

• Identification data (name, surname, contact details, education, qualifications, skills, language skills, work experience, including previous work experience, feedback from former employers, desired remuneration, other professional or personal characteristics included in the CV and/or the required selection process, or in any of the stages of such selection, including notes made during the interview and test task.
• The legal basis for processing of such information shall be the legitimate interest of SIA "DOKUMENTS", as stipulated in subparagraph f), paragraph one, article 6 of the Regulation, to employ the staff corresponding to the particular position;
•  In case of successful selection of staff, personal data shall be processed at the request of the selected candidate in order to carry out the necessary actions for the conclusion of the contract and performance of the contract concluded pursuant to art. 6 para. 1 (b) of the Regulation; whereas in case of unsuccessful selection of staff, personal data shall be processed in order to provide a response to the applicant, as well as to protect its legitimate interests in case of possible legal actions based on legitimate interests of SIA "DOKUMENTS", f) art. 1 para. There can be cases, when the processing of certain personal data is required by law - for example, to check whether an individual meets the statutory requirements in terms of health status of the employee.

SIA "DOKUMENTS" website

When you visit the SIA "DOKUMENTS" web site, SIA "DOKUMENTS" collects and processes information in the form of a cookie. We use this information for marketing purposes and also to optimize the website and provide you the best experience of using it.

Information on which cookies may be used and how you can delete them can be found in the "Cookie Policy" and also below:

• We process information about your IP address in connection with the cookies used. Also in summary form (i.e. without identifying the individual) we may process the following data: demographic information including gender and age, interests, information about your browser and its location (connection), the device from which you connect and the person providing the connection service. This data is processed to compile statistics and optimise performance by analysing website usage;
• The legal basis for such data processing shall be the legitimate interests of SIA "DOKUMENTS", as stipulated in article 6, part one, subparagraph f) of the Regulation, to collect statistical data and, by analyzing the use of the website, to optimize its operation as provided in the Regulation.

Social media

SIA DOKUMENTS has profiles on social media such as LinkedIn, Facebook and Instagram and TikTok and when you interact with SIA DOKUMENTS on these platforms (for example, by responding to or sharing our post), SIA DOKUMENTS receives information about it. You should be aware that the information we receive through these social networks is also processed by the social networks themselves, so with regard to this information SIA "DOKUMENTS" and the respective platform are considered to be jointly managing the processing of personal data.

The information we may receive from you is that which is available on your social network, including profile information, your photo and information about your interaction with SIA "DOKUMENTS".

The legal basis for processing such personal data is the legitimate interest of SIA "DOKUMENTS" to advertise its services and to contact existing and new customers, as specified in article 6, part one, subparagraph f) of the Regulation.

On the other hand, if SIA "DOKUMENTS" publishes information about a successfully settled customer case, the particular publication and the personal data contained therein will always be agreed with the customer and, if necessary, SIA "DOKUMENTS" will obtain the consent of the data subject to the publication of such information which the data subject has the right to withdraw.

 SOURCES OF PERSONAL DATA

In connection with consulting before and after the conclusion of the contract and during the performance of the contract concluded with the customer, SIA "DOKUMENTS" receives the personal data from its customer directly or from publicly available resources (databases), public institutions or third parties (e.g. other parties to the contract).

The data processed in connection with the performance of legal obligations of SIA "DOKUMENTS" concerning customer research and identification is obtained by SIA "DOKUMENTS" from the customer, from publicly available resources (databases) and from other persons specified in the applicable legislation.

Data that is processed for marketing and promotional purposes we receive from you, as the data subject, and from the company that is a customer of SIA "DOKUMENTS" where you are employed.

Data that is processed for the benefit of SIA "DOKUMENTS" as a business operator, SIA "DOKUMENTS" most often receives from the contracted client (incl. from the employer of the data subject with whom SIA "DOKUMENTS" has a contract) or directly from the data subject (e.g. from the application and CV of the potential employee or during the interview).

Cookie usage data is collected by SIA "DOKUMENTS" when you visit SIA "DOKUMENTS" website. See our cookie policy.

 DISCLOSURE OF PERSONAL DATA AND ITS TRANSFER TO THIRD PARTIES

Your personal data may only be disclosed and handed over to third parties if this is connected with legal assistance, pre-contract advice, contract preparation or performance of the contract concluded by SIA "DOKUMENTS" and in the case if SIA "DOKUMENTS" has a legal obligation to do so in accordance with applicable law or if consent was received from you to disclose and hand over such data to third parties or if this is in the legitimate interest of SIA "DOKUMENTS". Personal data may be disclosed to the following persons:

• parties or persons connected with the contract or the client's specific case;
• public institutions, courts, sworn notaries, sworn bailiffs, interpreters;
• credit institutions, insurers, accountants, valuers, auditors, experts, etc.

In addition, SIA "DOKUMENTS" may disclose and transfer your personal data to data processors with whom SIA "DOKUMENTS" cooperates and/or who assist SIA "DOKUMENTS" in providing legal advice such as accountants, IT specialists and business associates - for example, recruitment companies.

Personal data may also be disclosed within the framework of DOKUMENTS Ltd. partnership with other service providers - translation agencies, sworn notaries, public institutions (e.g. when providing legal assistance in different countries or complex services). In such a case, SIA "DOKUMENTS" and the relevant bureau of SIA "DOKUMENTS" group may be considered as the persons who jointly manage the processing of personal data within the meaning of article 26 of the Regulations.

As a rule, SIA "DOKUMENTS" will not transfer your personal data outside the EU/EEA, however, on rare occasions this may happen if you as a client or client's representative or a party related to the case (client's order) are in a third country. In this case, SIA "DOKUMENTS" applies the subparagraphs a), b) or e) of the first paragraph of article 49 of the Regulation, according to which the forwarding of personal data takes place, if the personal data subject has given his or her express consent to such forwarding after being sufficiently informed of the possible risks, if forwarding is necessary to perform the contract between SIA "DOKUMENTS" and the data subject or to carry out the pre-contractual measures, which have been performed at the data subject's request, or if such forwarding is necessary to submit, implement or protect legal

In certain cases SIA "DOKUMENTS" may directly or indirectly (including within the group of partner offices of SIA "DOKUMENTS", such as SIA "LEXAR", reg. no. 40203421091) use such services which are provided by data processors located outside the EU/EEA, namely in the following cases:

Data processing

Data processor

Country

Basis for data transfer

 Publication of information

MailChimp

USA

Standard EU treaty conditions for sending personal data to third countries

Administration of participation in events and videoconferences

Eventbrite

USA

Standard EU treaty conditions for sending personal data to third countries

Cookies

Google LLC

USA

Standard EU treaty conditions for sending personal data to third countries

PRIVACY

Employees of SIA "DOKUMENTS" are subject to strict confidentiality requirements, including the processing of personal data. SIA "DOKUMENTS" is obliged not to disclose the confidentiality of its principal (client) not only during the case, but also after the release from the case or after the end of the case. It must ensure compliance with this requirement, including in the work of its staff.

DATA STORAGE AND DELETION

SIA "DOKUMENTS" processes personal data until the purpose which is the basis for personal data processing is fulfilled. SIA "DOKUMENTS" has developed a data deletion policy and for each category of personal data a retention period has been set, upon completion of which personal data will be irrevocably deleted.

Storage of personal data depends on the type of document: for example, electronic documents are stored in the e-mail boxes of persons in charge, on work computers and/or in internal systems of SIA "DOKUMENTS", whereas paper documents: in internal locked archives. SIA "DOKUMENTS" applies developed technical and organizational measures to ensure security of personal data and its inaccessibility to third parties.

Providing pre-contract advice, contract execution and legal obligations in relation to customer research and identification

SIA "DOKUMENTS" mainly keeps personal data which is necessary to protect legitimate interests of SIA "DOKUMENTS" and provide evidence in case of litigation. SIA "DOKUMENTS" stores the following personal data until the expiry of the statute of limitations stipulated in the applicable regulations (generally three or ten years) or no longer than necessary.

Personal data that is processed solely on the basis of your consent shall be processed until such consent is withdrawn.

If cooperation is not commenced and personal information about you is only kept in connection with possible cooperation, this information is retained for one year from the last correspondence, unless there is another legal basis for keeping such information longer.

Personal data arising from the fulfilment of a legal obligation to research and identify a customer shall be retained for five years after the completion of the business relationship or one-off transaction.

Interests of SIA "DOKUMENTS" as a business operator

Information arising from the accounting records will be kept for the period specified in the Accounting Act, whereas other information about contracts between SIA "DOKUMENTS" and service providers and business partners will be kept until the statute of limitations specified in the applicable regulations (generally three or ten years) to protect the legal interests of SIA "DOKUMENTS" and provide evidence in the event of litigation.

Potential employees' data is kept for a period of three months from the day on which the employment relationship was announced and, in the case of court proceedings, until the execution of the final court decision.

Marketing and homepage

SIA "DOKUMENTS" stores the data until the data subject's consent is withdrawn (if the processing takes place on the basis of consent). If the business relationship continues (without direct marketing), a general retention period based on the statute of limitations specified in the applicable regulations (generally three or ten years) applies to the remaining personal data.

 YOUR RIGHTS

As a data subject, you have rights under the Regulation in relation to the personal data you process.

In the event that you as a data subject want to exercise one or more of your rights please contact SIA "DOKUMENTS" using the contact details previously stated in this privacy policy. Please note that SIA "DOKUMENTS" will need to identify you and SIA "DOKUMENTS" may also request additional information to fulfill your request.

You may exercise your data subject rights at any time, however, SIA "DOKUMENTS" has the right to refuse to exercise these rights fully or partially, if there are reasons justified by the Regulation or other regulations.

The right to access your personal data

The data subject has the right to receive confirmation from SIA "DOKUMENTS" whether or not the personal data of the data subject has been processed.

If SIA "DOKUMENTS" processes the personal data of a data subject, the data subject has the right to access their personal data and to receive information about what personal data is processed, the purpose of processing, the recipients of personal data and other information specified in article 15, paragraphs 1 and 2 of the Regulation.

SIA "DOKUMENTS" may provide the data subject with a copy of the personal data being processed, however, in certain cases, if such a request requires disproportionate resources, SIA "DOKUMENTS" is entitled to ask for additional fees for the preparation of the information or to refuse to provide such information to the data subject.

The right to have personal data corrected

The data subject has the right to have SIA "DOKUMENTS" correct the inaccurate personal data without undue delay and, given the purpose of the processing, to have the inaccurate personal data supplemented, including by way of supplementary notification. However, in the event that SIA "DOKUMENTS" reasonably believes that such request by the data subject is unreasonable and SIA "DOKUMENTS" has no obligation to correct the data, then SIA "DOKUMENTS" will be able to note that the data subject believes the personal data is inaccurate.

The right to erasure of personal data ("right to be forgotten")

The data subject has the right to request SIA "DOKUMENTS" to delete personal data without undue delay and SIA "DOKUMENTS" is obliged to delete personal data without undue delay, if one of the following applies

• personal data is no longer needed for the purposes for which it was collected or processed;
• the data subject withdraws their consent to the processing of their personal data and there is no other legal basis for processing them;
• based on their particular situation, the data subject objects to the processing of their personal data that is based on (i) the public interest; (ii) the exercise of official powers conferred by law on the person managing the personal data processing, (iii) the legitimate interests of the person managing the personal data processing or a third party in the absence of a more important legal basis for the above processing of such personal data or (iv) direct marketing, which includes profiling;
• personal data is processed unlawfully;
• the personal data must be deleted in order for SIA "DOKUMENTS" to fulfil the legal obligation set out in the legislation;
• personal data is processed in connection with the provision of a public information service to a child on the basis of consent.

However, in the event that SIA "DOKUMENTS" reasonably points out another legal ground for processing personal data, which provides the necessity to continue processing the personal data or which is assessed as more substantial than these rights of the data subject, SIA "DOKUMENTS" has the right not to comply with the data subject's request to delete data (for example, personal data may be processed in order to provide SIA "DOKUMENTS" with the right to file or maintain a claim in the future, and personal data may serve as evidence of

The right to restrict the processing of personal data

The data subject may ask to restrict the processing of his or her personal data (without any changes to the relevant data) if

• the data subject disputes the accuracy of personal data (processing is restricted for the time until data verification is completed, unless the regulations establish an obligation for SIA "DOKUMENTS" to process personal data);
• the processing of personal data is unlawful (the data subject nevertheless disputes the erasure of the data, requesting instead that the processing be restricted);
• personal data is no longer required to achieve the purpose of the processing and the data subject requests their personal data in order to make, implement or defend legal claims;
• the data subject objects to the processing that is based on the legitimate interests of SIA "DOKUMENTS" or a third party before the end of the consideration of the data subject's objections.

If processing is restricted, SIA "DOKUMENTS" processes such personal data, with the exception of storage, only:

• with the consent of the data subject;
• to assert, enforce or defend legal claims (e.g. in court);
• to protect the rights of another person or entity;
• to protect important public interests.

The right to port personal data

The right to data portability applies to personal data that the data subject himself/herself has provided on the basis of consent or contractual relationship (including at the stage of preparation for the conclusion of a contract), if the processing of this data takes place by automatic means.

The data subject has the right to obtain their personal data in a structured, universally recognised and machine-readable form and to transfer this personal data to another person managing the processing of personal data.

The sending of personal data to the data subject must be adequately secured and protected by implementing the necessary technical measures to ensure the correct and reliable sending and the confidentiality and integrity of personal data.

The use of data portability does not affect other rights, such as the right to information. The exercise of the right to data portability shall not affect the rights and obligations of SIA "DOKUMENTS" to continue the processing of personal data after data portability, if such further processing has a legal basis.

The right to object to the processing of personal data

The data subject may object to the processing of his or her personal data in the following cases:

• for the purpose of direct marketing (including profiling to the extent related to direct marketing);
• processing based on legitimate interests (including profiling based on regulations), public interests or fulfilment of official powers of SIA "DOKUMENTS", if granted by SIA "DOKUMENTS";
• processing for scientific or historical research purposes or for statistical purposes.

The right to object to the processing of one's personal data must be justified by a specific situation, except for objections to the processing of one's personal data for direct marketing purposes, which need not be justified.

The right not to be subject to such a decision, on the basis of which only automatic processing, including profiling, is carried out

Please note that SIA "DOKUMENTS" does not carry out such automatic processing.

The right to withdraw your consent

To the extent that your personal data is processed on the basis of your consent, you have the right to withdraw such consent at any time at any stage of processing.

 RIGHT TO COMPLAIN

In any case, if you have any questions about how your personal data is handled, please contact us by email: a@arnautov.lv 

We are committed to working with you to achieve a fair resolution of any personal data processing issues.

If you don't think we've been able to help you in your case and you're not satisfied with the handling of your personal data by SIA "DOKUMENTS", you have the right to complain to the Republic of Latvia Data State Inspectorate, Tel. + 371 67223131: e-mail info@dvi.gov.lv. Please be aware that the Data State Inspectorate will ask you to provide information and relevant documents whether you have had contact with SIA "DOKUMENTS" in relation to the subject of your complaint or not and what the response of SIA "DOKUMENTS" was.

 CHANGES IN PRIVACY POLICY

SIA "DOKUMENTS" regularly reviews its internal procedures and makes changes in the documents related to the processing of personal data, so that such documents are in compliance with the regulations and protect the interests of the data subject as much as possible.

The date on which the Privacy Policy was last amended is shown below.

Last modified: 14.11.2022.