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Privacy Policy

MEDIA HOUSE PRIVACY POLICY

The purpose of this Privacy Policy is to inform the individual — the customer of SIA “Media House” (hereinafter referred to as the ‘Company’) — about the purpose, scope, protection, processing period, and the rights of the data subject during the collection and processing of the customer’s personal data.

CONTROLLER AND ITS CONTACT DETAILS

The data controller responsible for the processing of your data is SIA “Media House”, reg. No. 40003229368. The Company is responsible for the secure storage, processing, and deletion of your data. If you have any questions about the processing of your personal data, please contact the Company by sending an e-mail to house@media-house.lv or by calling +371 67326315.

SCOPE OF THE DOCUMENT

Personal data means any information relating to an identified or identifiable natural person. The categories of personal data and examples are specified below.

Data Category

Examples

Customer and business partner data

Data of a job applicant (an individual applying for a job vacancy in the Company)

Name, surname, place of work and position, personal identification number, bank account number, address, phone number, mobile phone number, e-mail.

Name, surname, phone number, e-mail, LinkedIn profile address, the submitted CV, and motivation letter.

The Privacy Policy is applicable to ensure the privacy and protection of personal data of the following data subjects (hereinafter referred to as ‘Customers’):

natural persons — customers and other users of the Company’s services (including prospective, former and current users), as well as third parties who, in connection with the provision of services to a natural person (customer, partner), receive from or provide to the Company any information (including contact persons, payers, etc.);
visitors to the Company’s office;
visitors of the websites hosted by the Company, and callers to the Company’s registered phone numbers;
natural persons — applicants to the Company’s job vacancies.

The Company is committed to the privacy and personal data protection of its Customers, and respects the right of its Customers to the lawful processing of personal data in line with the applicable legislation – Regulation 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 referred to as the ‘Regulation’), and other applicable privacy and data processing legislation.

The Privacy Policy applies to data processing regardless of the form and/or environment in which the Customer provides his/her personal data (on the website, mobile applications, self-service portal, in paper or by phone), and the Company’s systems or paper form in which they are processed.

For specific types, environments, or purposes of data processing (e.g. cookie processing, etc.), additional specific rules may be established, of which the Customer is informed at the time of providing the relevant data to the Company.

PURPOSES OF PROCESSING PERSONAL DATA

Media House processes data for the following purposes:

1. For the provision of services:

to identify the customer;
to draft, conclude and prove the conclusion of the contract;
to provide services (performance of contractual obligations);
to ensure the operation of services;
to improve and develop services;
to promote, advertise and distribute the use of services;
for customer service;
to review and process the submissions and objections;
for customer retention, fostering loyalty, satisfaction measurements;
to administer payments;
for debt recovery and collection;
to maintain the websites and improve their operation.

2. For business planning and analytics:

for statistics and business analytics;
or planning and accounting;
for effectiveness measurements;
for data quality assurance;
for market and public opinion research;
for reporting purposes;
for customer surveys;
as part of risk management activities.

3. For safeguarding information, information systems and the security of the Company.

4. For the provision of information to state authorities and subjects of operational activity in the cases and to the extent stipulated in state and local laws and regulations.

5. For assessing the suitability of job applicants.

6. For other specific purposes, which shall be notified to the Customer at the time the Customer provides the relevant data to the Company.

LEGAL BASIS FOR PROCESSING OF PERSONAL DATA

The Company processes personal data based on the following legal grounds:

Customer’s consent — the Customer, as a subject of the personal data, gives his/her consent to the collection and processing of personal data for the specified purposes. The Customer’s consent is his/her free will and independent decision, which may be given at any time, thereby authorising the Company to process personal data for the specified purposes. The Customer’s consent shall be binding on the Customer when given verbally (during a phone conversation after the Customer has been identified) or in writing (by filling in a form at the Company’s office, by sending an electronic request after the Customer has been identified). The Customer has the right to withdraw his/her prior consent at any time through the specified communication channels with the Company. The withdrawal of consent shall not affect the lawfulness of processing based on consent given prior to the withdrawal.
Consent of the job applicant — an applicant for a job vacancy in the Company, as a subject of personal data, gives his/her consent to the collection and processing of personal data to enable the Company to assess the applicant’s suitability for the vacancy as accurately as possible. The job applicant’s consent is his/her free will and independent decision, which may be given at any time, thereby authorising the Company to process personal data for the specified purposes. The job applicant’s consent is binding on the job candidate when given verbally (during a phone conversation after the job applicant has been identified) or in writing (by filling in a form at the Company’s office, or by sending an electronic request). The job applicant has the right to withdraw his/her prior consent at any time through the specified communication channels with the Company. The withdrawal of consent shall not affect the lawfulness of processing based on consent given prior to the withdrawal.
Contract conclusion and performance — to enable the Company to conclude and perform a contract with the Customer, to provide quality services and serve the Customer, the Company must collect and process certain personal data that is collected before concluding the contract or during the term of the contract with the Company.
Compliance with legal obligations — the Company is entitled to process personal data to comply with the statutory requirements, as well as to respond to lawful requests from the state and local government.
Protection of vital interests — the Company is entitled to process personal data in order to protect the vital interests of the Customer or another natural person, e.g. where the processing is necessary for humanitarian purposes, for monitoring natural and man-made disasters, in particular epidemics and their spread, or in humanitarian emergencies (terrorist acts, technogenic disasters, etc.).
Exercise of official authority or public interest — the Company is entitled to process data for the performance of a task conducted in the public interest or in the exercise of official authority vested in the Company by law. In such cases, the grounds for processing of personal data are included in the laws and regulations.
Legitimate (lawful) interests of the Company or a third party — in accordance with the interests of the Company, which are based on the provision of quality services and timely support to the Customer, the Company has the right to process personal data to the extent objectively necessary and sufficient for the purposes set out in this Policy.

The Company has the following legitimate interests:

to engage in commercial activities;
to provide the Company’s services;
to verify the Customer’s identity before entering into an agreement;
to ensure compliance with the contractual obligations;
to avoid undue financial risks to their business (also by conducting a credit risk assessment before the sale of services and during the performance of the contract);
to store Customer requests and applications for the purchase and provision of services, other requests and applications, related notes, including those made in writing or verbally, by calling to the Company’s phone numbers, and on the Company’s websites;
to record the conversation with the Customer regarding the provision, maintenance, billing of services to monitor the quality of customer service;
to record the conversation with the Customer to arrange the performance of the contractual service obligations;
to record the conversation with the Customer, during which a verbal contract is concluded, to prove the conclusion of the contract;
to analyse the performance of the Company’s websites, web pages and mobile applications, and develop and implement improvements thereto;
to take action to retain Customers;
to segment the customer database for more efficient provision of services;
to design and develop services;
to advertise the Company’s services;
to send other reports on the progress of the contract performance and events relevant to the performance of the contract, and to conduct Customer surveys about the services and their experience in using them;
to prevent fraud;
to ensure corporate governance, financial and business accounting, and analytics;
to ensure effective corporate governance processes;
to improve the efficiency of services;
to ensure and improve the quality of services;
to administer payments;
to administer missed payments;
to select the best candidate to work for the Company;
to apply to public administration and operational bodies and courts to protect its legal interests;
to inform the public about the Company’s operations.

PROCESSING OF PERSONAL DATA

The Company processes the Customer’s data using modern technologies, with due regard to the existing privacy risks and the organisational, financial, and technical resources reasonably available to the Company.

To ensure the quality and prompt performance of the obligations under the contract with the Customer, the Company may authorise its business partners to perform certain service provision activities, such as sending invoices and the like. If, in the performance of these tasks, the business partners process the Customer’s personal data held by Media House, the respective business partners shall be deemed to be Media House’s data processing operators (processors) and the Company shall be entitled to transfer the Customer’s personal data necessary for the performance of these activities to the business partners to the extent necessary for the performance of such activities.

The Company’s business partners (in the capacity of a personal data processor) shall ensure that the processing and protection of personal data complied with the Company’s requirements and legislation and shall not use personal data for any purpose other than to perform the obligations under the contract/agreement entered into with the Customer on behalf of Media House.

PROTECTION OF PERSONAL DATA

The Company protects the Customer’s data using modern technologies, with due regard to the existing privacy risks and the organisational, financial, and technical resources reasonably available to the Company, including the following security measures:

encryption of data during transmission (SSL encryption);
ata encryption on servers;
firewalls;
intrusion protection and detection programmes;
other safeguards in line with the state-of-the-art capabilities.

CATEGORIES OF RECIPIENTS OF PERSONAL DATA

The Company shall not disclose to third parties the Customer’s personal data or information obtained during the provision of any services and the term of the contract, including information about the services received, except:

where it is necessary to transfer data to the third party in the context of a contractual agreement in order to perform a function necessary for the performance of the contract or delegated by law (e.g. to a bank for billing purposes or to provide a service);
subject to the Customer’s express and unambiguous consent;
to the persons specified for in external laws and regulations, upon their justified request, in the manner and to the extent stipulated in external laws and regulations;
in the cases specified in external laws and regulations, to protect the legitimate interests of Media House, e.g., to apply to court or other public authorities against the person who has infringed the legitimate interests of the Company.

DURATION OF RETENTION OF PERSONAL DATA

The Company stores and processes the Customer’s personal data for as long as at least one of the following criteria applies:

only for the duration of the contract with the Customer (including recordings of conversations where a verbal contract is concluded / a service request is made); the data are necessary for the purpose for which they were received;
until Media House or the Customer can exercise their legitimate interests (e.g. to file objections or to bring or pursue legal action) in accordance with the procedures established by external laws and regulations;
as long as one of the parties is legally obliged to store the data (e.g. according to the laws and regulations of the Republic of Latvia, the company must keep invoices for 5 years, etc.);
as long as the Customer’s consent to the processing of personal data is valid unless there is another lawful ground for the processing.
After the conditions referred to in this clause cease to apply, the Customer’s personal data are deleted. Audit trails are stored for at least one year from the date of their creation in accordance with the laws and regulations.

ACCESS TO PERSONAL DATA AND OTHER CUSTOMER’S RIGHTS

The Customer has the right to request Media House to access his/her personal data, as well as to request the Company to update, rectify or delete them, or to restrict processing in relation to the Customer, or the right to object to processing (including processing of personal data based on the legitimate interests of the Company), as well as the right to data portability, in accordance with the laws and regulations. These rights shall be exercised to the extent that the processing of the data does not result from Media House’s obligations under applicable laws and regulations and is conducted in the public interest.

The Customer can request to exercise his/her rights:

Upon receipt of a Customer’s request to exercise his/her rights, Media House shall verify the identity of the Customer, assess the request, and execute it in accordance with the laws and regulations.

The Company shall send the reply to the Customer by post to the contact address provided by the Customer by registered mail or by the method of receipt indicated by the Customer.

Media House shall ensure compliance with data processing and data protection requirements in accordance with laws and regulations and, in the event of an objection from the Customer, shall take reasonable steps to resolve the objection. However, if this fails, the Customer has the right to apply to the supervisory authority — the Data State Inspectorate.

THE CUSTOMER’S CONSENT TO DATA PROCESSING AND THE RIGHT TO WITHDRAW IT

The Customer may give his/her consent to the processing of personal data based on consent on the Company’s websites (e.g., newsletter subscription forms), by phone or in person at the Company’s office.

The Customer has the right to withdraw his/her consent to data processing at any time in the same way as it was given, i.e. by calling, sending an e-mail, or in person at the Media House office, in which case no further data processing based on the consent given for the specific purpose will be conducted.

Withdrawal of consent shall not affect the processing of data that occurred at the time when the Customer’s consent was valid.

Withdrawal of consent shall not interrupt the processing of data conducted based of other legal grounds.

COMMUNICATION WITH THE CUSTOMER

The Company communicates with the Customer using the contact details provided by the Customer (phone number, e-mail address, postal address).

The Company communicates regarding the performance of contractual obligations based on the concluded contract (e.g. provision of services, information on invoices, changes to services, etc.).

COMMERCIAL NOTIFICATIONS

Communication regarding commercial notification about the Company’s and/or third-party services and other notifications not directly related to the provision of the contracted services (e.g. customer surveys) shall be conducted by Media House in accordance with external laws and regulations or with the Customer’s consent.

The Customer may consent to receive commercial notifications from the Company and/or its business partners on the Company’s websites (e.g. newsletter subscription forms), by phone or in person at the Company’s office.

The Customer’s consent to receive commercial notifications is valid until withdrawn (including after the termination of the Processing Agreement for Services). The Customer may at any time refuse from receiving further commercial notifications in any of the following ways:

by sending an e-mail to house@media-house.lv;
by calling to +371 67326315;
in person at the Company’s office;
using the automated opt-out option provided in the commercial notification by clicking on the opt-out link at the end of the relevant commercial notification (e-mail).

As soon as the Customer’s request has been processed, the Company shall stop sending commercial notices. The processing of the request depends on the technological capabilities, which can take up to seven days.

By expressing his/her opinion in the surveys and by providing his/her contact details (e-mail, phone number), the Customer agrees that Media House may contact him/her in connection with the assessment provided by the Customer using the contact details provided by the Customer.

USE OF COOKIES ON MEDIA HOUSE WEBSITES

The Company’s websites use cookies. Cookies are small text files that a web browser (Chrome, Mozilla Firefox, Safari, etc.) stores on a user’s terminal device (computer, mobile phone, tablet) when the user visits a website to identify the browser, or information or settings stored in the browser. Cookies enable the website to store the user’s individual settings, recognise them and respond accordingly, with the aim of improving the website user experience. The user can disable or restrict the use of cookies, but without cookies it will not be possible to use the full functionality of the websites.

Depending on the functions performed and the purpose of use, the Company uses the following cookies:

Mandatory cookies
These cookies are necessary to allow the user to freely visit and browse the website and to experience the features it offers, including information on news and products. These cookies identify the user’s device but do not disclose the user’s identity, nor do they collect or aggregate information. Without these cookies, the website will not be able to function fully, for example, to provide the information the user needs. These cookies are stored on the user’s device until the web browser is closed.
Functional cookies
Functional cookies are used to remember the settings and choices made by the user to make the website more convenient for the user. These cookies are stored permanently on the user’s device.
Analytical cookies
Analytical cookies collect information about how the user uses a website, identifying the most frequently visited sections, including the content the user selects when browsing the site. The information is used for analytical purposes to establish the user interests and to improve the functionality of the website to make it more user-friendly. Analytical cookies only identify the user’s device, but do not disclose the user’s identity. In some cases, some of the analytical cookies are managed by third-party data processors (operators), such as Google Analytics, on behalf of the site owner, in accordance with the site owner’s instructions and only for the purposes indicated.
Targeting (advertising) cookies
Targeting (advertising) cookies are used to collect information about the websites visited by the user and to offer the Company’s or business partners’ products that are of direct interest to a specific user or to target offers relevant to the interest expressed by a specific user. These cookies are usually deployed by third parties, such as Google Ads, with the permission of the website owner for the purposes indicated. Targeting cookies are stored permanently on the user’s end device.

Media House uses cookies for the following purposes:

to improve the user experience on websites and webpages;
to ensure the functionality of the website;
to obtain statistical data on the traffic of the website: the number of visitors, time spent on the website, geographic location, device used, etc;
to provide the content and offers created or distributed by the Company.

Cookie retention period

Unless otherwise stated, cookies are stored until the action for which they were collected is performed, after which they are deleted.

Cookie information is not transferred for processing outside the European Union and EEA countries.

Accepting and disabling of cookies

When visiting the Company’s websites and webpages, the user is presented with a window with a message that cookies are used on the website. By closing this message box, the user confirms that he/she has read and agrees to the information on cookies, the purposes for which they are used and the cases in which their information is transferred to a third party. Accordingly, the legal basis for the use of cookies is the user’s consent. The security settings of each web browsers allow restricting and deleting cookies. However, it should be noted that the use of mandatory and functional cookies cannot be rejected, as without them the full use of the website and the webpage is impossible.

Media House websites may contain links to third-party websites which have their own terms of use and personal data protection policies for which the Company is not responsible.

OTHER PROVISIONS

The Company has the right to make additions to the Privacy Policy by proving the Customer with the current version on the Company’s website: https://www.media-house.lv.