by SIA Clean R management board
order No ADM53 of 10 May 2018
Personal data processing policy
1. Purpose of personal data processing
The purpose of the personal data processing policy is to provide the natural individual (data subject) with information about the purpose, scope, protection and duration of the processing of personal data, during the collection and processing of the data subject’s personal data.
2. Data controller and contact details
The personal data controller is SIA Clean R (‘Clean R’), uniform registration No 40003682818, registered address Vietalvas iela 5, Riga, LV-1009, phone 67111001, e-mail [email protected].
The Clean R contact for personal data processing is the Customer Service Centre. You can ask questions about our processing of personal data by calling 67111001, sending an e-mail to [email protected], or contacting Clean R at its registered address. You may submit a request for the exercise of your rights in accordance with Section 12 of this document.
Personal data are any information about an identified or identifiable natural individual. The definitions, explanations, and categories of personal data are specified in Annex 1.
- natural individuals who are clients, employees and other users of Clean R services (including potential, former and existing ones), as well as third parties who receive or pass on any information (including contact persons, payers, etc.) from/to Clean R in relation to the provision of services to a natural individual (a subscriber, a client, a user);
- visitors of Clean R offices, the Customer Service Centre;
- employees of Clean R offices, repair area, warehouses, waste sorting facilities, car wash with video surveillance;
- video surveillance of Clean R-owned areas, courtyards, and adjacent areas, for property security;
- visitors of the websites maintained by Clean R (‘Clients’).
Clean R works to ensure its Clients’ privacy and the protection of their personal data, observes the Clients’ right to the lawfulness of personal data processing in accordance with applicable law, i.e. Regulation (EU) of the European Parliament and of the Council No 2016/679 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 (‘Regulation’), and other applicable laws in the field of privacy and data processing.
Additional, special rules may be set for specific types of processing (e.g. cookies, etc.), environments, purposes of data processing, of which the Client is informed when providing the data to Clean R.
4. Purposes of the processing of personal data
Clean R processes personal data for the provision of services and sale of goods:
- to identify clients and prepare an offer;
- preparation, conclusion, amendment, transfer and termination of contracts;
- customer service;
- supply of goods (containers) and services (fulfilment of contractual obligations);
- provision/maintenance of services;
- improvement of goods and services, development of new goods and services;
- advertising and distribution of services, i.e. commercial purposes;
- handling and processing objections;
- measuring of client satisfaction, boosting of client retention and loyalty;
- management of payments.
- credit assessment, credit monitoring;
- debt recovery and enforcement;
- maintaining the website and improving its performance.
Clean R processes personal data for business planning and analysis:
- for accounting, planning and statistics;
- for data quality assurance and efficiency measurements;
- for market and public opinion research;
- for preparation of reports;
- for client surveys.
Clean R processes personal data for the provision of information to public authorities and operational agencies in the cases and to the extent provided for in external regulations, and for other specific purposes, of which the Client is informed at the time of providing the data to Clean R.
5. Legal grounds for the processing of personal data
Clean R processes the Client’s personal data based on the following legal grounds:
- conclusion and execution of a contract: to enter into a contract following the Client’s application and to ensure its fulfilment;
- compliance with laws and regulations: to fulfil an obligation specified in the external regulations binding to Clean R;
- in accordance with the consent of the Client, as the data subject;
- legitimate interest: to pursue the legitimate interests arising out of existing liabilities or a contract concluded between Clean R and the Client, or a legal interest of Clean R group.
The legitimate interests of Clean R are to:
- conduct business activities;
- provide waste collection and sorting services;
- provide cleaning services for premises and grounds;
- verify the Client’s identity before entering into a contract or as part of customer service, by phone, electronically, in person;
- ensure the fulfilment of contractual obligations;
- eliminate unjustified financial risks for its business operations (incl. carrying out the assessment of credit risk before the selling of goods and services as well as during the execution of the contract);
- store the Client’s applications and submissions for the purchase of goods and the provision of services, other applications and submissions, records about them, including ones made in writing or verbally, by contacting call centres, on websites and on the self-service portal;
- analyse the performance of Clean R’s homepage, websites and mobile applications, to develop and implement their improvements;
- manage the Client’s account on Clean R’s homepages, websites and mobile applications;
- carry out activities for the retention of Clients;
- segment the client database for more efficient provision of services;
- develop and improve goods and services;
- advertise goods and services by sending commercial messages;
- send other reports on the progress of execution of the contract and events relevant to the execution of the contract, and to conduct Client surveys on goods and services and their experience of use;
- provide information about changes in the service and the price list;
- keep Clients informed about industry news;
- engage in environmental education activities;
- maintain the waste bins;
- prevent fraud;
- ensure corporate management, financial and business accounting and analysis;
- ensure the effective governance of the company;
- ensure the efficiency of the supply of services and the sale and delivery of goods;
- ensure and improve the quality of services;
- administer payments;
- administer outstanding payments;
- apply to state administration institutions and institutions of operational activities and court for the protection of its legal interests;
- inform the public about its activities
6. Transfer of data from one controller to another
These data processing regulations apply only to the processing of personal data resulting from contracts for services provided by Clean R to another legal entity.
Each such party acts as an independent data controller.
The parties take appropriate technical and organisational measures to ensure the security of the processing of personal data.
The parties must promptly, and in any event within two (2) business days, inform the other party of a request received from a data subject if it concerns or affects the processing of personal data by the other party (for example, a request to restrict the processing) or affects personal data (for example, a request for rectification). The parties cooperate with each other in good faith (for example, by exchanging information about the processing of personal data) to comply with reasonable requests from data subjects and to ensure the accuracy of the data throughout the processing.
7. Processing of personal data
Clean R processes the Client’s data using the options provided by modern technologies, taking into account the existing privacy risks and organisational, financial, and technical resources that are reasonably available to Clean R.
Clean R may use automated decision-making with regard to the Client. The Client is informed about these Clean R activities individually, in accordance with laws and regulations. The Client may object to the use of automated decision-making in accordance with legal acts, yet understanding that in separate cases this can restrict the Client’s right to use individual possibilities potentially available thereto (for example, to receive commercial offers).
The use of automated decision, which results in legal consequences for the Client (for example, approval or rejection of the Client’s application), can be carried out only in the process of entering into, or execution of, the contract between Clean R and the Client, based on the Client’s unambiguous consent or in the cases stipulated in external laws and regulations.
For the high-quality and fast execution of the contractual obligations arising out of the contract entered into with the Client, Clean R may authorise Clean R group companies, its cooperation partners to perform individual deliveries of goods and activities for the provision of services, such as service deployment works, billing, and the like. If, in carrying out these tasks, Clean R group companies or partners process the Client’s personal data available to Clean R, these Clean R group companies or partners are considered to be data Clean R’s processing operators (processors), and Clean R is entitled to transfer the Client’s personal data to Clean R group companies and partners for the performance of these activities, to the extent necessary to carry out these activities.
Partners of Clean R and Clean R group companies (in the status of a processor of personal data) ensure the fulfilment of the requirements for personal data processing and protection in line with the requirements of Clean R and laws, and do not use personal data for other purposes, except for the fulfilment of the contractual obligations arising out of the contract entered into with the Client, on behalf of Clean R.
8. Protection of personal data
Clean R protects the Client’s data using the options provided by modern technologies, taking into account the existing privacy risks and organisational, financial, and technical resources that are reasonably available to Clean R.
9. Categories of recipients of personal data
Clean R does not disclose to third parties any of the Client’s personal data or any information obtained during the provision of services and the contract, inter alia, information regarding received electronic communications, content or other services, except the following:
- If the data must be transferred to the third party under a contract concluded to carry out a function relevant for the fulfilment of a contract or a function assigned by law (e.g. so that the bank can provide its services as part of a payment);
- delivery of invoices to the Client;
- sending of post to the Client concerning amendments to the contract or the price list;
- in accordance with the Client’s explicit and unambiguous consent;
- to persons stipulated in the external laws and regulations upon their reasonable request, in accordance with the procedure and volume specified in the external laws and regulations;
- in the cases stipulated in the external laws and regulations, to protect the legitimate interests of Clean R, e.g. by filing action with a court or other state institutions against a party that violated these legitimate interests of Clean R.10. Access of third-country subjects to personal data
Clean R ensures compliance with the binding statutory procedures to ensure the level of personal data processing and protection equivalent to the level set forth in the Regulation.
11. Duration of storage of personal data
Clean R stores and processes the Client’s personal data for as long as at least one of the following criteria exists:
- the contract entered into with the Client is valid;
- Clean R or the Client can pursue their legitimate interests in line with the procedure specified in external laws and regulations (for example, to submit complaints or to bring action in court);
- one of the parties has a legal obligation to store the data;
- the Client’s consent to the respective personal data processing is valid, if there are no other legal grounds for data processing.
Once the conditions referred to in this clause cease, the personal data of the Client are deleted.
12. Access to personal data and other Client rights
The Client has the right to receive information specified in laws and regulations regarding the processing of their data. Most of the Client’s information is already posted in the e-services section on the cleanr.lv/clean-r website, where the Client can verify the accuracy of their data.
In accordance with applicable laws and regulations, the Client also has the right to request from Clean R access to their personal data, and to ask Clean R to expand, correct or delete these data, or to restrict the processing of the Client’s data, or to object to the processing (including the processing of personal data carried out on the basis of legitimate interests of Clean R); there is also the right to data portability. These rights can be exercised in so far the processing does not arise out of the obligations imposed on Clean R by the applicable laws and regulations and that are in the public interest.
The Client may submit a request for the exercise of their rights:
- in writing, personally submitting the request at the Clean R Customer Service Centre, producing a personal identification document;
- remotely, by signing an application with a secure electronic signature, by logging in to the e-services section of the website;
- Clean R or the Client may pursue their legitimate interests in line with the procedure specified in external laws and regulations (for example, to submit complaints or to bring action in court);
- in electronic form by signing it with a secure electronic signature;
- via the self-service portal at cleanr.lv/clean-r.
Having received the Client’s request for the exercise of their rights, Clean R verifies the Client’s identity, evaluates the request and carries it out in accordance with laws and regulations.
Clean R sends the reply to the Client by registered letter to the contact address provided by the Client, by electronically signed reply via e-mail at the Client’s request, or via the self-service portal cleanr.lv/clean-r, taking into account, as far as possible, the method of receipt of the reply indicated by the Client.
Clean R ensures the compliance with data processing and protection requirements in accordance with laws and regulations and, in the case of the Client’s objections, performs meaningful actions to resolve the objection. However, if this fails, the Client has the right to contact the supervisory authority, the Data State Inspectorate.
13. Client’s consent to data processing and the right to withdraw it
The Client may give their consent to the processing of personal data, the legal basis for which is consent (for example, analysis of data on the habits of using services, customised advertising, etc.), on the self-service portal at cleanr.lv/clean-r, in Clean R service application forms, in Clean R service portals/applications, on Clean R’s and other websites (for example, newsletter subscription forms), by calling the Customer Service Centre at 67111001, via e-mail at [email protected], or in person at the Customer Service Centres.
A list of the categories of personal data that may be processed in accordance with the Client’s consent and other legal grounds is available in Annex 1.
The Client has the right to withdraw their consent to the data processing at any time in the same manner as it was provided, that is on the self-service portal at cleanr.lv/clean-r, by calling the Customer Service Centre at 67111001, via e-mail at [email protected], or in person at the Customer Service Centre, and in this case, the further processing of data, which is based on the previously given consent, will no longer be carried for the particular purpose.
The withdrawal of consent does not affect the processing performed at the time when the Client’s consent was valid.
The withdrawal of consent cannot stop the processing of data carried out on the basis of other legal grounds.
14. Communication with the Client
Clean R communicates with the Client using the contact details provided by the Client (phone number, e-mail address, postal address, www.cleanr.lv/clean-r website)
Clean R communication concerning the fulfilment of contractual service obligations (e.g. change of service or product (e.g. waste container) , information about invoices, changes in services, etc.) is based on the contract.
As part of the communication (incoming calls, e-mails), Clean R verifies the identity of the Client according to the following criteria:
- Phone call: contact phone number of the caller, if it is specified in the contract; Client’s contract number; personal identity number; name; address of service provision;
- E-mail: e-mail address of the author of the message, if it is specified in the contract; Client’s contract number; personal identity number; name; address of service provision;
- E-services section of the website: if the Client has logged in with a bank link or using an electronic signature, then no additional Client authorisation is required, and if the Client has not logged in, the criteria from the e-mail section apply;
- In person: personal identification document
- Postal communication;
- Contact persons: sellers.15. Commercial messages
Clean R conducts communication about commercial messages regarding Clean R and/or third-party services and other messages not related to the provision of directly contracted services (such as client surveys) in accordance with external laws and regulations or with the consent of the Client.
The Client may give their consent to the receipt of commercial messages from Clean R and/or its partners by signing in to the self-service portal at cleanr.lv/clean-r, in Clean R’s service application forms, via Clean R’s service portals/applications, Clean R and other webpages (for example, newsletter subscription forms).
The Client’s consent to receive commercial messages is valid until its withdrawal (also after the termination of the service contract). The Client may at any time refuse to receive further commercial messages in any of the following ways:
- by selecting the corresponding setting in their user profile on the Clean R self-service portal at cleanr.lv/clean-r;
- by sending an e-mail to [email protected];
- by calling the Client Service Call Centre, 67111001;
- by coming to the Client Service Centres in person;
- by using the automated option to unsubscribe from further communication provided in the commercial message, by clicking on the unsubscribe link at the end of the commercial (e-mail) message.
Clean R stops sending the commercial messages as soon as the Client’s request is processed. The processing of a request depends on technological capabilities, and may take up to three full days.
When expressing their opinion in the surveys and leaving their contact details (e-mail, phone), the Client agrees that Clean R can communicate with them in relation to the assessment provided by the Client, using the contact details provided by the Client.
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- recognise new or previous Clients;
- remember your viewing preferences, such as contrast settings or font sizes;
- collect anonymised statistics on how and what services you have searched for;
- collect reliable website use information that allows us to measure how well the site is meeting the needs of its users and to make any necessary improvements;
- analyse the intensity of website visits from specific geographic regions.
Please note that some cookies may be placed by a third-party service provider that performs certain functions for us.
We work with third parties to track your activities on our website, to improve our marketing efforts, and to provide you with advertising based on your visit to our website.
Clean R’s websites may contain links to third-party websites which have their own user and personal data protection policies, for which Clean R bears no responsibility.
17. Other provisions
Clean R keeps the previous versions of this policy and they are available on Clean R website, at www.cleanr.lv/clean-r.
|1||Person’s identification data||name, surname, personal identity number/ID, date of birth, passport No/ID card No|
|2||Contact details||Address, phone number, e-mail address|
|3||Special categories of data (sensitive)||disability note|
|4||Client contact person data||name, surname, e-mail address, phone number of the contact person|
|5||Client data||client contract number, registration date, status, client number|
|6||Self-service portal cleanr.lv/clean-r||data user number, actions performed on the cleanr.lv/clean-r self-service portal|
|7||Supplier details||supplier number, invoice details, address, bank account number|
|8||Client profiling data||category assignment, segment (profiling is subject to the client’s permission for data analysis)|
|9||Service data||service number, service name, service address, price, discount,
expiry date of the discount
|10||End device data||name, type, serial number, MAC address, meter number of the end device|
|11||Service contract data||contract number, date of signature/approval, type, annex number, annex date|
|12||Transaction details||transaction number, date, transaction name, type, status, service
|13||CRM2 activity data||activity number, type, date, category, owner|
|14||Communication data||incoming/outgoing communication type, number, date, content, channel,
|15||Product purchase data||product name, code, date of purchase, consignment note number, product
receipt method, price, method of payment, invoice information, accessories, RFID code
|16||Service purchase data||purchase information: customer orders, purchases, applications linked to the contract; address of service provision|
|17||Instalment payment details||number of the instalment agreement, decision, payment schedule|
|18||Lease (with a purchase option) data||date of lease payment, monthly payment, lease number, RFID CODE of the device|
|19||Solvency verification data||status of external debt, credit risk rating, solvency status|
|20||Payment data||payment system account number, bank account number, invoice number, date, amount, billing method, date of payment, amount owed, debt recovery information|
|21||Fault data||fault number, date of recording/resolution, type, description|
|22||Complaint data||complaint number, date of registration/resolution, type, description|
|23||Client survey data||survey title, date of sending, date of reply, survey questions and answers provided|
|24||Clean R website
|IP address, name of the action taken, section of the web page, date and time|
|25||Photos and pictures||Photos from customer events, photo-shooting date|
|26||Video data||videos from client events, video surveillance on Clean R sites, recording date|
|27||Phone conversation record data||Clean R customer service phone conversation records, date and time|
|28||Data on access to systems||usernames and passwords assigned to the customer|
|29||Consent information 4||client’s statement of consent broken down by subject; date and time of consent, source|
|30||Location data 5||Location of waste containers|
* This is not an exhaustive list of data included in a certain data category
1 Profiling consists of any form of automated processing of personal data which involves the assessment of personal aspects relating to a natural individual, in particular to analyse or predict aspects relating to work performance, economic situation, health, personal preferences or interests, trustworthiness or behaviour, location or movements, while such processing has legal effects concerning the natural individual or significantly affects the natural individual in a similar way.
2 CRM: Client Relationship Management.
3 Stored data include voice telephony (any information or data processed for the purposes of billing and payment accounting),
4 Consent is a freely given, unambiguously expressed declaration of will by the client, by which the client authorises the processing of their personal data in accordance with the information provided by Clean R.
5 Location data include data processed electronically in record-keeping systems.