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Privacy Policy

General notice

Scope

This Privacy Policy tells you everything you need to know about how Digital Mind JSC and/or its affiliates, subsidiaries and newly acquired companies protect the personal data we process and control relating to you and which rights you have in relation to the processing of your personal data.

Data controller

The “data controller” means the entity that will make the decisions about how your data is used and that is responsible for deciding how it holds personal information about you.

All Digital Mind entities for the purposes of compliance with data privacy laws are represented by:

Digital Mind JSC, registration No. 40003761569, legal address: 11 Sporta street, Riga, LV-1013, Latvia, privacy@digitalmind.lv.

Data protection and security

Digital Mind attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure that when you deal with Digital Mind, your personal data are in good hands.

We process your personal data only in accordance with the applicable privacy legislation, which means that the personal information we hold about you must be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

Data security

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Personal data categories

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We collect, use, store and transfer different kinds of personal data about you depending on the situation. For more specific information on the processed data, please see the specific privacy notices provided on this website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

We do not generally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. In the limited cases where we do process such data, we do this in accordance with the applicable legislation or our legitimate interest.

Personal data collection and processing

We collect personal data of our employees, potential employees, clients, suppliers, business contacts, shareholders and website users. This data is collected using different methods to collect data from and about you including through direct interactions, automated technologies or publicly available sources. If the data we collect are not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used.

Purpose of processing

We will only use your personal information when the law allows us to. We will use your personal information in the following circumstances:

  • Where you have given consent to the processing of your personal information for one or more specific purposes.
  • Where the processing of your personal data is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Where we need to comply with a legal or regulatory obligation. This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure and we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

We may also use your personal information in the following situations, which are likely to be rare:

  • Where we need to protect your interests (or someone else’s interests).
  • Where it is needed in the public interest (or for official purposes].

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at privacy@digitalmind.lv.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data sharing

Sharing within Digital Mind group

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise and for system maintenance support and hosting of data.

Sharing with 3rd parties

We may transfer personal data to our service providers, professional advisors, public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws.

We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.

Data transfer outside EU/EEA

Unless you are otherwise notified, any transfers of your personal data from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses. Any other non-EEA related transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and standards.

Please contact us at privacy@digitalmind.lv, if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Rights of access, rectification, erasure, and restriction

Under certain circumstances, by law you have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive information on how we process your personal data and a copy of the personal data we hold about you.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data or request that we transfer a copy of your personal information to another party, please contact us at privacy@digitalmind.lv.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Rights of withdrawal

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us at privacy@digitalmind.lv. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Automated decision making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making unless we have a lawful basis for doing so and we have notified you.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

Changes and 3rd party links

Changes to the Privacy notice

Digital Mind reserves the right to amend this General Privacy notice and specific privacy notices at any time, for any reason, without notice to you, other than the posting of the amended privacy notices on this website. You must review this Privacy Notice from time to time for any amendments.

3rd party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Website visitors

Scope

This privacy notice aims to give you information on how Digital Mind collects and processes your personal data and tells you about your privacy rights and how the law protects you, when you:

  • visit our websites (regardless of where you visit is from), or
  • while visiting our website e.g. fill in forms, subscribe to our newsletters and whitepapers, request marketing to be sent to you, ask us to contact you for other reasons, take part in a competition, promotion or survey, or give us some feedback or comment our content.

Personal data categories

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data such as first name, last name, username or similar identifier.
  • Contact Data such as address, email address, telephone numbers, social media contact.
  • Employment Data such as title, company name, department name.
  • Technical Data such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data such as information about how you use our website, products and services.
  • Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not generally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. In the limited cases where we do process such data, we do this in accordance with the applicable legislation. If you choose to provide us with unsolicited sensitive personal data through our websites, you are consenting to the processing of that personal information to the extent necessary and to the extent permitted by applicable legislation.

Personal data collection and processing

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from analytics providers, advertising networks and search information providers.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Purpose/Activity

Lawful basis for processing


To manage our relationship with you, including
  • managing and answering to your requests submitted on the website
  • Notifying you about changes to our terms or privacy policy
  • Asking you to leave a review or take a survey
  • Communicating with you
1. Performance of a contract with you
2. Necessary to comply with a legal obligation
3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website, including
  • troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Marketing and marketing analytics, including
  • Delivering relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • Using data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • Making suggestions and recommendations to you about goods or services that may be of interest to you
1. Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
2. You have given consent to the processing of your personal information for one or more specific purposes.
Administrative reasons and legal compliance
  • complying with legal obligations
Necessary for our legitimate interests (for the purposes of satisfying any legal, accounting, or reporting requirements)

Purpose and legal basis of processing

We will only use your personal information when the law allows us to. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at privacy@digitalmind.lv. if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING COMMUNICATION AND OPTING OUT

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You can ask us or third parties to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at privacy@digitalmind.lv at any time. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

PROMOTIONAL OFFERS FROM US

We may use your personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have given your consent to us sending marketing communication to you, or if you (or the company you represent) have purchased goods or services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we disclose your personal data with any company outside the Digital Mind group of companies for marketing purposes.

TARGETED EMAIL

We send commercial e-mails that typically include technologies (web beacons, cookies or similar) that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from us, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.

We may combine the data collected about you from publicly available sources, and from our different e-mail, website, and personal interactions with you. We combine this data to better assess your experience with Digital Mind and to perform the other activities described in our privacy notice.

COOKIES

When you visit our Website, we may employ cookies that contain information (such as a unique cookie ID) used to track your usage of our Website. This enables our systems to recognize your browser and tell us how, when and which pages in our Website are visited and by how many people, and also enables us to recognize a return visitor as a unique user. For more information about the cookies we use, please see our separate Cookies policy.