Privacy Policy

Privacy Policy  

SIA LATIO Privacy Policy 

The aim of this Privacy Policy of SIA LATIO is to provide the data subject (natural person) with information about the purposes and extent of processing, data protection and the period of data processing at the time of receipt of data from the data subject and during the processing of personal data.

Controller and its contact details

1.    The personal data controller is SIA LATIO (hereinafter: Latio), Unified registration No 41703000843, registered office: Rīga, Elizabetes iela 21A-102, LV-1010.

2.    Latio’s contact details for matters related to personal data processing are: latio@latio.lv. You may use these contact details or apply in person at Latio’s registered office with any questions regarding personal data processing. You may submit a request for the exercise of your rights in accordance with the procedure specified herein.

Scope of application of the Privacy Policy

3.    Personal data are any information about an identified or identifiable natural person. 

4.    The Privacy Policy applies to the protection of privacy and personal data in relation to:

4.1       natural persons - clients and other users of services (including potential, former and existing ones), as well as third parties who receive or pass on any information to Latio in relation to the provision of services to a natural person; and

4.2       visitors of Latio’s website,

(hereinafter: the Clients).

5.    Latio takes care of the Clients’ privacy and personal data protection, observes the Clients’ rights to the lawfulness of personal data processing in accordance with the applicable legal acts, inter alia, Regulation (EU) No 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: the Regulation), and other applicable legal acts in the field of privacy and data processing.

6.    The Privacy Policy applies to data processing regardless of the form and/or environment in which the Client provides personal data (paper or electronic format), and on which systems of the company or paper forms they are processed.

Purposes of personal data processing

7.    Latio processes personal data for the following purposes:

7.1       Provision of services:

7.1.1    identification of a client;

7.1.2    preparation and signing of an agreement;

7.1.3    provision of services (fulfilment of contractual obligations);

7.1.4    promotion of use of the service;

7.1.5    service advertising and distribution or for commercial purposes;

7.1.6    client servicing;

7.1.7    reviewing and processing of clients’ objections/complaints;

7.1.8    improvement of client loyalty;

7.1.9    administration of payments; and

7.1.10  improvement of the website.

7.2    Provision of information to state administrative agencies in the cases and to the extent specified in the external laws and regulations.

7.3    Other specific purposes for which the Client is informed on submission of relevant data to Latio.

Legal basis for personal data processing

8.    Latio processes the Client’s personal data based on the following legal grounds:

8.1       conclusion and execution of a contract – to enter into a contract for the provision of services and to ensure its execution;

8.2       execution of laws and regulations – to fulfil an obligation specified in external laws and regulations binding on Latio;

8.3       in accordance with the consent of the Client (the data subject);

8.4       in legitimate interests – to pursue the legitimate interests of Latio arising out of a contract entered into by and between Latio and the Client, or arising out of law.

9.    The legitimate interests of Latio are as follows:

9.1       carry out commercial activities;

9.2       provide appraisal (valuation), consulting and mediation services in real property transactions;

9.3       verify the Client’s identity prior to entering into a contractual relationship;

9.4       ensure the fulfilment of contractual obligations;

9.5       store Clients’ requests for the provision of services, other submissions and applications filed on the website or sent to Latio’s email address, or submitted in paper form;

9.6       analyse the performance of Latio’s homepage, develop and implement improvements thereof;

9.7       take steps for the improvement of customer retention and loyalty;

9.8       develop new services;

9.9       advertise its services by sending commercial communications to the Client;

9.10     send reports on the progress of the contract execution and events relevant to the execution thereof;

9.11     ensure financial and business accounting and analytics;

9.12     ensure the effective governance of the company;

9.13     improve the efficiency of service provision;

9.14     ensure and improve the quality of services;

9.15     administer payments;

9.16     administer outstanding payments; and

9.17     apply to state administrative agencies and law-enforcement bodies and to court to seek protection of its legal interests.

Processing of personal data 

10.       Latio 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 available to Latio.

11.       For the high-quality and timely execution of contractual obligations arising out of the contract entered into with the Client, Latio may authorise Latio group companies or its cooperation partners to perform individual activities for the provision of services, such as inspecting and taking photos of an appraisal object, drafting an appraisal report, sending appraisal reports, invoices and other information, etc. If, in carrying out these tasks, Latio group companies or cooperation partners process the Client’s personal data at the disposal of Latio, the relevant Latio group companies or cooperation partners are considered to be Latio’s processing operators (processors), and Latio is entitled to transfer the Client’s personal data to Latio group companies and cooperation partners for the performance of the above-mentioned activities to the extent necessary to carry out such activities.

12.       Cooperation partners of Latio and Latio group companies (in the status of a processor of personal data) will ensure compliance with the requirements for personal data processing and protection in line with the bylaws and regulations of Latio and external legal acts, and will not use personal data for any other purposes except for the fulfilment of contractual obligations arising out of the contract entered into with the Client and at the instruction of Latio.

Protection of personal data

13.    Latio 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 available to Latio, inter alia, the following security measures:

13.1     Data encryption by transmitting data (SSL encryption);

13.2     Firewall, antivirus programs;

13.3     In-house monitoring software for the prevention of data leakages and intrusions; and

13.4     Other protective measures to the extent technically possible.

Categories of recipients of personal data

14.    Latio shall not disclose to third parties any Client’s personal data or any information obtained in the course of service provision and the validity period of the contract, except for the following:

14.1     if personal data are to be transferred to a third party with regard to the concluded contract to perform any function necessary for the fulfilment of the contract or any function delegated by law (e.g., forwarding/submission of a property appraisal report to a credit institution, bailiff, insolvency  administrator, judicial body, etc.);

14.2     in accordance with the Client’s explicit and unambiguous consent;

14.3     to persons referred to in the external laws and regulations upon their reasonable request, in accordance with the procedure and to the extent referred to in the external laws and regulations;

14.4     in the cases referred to in the external laws and regulations to protect the legitimate interests of Latio, e.g., by applying to court or other state bodies against a person who has infringed upon the legitimate interests of Latio.

Access of third-country parties to personal data

15.    In some cases, subject to statutory requirements, access to Latio’s personal data is granted to service developers or providers based in third countries (i.e., countries outside the European Union and the European Economic Area) in the status of the data processor (operator) (i.e., transfer to third countries within the meaning of the Regulation).

16.    In such cases Latio shall provide for legally required procedures to ensure the level of personal data processing and protection equivalent to the level set forth by the Regulation.

Personal data storage limitation

17.    Latio shall store and process the Client’s personal data as long as at least one of the following criteria exists:

17.1     as long as the contract signed with the Client is in force;

17.2     as long as Latio or the Client can exercise their legitimate interests in line with the procedure laid down in the external laws and regulations (e.g., submit an objection or bring action in court);

17.3     as long as any of the parties has a legal obligation to store data; or

17.4     while the Client’s consent to the respective data processing is valid, if there are no other legal grounds for data processing.

After the date on which the conditions referred to in this clause cease, the Client’s personal data shall be deleted.

Access to personal data and other rights of the Client

18.    The Client has the right to receive information specified in laws and regulations regarding the processing of his/her personal data. 

19.    In accordance with the applicable laws and regulations, the Client also has the right to request from Latio access to his/her personal data, as well as to request from Latio the supplementation, correction or deletion thereof, or request to restrict data processing with regard to the Client, or to object against data processing (inter alia, against the processing of personal data based on the legitimate interests of Latio), as well as the right to data portability. These rights are exercisable in so far as the data processing does not arise out of the obligations imposed on Latio by the applicable laws and regulations.

20.    The Client may submit a request regarding his/her data processing:

20.1     in writing in person at Latio’s offices producing a personal identification document;

20.2     in electronic form (via email) by signing it with a secure electronic signature.

21.    Upon receipt of the Client’s request for regarding his/her data processing, Latio shall verify the Client’s identity, consider the request and execute it in accordance with laws and regulations.

22.    Latio sends a reply to the Client by registered mail to his/her specified contact address, or to the email address if the request was sent by email.

23.    Latio ensures the compliance of data processing and protection with the requirements of laws and regulations, and in case of the Client’s complaint, takes reasonable steps to resolve the complaint. However, if this fails, the Client shall be entitled to apply to the supervisory authority – the Data State Inspectorate.

Client’s consent to data processing and the right to withdraw consent

24.  The Client may give his/her consent to the processing of personal data whose legal basis is customer consent (e.g., for receipt of commercial communications) by filling out an electronic request form for Latio services at Latio’s website, by confirming one’s consent in writing via email, by meeting with Latio’s service providers, inter alia, Latio’s cooperation partners, and by signing a contract with Latio.

25.  The Client has the right to withdraw his/her consent to the data processing at any time by sending a respective notice to the email address: latio@latio.lv, or in person at Latio’s offices, and in such case, no further data processing, based on the previously given consent, shall be carried for that particular purpose.

26.   The withdrawal of consent does not affect the processing performed at the time when the Client’s consent was valid.

27.   The withdrawal of consent cannot stop the processing of data carried out on the basis of other legal grounds.

Communication with the Client

28.    Latio communicates with the Client using the contact details provided by the Client (phone number, email address, postal address).

29.    Communication regarding the fulfilment of contractual obligations is carried out by Latio on the ground of a signed contract (e.g., coordination of services, information about invoices, changes in services, etc.)

Commercial communications

30.   Latio carries out commercial communications regarding Latio group’s services in accordance with external laws and regulations or in accordance with the Client’s consent.

31.   The Client may give his/her consent to the receipt of Latio group’s commercial communications by email or in writing at Latio’s offices or by signing a contract with Latio for the provision of services.

32.    The Client’s consent to the receipt of commercial communications shall be valid until its withdrawal (also after the termination of the service contract period). The Client may at any time refuse to receive further commercial communications in any of the following ways:

32.1     by sending an email to latio@latio.lv;

32.2     in person at Latio’s offices; or

32.3     by using the automated option provided in the commercial communication to unsubscribe from further communications by clicking on the unsubscribe link at the end of the relevant commercial communication (email).

33.    Latio shall stop sending commercial communications as soon as the Client’s request has been processed. The processing of a request depends on technological possibilities and may take up to three days.

Web traffic and use of ‘cookies’ 

34.    Latio’s website uses analytical cookies such as Google Analytics cookies. The purpose of using Google Analytics cookies is to improve the quality of content of Latio’s website and to adapt it to customer needs.

35.   Latio’s website may contain links to third-party websites having user and personal data protection regulations of their own, for which Latio shall bear no responsibility.

Other provisions

36.    Latio has the right to make additions to the Privacy Policy and publish a new version hereof on Latio’s website.