1. Personal data processing controller is SIA “Promenade Hotel”, unified registration No. 42103050050, registered address: Juras Street 12, Liepaja, LV-3401.
2. Personal data is information regarding a natural person – a client, employee, job candidate, etc. of SIA "Promenade Hotel" – that allows identifying this person, including a name, surname, identity number, address of place of residence, personal telephone number, personal e-mail, occupation, income amount, received and planned services, payment information, information on communication by telephone, e-mail, and other information. The privacy policy shall be applicable to the processing of data regardless of the form and/or the environment, in which the Client provides personal data (on the SIA "Promenade Hotel" website, on paper or electronically) and the company’s systems or paper form it is being processed.
SIA "Promenade Hotel" cares about the privacy and personal data protection of its Clients, respects the Clients’ rights to lawfulness of the personal data processing in accordance with the applicable laws and regulations of the Republic of Latvia and any subordinated laws and regulations, as well as the 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 (the Regulation), and any other applicable laws and regulations in the field of privacy and data processing.
3. SIA “Promenade Hotel" processes personal data for the following purposes:
• Provision of services: identification of the client; preparation and signing of the contract; ensuring/maintaining the service operation; service improvement and development of new services; advertising and distribution of services or use for commercial purposes; customer service; complaint/claim review and processing; keeping of clients; building of loyalty; satisfaction measurements; administration of payments; debt recovery and collection; website maintenance and improvement of its operation.
• Business planning and analytics: statistics and business analysis; planning and accounting; measuring of effectiveness; data quality assurance; carrying out the market and public opinion studies; preparation of reports; customer surveys; and in the scope of the risk management activities.
• Provision of information to state authorities and subjects of operational activities in the events and to the extent specified in external laws and regulations.
• For the safety of SIA "Promenade Hotel" property and persons in the scope of video surveillance, with a goal to protect the property of SIA "Promenade Hotel" and third parties located on the Hotel (office) premises and territory, to provide for the safety of individuals, prevent possible crimes, record the fact of the crime, as well as to monitor the progress and quality of the Hotel service. Video surveillance data shall be stored for up to 14 days. At the end of this period, SIA "Promenade Hotel" shall ensure complete automatic deletion of data, unless the data has been requested prior to the expiration of the above deadline, or any crimes or other breaches of security have been established. If the data has been requested by the competent state or local government authorities, or security breaches have been recorded, the data shall be stored as needed.
• For other specific purposes for which the Client is informed at the moment when he/she provides his/her data to SIA "Promenade Hotel".
4. SIA "Promenade Hotel" shall process the Client’s personal data, based on the following legal grounds:
• for conclusion and fulfilment of the contract - to enter into the contract based on the Client’s application and ensure its fulfilment;
• for the compliance with the laws and regulations - to fulfil an obligation of SIA "Promenade Hotel" prescribed for in binding external laws and regulations;
• based on the consent of the Client - data subject;
• for legitimate purposes - to exercise legitimate interests of SIA “Promenade Hotel” arising from the obligations or a contract between SIA “Promenade Hotel” and the Client, or prescribed by law.
The legitimate interests of SIA “Promenade Hotel” are as follows: to carry our economic activity; verify the Client’s identity prior to entering into a contract; ensure fulfilment of the contractual obligations; eliminate unjustified financial risks for its commercial activity; keep the Clients’ applications and requests regarding provision of services, other applications and requests, notes regarding them, including applications made orally, by calling, by e-mail, on website, etc.; analyze SIA “Promenade Hotel” website, use of information, develop and introduce improvements thereto; take actions to keep Clients; segment the client database for more effective provision of services; design and develop services; advertise services by sending commercial messages; send other messages regarding fulfilment course of the contract and events important for the fulfilment of the contract, as well as conduct Client surveys regarding the services and experience of use thereof; prevent fraud; ensure corporate governance, financial and business accounting and analytics; ensure effective company management processes; effectiveness of the service provision; ensure and improve the service quality; administrate payments; administrate outstanding payments; file requests to the state authorities and the authorities carrying out operative activities for the protection of its legal interests; inform society regarding its activities.
5. SIA ''Promenade Hotel" shall process the Client data using the modern technologies, taking into account the existing privacy risks and organisational, financial and technical resources reasonably available to SIA "Promenade Hotel", including through the following security measures:
• Pseudonymisation of data to the extent possible;
• Firewalls;
• Programmes for protection against intrusion and for detection purposes;
• Other protection measures according to the current technical development capabilities.
SIA "Promenade Hotel" can make automated decisions in respect of the Client. The Client shall be informed regarding such actions taken by SIA "Promenade Hotel" separately in accordance with the laws and regulations. The Client may object to automated decision-making in accordance with the laws and regulations, however, recognising that in some cases it may restrict the Client’s right to use some options potentially available to him/her (such as to receive commercial offers).
For the qualitative and prompt fulfilment of the obligations arising from the contract signed with the Client, SIA "Promenade Hotel" may authorise its partners to perform some delivery or service provision activities, such as individual works, provision of catering services, sending of invoices and similar. If during performance of these tasks the cooperation partners of SIA "Promenade Hotel" process the Client’s personal data in the possession of SIA "Promenade Hotel", the relevant cooperation partners of SIA "Promenade Hotel" shall be considered as the processors of SIA "Promenade Hotel" data processing, and SIA "Promenade Hotel" may provide the cooperation partners of SIA "Promenade Hotel" with the necessary Client’s personal data to the extent necessary for the performance of these activities.
SIA "Promenade Hotel" cooperation partners (in the status of personal data processor) shall ensure fulfilment of the requirements for personal data processing and the protection according to SIA "Promenade Hotel" requirements and laws and regulations, and shall not use personal data for any other purposes except for the fulfilment of the obligations arising from the contract signed with the Client at the request of SIA “Promenade Hotel”.
6. SIA "Promenade Hotel" shall not disclose to third parties the Client’s personal data or any information acquired during provision of services and the validity term of the contract, unless:
• the personal data must be provided to the relevant third party under the signed contract to perform any function necessary for the fulfilment of the contract or delegated by law (for example, in the scope of bank settlements);
• in accordance with the Client's explicit and unambiguous consent;
• to persons prescribed in external laws and regulations at their reasonable request, based on the procedure and to the extent prescribed in external laws and regulations;
• in events prescribed in external laws and regulations, as well as for protection of legitimate interests of SIA “Promenade Hotel”, for example, by bringing a claim in court or in other state authorities against a person violating these legitimate interests of SIA “Promenade Hotel”.
7. Personal data of SIA "Promenade Hotel" may not be accessed by the developers or service providers in the status of the data processor (operator) in the third countries (i.e. countries outside the European Union and the European Economic Area) (for the purpose of the Regulation - transmission to third countries).
8. SIA "Promenade Hotel" shall store and process the Client’s personal data as long as at least one of the following criteria is met:
• only as long as the contract concluded with the Client is in force;
• while SIA "Promenade Hotel" or the Client can exercise their legitimate interests (such as submit objections or bring or handle action in court) based on the procedure prescribed in the external laws and regulations;
• while either party has a legal obligation to store data;
• while the Client’s consent for the relevant personal data processing is in force, unless any other lawful grounds for the data processing exist.
When the above conditions cease to exist, the Client’s personal data shall be deleted.
9. The Client is entitled to receive information in relation to his/her data processing prescribed in laws and regulations, ensure the accuracy of his/her data and correct it.
In accordance with the laws and regulations, the Client shall have the right to request SIA "Promenade Hotel" to get access to his/her personal data, as well as request SIA "Promenade Hotel" to supplement, correct or delete these data, or restriction of processing in respect of the Client, or the right to object to processing, including to the processing of personal data carried out on the basis of SIA "Promenade Hotel" legitimate interests, as well as the right to data portability. This right may be exercised, as far as the processing of data is not arising from SIA "Promenade Hotel" obligations imposed upon it by the effective laws and regulations, and which are fulfilled for the public interest.
The Client may submit a request on exercising of his/her rights:
• in person at SIA "Promenade Hotel" hotels in writing, presenting a personal identification document;
• based on the procedure prescribed in laws and regulations, SIA ''Promenade Hotel" or the Client may exercise his/her legitimate interests (such as submit objections or bring or handle action in court);
• by e-mail by signing it with a safe electronic signature.
Upon receipt of the Client’s request on exercising of his/her rights, SIA "Promenade Hotel" shall verify the Client’s identity, assess the request and fulfil it in accordance with the laws and regulations.
SIA "Promenade Hotel" shall send a response to the Client by mail to the contact address specified by him/her by a registered letter, taking into account the method of receipt of the answer indicated by the Client to the extent possible.
10. The Client may provide consent for the personal data processing, the legal grounds for which is consent, on the SIA “Promenade Hotel” website or in person at the SIA “Promenade Hotel” hotel.
The data subject shall have the right to withdraw the consent for the processing of data at any time in the same manner in which it was given, and in that case, the further processing of data based on the consent for the above specific purpose will not be carried out in the future.
Withdrawal of consent will not affect the data processing carried out at a time when the Client’s consent was valid.
Processing of data carried out on the basis of other legal grounds may not be terminated by withdrawing consent.
11. SIA "Promenade Hotel" shall communicate with the Client using contact information (phone number, e-mail address, postal address) provided by the Client.
Communication regarding fulfilment of the contractual obligations shall be handled by SIA "Promenade Hotel" on the basis of the signed contract (for example, coordination of the work performance time, invoicing information, changes in services, etc.).
