Zila str 23a, Riga, LV-1007, Latvia. Phone +37167322945. E-mail riga@strek.lv

The document (hereinafter referred to as the Policy) is designed to inform the natural persons specified in the Policy about the activities carried out with their personal data by STREK, registration number: 40003034583, legal address: Riga, Zila str. 23, LV-1007 (hereinafter referred to as STREK).


Strek provides the following services (hereinafter - Services):

  • Stevedoring services;
  • Acceptance, storage and transshipment of cargo;
  • Coal crushing, sorting and magnetic cleaning;
  • Cargo transportation services;
  • Customs formalities services;
  • Shipping agent services;
  • other related services (eg customer support services).

Personal data is any information relating to an identified or identifiable natural person (data subject).

1. Scope of the policy

The policy defines the processing of natural persons' data that applies to Strek:

  • to existing customers who are natural persons and who use the Strek Services;
  • to potential customers who are natural persons who have not established a relationship with Strek and who are interested in the terms and/or costs of providing Strek Services;
  • former customers, including those whose contractual obligations have not been fulfilled or who agreed to receive commercial communications after the termination of the contract;
  • for persons present in the facilities or in the areas adjacent to them;
  • for followers of information systems, websites, social network accounts and users of technical solutions (e.g. mobile apps);
  • real estate owners, owners' representatives;
  • real estate lessees, lessors;

any other natural person (hereinafter - Clients) who applies to Strek.

The Policy operates in conjunction with Strek's other terms and conditions in relation to the use of the Strek Service, web pages.

In order to inform you about the processing of your personal data, Strek provides you with the following information in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (April 27, 2016) on the protection of natural persons with regard to the processing of personal data and the free movement of such data and which repeals Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the Regulation) and the Personal Data Processing Act.

2. Processor

The manager of your personal data specified in the policy is Strek. Strek's contact information for personal data processing issues is:

address: Zila str. 23, Riga, LV-1007, Latvia

phone number: +371 67 322 945

E-mail address: riga@strek.net

3. Personal data and purposes of personal data processing

Strek processes your personal data (Personal Data) including, but not limited to, for the following purposes:

a. To provide Strek Services:

  • for the conclusion and implementation of the product/goods trade agreement and other agreements, as well as for the provision of Services, including, for example:
  • For customer identification;
  • for consideration of submissions, requests, claims and proposals;
  • For customer consultation.

b. To develop Strek Services and ensure quality:

  • To improve services and develop business;
  • To ensure the provision of services and quality control.

c. For security and protection of other legal interests:

  • To ensure the security of Strek's information systems and to prevent and investigate information technology security incidents (for example, unauthorized external access to Strek's information systems, any websites or apps, as well as any kind of malicious activity on Strek's information systems, any websites or apps (for example, a DDoS attack)) ;
  • for ensuring physical security in Strek premises, in the territory of the facilities or near the facilities, including video surveillance and the implementation of access control (for example, issuing passes), and the prevention and investigation of physical security incidents;
  • for identifying fraud and corruption risks and ensuring transparency, including reporting of violations.

d. For marketing and loyalty promotion:

  • To promote the Strek Services and for marketing activities, including, for example:
  • for direct advertising aimed at the Customer;
  • for organizing visits and events for Customers at Strek facilities, as well as for other public events and ensuring publicity of events;
  • for organizing surveys and researching opinions about Strek services and products/goods.

e. For the implementation of social responsibility and improvement of representative relations:

  • for the general development of the Manager's activity, for building sustainable and trust-promoted relationships with Customers and other interested parties.

f. To ensure economic activity:

  • for record keeping, accounting and financial records, protection of financial interests (for example, accounting of transactions, payment of bond coupons and convening of meetings);
  • for the management of movable and immovable property;
  • for organizing procurement.

g. To fulfill the requirements of regulatory acts or to exercise Strek's rights in accordance with regulatory acts:

  • for providing information to state and local government control and pre-trial investigation institutions, other state and local government institutions within their competence, for example, the Police, the State Audit Office or archives;
  • for requesting information from state institutions or other authorized persons about the Client in cases where it is permitted by law, for example from the Land Registry, Cadastre IS or municipalities about the owner of land/buildings;
  • for the prevention of money laundering and financing of terrorism and proliferation and compliance with national and international sanctions.

If you want to know exactly which categories of your personal data are processed in relation to a specific purpose of data processing, we invite you to familiarize yourself with Policy Annex no. 1.


4. Legal basis of personal data processing

Strek processes your Personal Data in the following cases (see information in Policy Appendix No. 1).

A contract has been concluded or will be concluded between you and Strek. In this case, Strek processes your Personal Data if it is necessary for Strek to fulfill the contract or to take measures at your request before concluding the contract. This includes the electricity and/or natural gas trade agreement, as well as any other agreement concluded between Strek and you. If you do not provide Strek with the Personal Data necessary for the performance of the contract, Strek will not be able to perform the contract. Strek is not responsible for non-fulfilment of such obligations in accordance with the mentioned contract, if the contract cannot be fulfilled due to non-provision of Personal Data.


The processing of your Personal Data is necessary to fulfill the legal obligations applicable to Strek as defined in the regulatory acts. For example, Strek is obliged to ensure the provision of your information to state institutions and information systems under their management, for example, the protected user data information system managed by the Construction State Control Office, to comply with the management obligations of accounting documents, as well as to archive documents in cases determined by regulatory acts.


The processing of personal data is necessary to meet the legitimate (lawful) interests of Strek or a third party. Legitimate interests are rights, the exercise of which is permissible in accordance with regulatory enactments, including in connection with the contract concluded between you and Strek.


Strek obtained your consent for the processing of Personal Data (including in writing, as well as by telephone or using other online solutions).


The processing of personal data is necessary for Strek to fulfill a task carried out in the public interest. For example, in accordance with the Law on the Legalization of Criminal Proceeds and the Prevention of Financing of Terrorism and Proliferation, research of Strek Clients is carried out in the public interest to the extent prescribed by law.


5. Recipients and sources of personal data

Strek may transfer your Personal Data to the following recipients of Personal Data, if this does not conflict with applicable regulatory enactments:

  • Strek employees and authorized persons who process the Personal data specified in this Policy on behalf of Strek within the scope of their competence and work tasks;
  • to persons related to the provision of Strek Services, if the Service involves the processing of certain types of data or it results from ensuring the Controller's economic activity, including, but not limited to:
  • information system consultants and their service providers, including machine learning service providers;
  • contractors (for example, construction contractors who receive Personal Data of real estate owners);
  • For customer opinion research service providers and research service providers;
  • to service providers who ensure the delivery of information or goods to Customers;
  • legal service providers;
  • real estate management and administration service providers;
  • economic activity assurance service providers;
  • printing service providers;
  • out-of-court debt recovery service providers;
  • security and security service providers.
  • insurance service providers;
  • postal and delivery service providers;
  • to providers of public information services (eg media);
  • credit information bureaus;
  • audit and audit service providers;
  • banks and other settlement and financial service providers, as well as service providers who ensure the exchange of information between Strek and financial service providers;
  • cookie managers;
  • for maintainers and service providers of online communication channels;
  • to verifiers of the reliability of a secure electronic signature (the European Commission and/or VAS "Latvijas Valsts radio und televsionis centrs");
  • To your authorized persons with whom Strek communicates to ensure the provision of Services or the protection of its interests, as well as for other purposes mentioned in this Policy;
  • to state and local government institutions (for example, the Land Registry, Cadastre IS, the protected user data information system, the Directorate of Citizenship and Migration Affairs);
  • law enforcement authorities, courts.

In addition, Strek may receive information about you from third parties, such as:

  • state and local government institutions (for example, the Land Registry, Cadastre IS, the protected user data information system, the Directorate of Citizenship and Migration Affairs);
  • credit bureaus and other persons who have the right to maintain information about the creditworthiness of individuals in order to verify the Customer's ability to pay for Strek Services;
  • service providers who ensure the exchange of information between Strek and financial service providers.
6. Term of personal data processing

Your Personal data is processed to the extent that is reasonably necessary depending on the specific purpose of data processing, in compliance with the provisions of the applicable laws and regulations.


Strek will store your Personal Data:

  • as long as it is necessary to achieve the purposes of Personal Data processing specified in Section 4 of the Policy, including fulfilling the obligations set forth in regulatory acts, for example:
  • we will keep the information reflected in the contract and which reflects the fulfillment of the obligations assumed in the contract for 10 years after the termination of the contract. The manager, if in his opinion the information reflecting the fulfillment of the obligations assumed in the contract is not essential, reserves the right to delete certain information sooner;
  • fulfilling the obligation set forth in the law on the legalization of proceeds of crime and the prevention of terrorism and proliferation financing, we will keep the information obtained during the inspection for 5 years after the termination of the transaction;
  • we will keep information about issued invoices and information related to payments for no less than 5 years, in accordance with the provisions of the Accounting Law;
  • we will keep audio recordings for no longer than 2 years;
  • we will store video surveillance recordings for no longer than 60 days, depending on the object's functions,
  • as long as your consent to the processing of Personal Data, such as marketing activities or cookie processing, is valid,
  • if a complaint is received or the Controller's legal interest is violated, for example, there is a dispute about the amount of services received, the relevant information may be stored until the issue is resolved, for example, until the final court judgment enters into force.
7. Personal data is processed through cookies

In order to improve the functionality of Strek web pages and to adapt them to your usage habits, as well as to obtain statistics on the actions performed, provide a personalized user experience and inform you of current events, Strek websites process cookies. Necessary or functional cookies are processed for Strek's legitimate interests.


The Strek web page may contain links to other web sites. However, if you use these links, you should note that Strek has no control over other websites. For this reason, Strek cannot be held responsible for the protection and confidentiality of any information you provide when visiting such websites, and these websites are not covered by this notice. You should exercise caution and review the privacy or confidentiality statement of the respective website.


8. Transfer of personal data outside the European Union

In some cases, Strek may transfer Personal Data outside the European Union, for example, when online communication (such as WhatsApp) or data storage solutions that provide services outside the European Union are used, or by engaging third parties that help Strek carry out the economic activities mentioned in this Policy operational tasks and located outside the European Union. For statistical and marketing purposes, Strek may also use cookies from third parties, such as Google, Facebook, where the information generated by the cookies may be sent and stored outside the European Union.

Depending on the circumstances, Strek can choose the special Personal Data Protection Guarantees specified in the Regulation, for example, conclude standard clauses with the recipient of Personal Data or use exceptions, for example, grounds such as the need to fulfill the contract concluded between you and Strek or your consent to data processing, for example by giving consent for the processing of cookies or after receiving relevant information about the communication channel used, you indicate information containing personal data, thus expressing your consent to the exchange of personalized information on the WhatsApp channel.

You have the right to familiarize yourself with or receive information about the processing and/or the mentioned guarantees using the Strek contact information specified in Section 2 of the Policy.

9. Your rights within the framework of Personal data processing

You have the following rights regarding the Personal Data mentioned in this Policy:

  • Access rights. You have the right to access your personal data and receive information from Strek about the processing of your personal data. If the information provided in this Policy does not seem comprehensive enough to you, please contact Strek using the Strek contact information provided in Section 2 of the Policy!
  • For any additional copies of Personal Data that You request from Strek, Strek may request a reasonable fee arising from administrative costs. In addition, if you submit a request in electronic form and do not request otherwise, Strek provides information in a widely used electronic format.
  • Right to correct. In case of inaccuracies, you have the right to request that Strek correct inaccurate Personal Data.
  • Right to erasure. You have the right to request that Strek delete your Personal Data if:
  • You revoked your consent to the processing of Personal Data, taking into account that the withdrawal of consent does not affect the data processing that was carried out during the validity of the given consent;
  • The personal data are no longer necessary in connection with the purposes specified in Section 3 of the Policy for which they were processed;
  • You have objected to the processing and Strek's legitimate reasons do not override your legitimate reasons, or if the Personal Data is processed for direct marketing purposes;
  • Personal data is processed illegally;
  • Personal data must be deleted in accordance with the requirements of regulatory acts.
  • Please note that the right to deletion does not apply to cases where Strek is obliged to process Personal Data in accordance with regulatory enactments or data processing is necessary for archiving, public interest or statistical purposes, as well as in connection with the filing, implementation or defense of a legal claim.
  • The right to restrict the processing of Personal Data. You have the right to request Strek to restrict the processing of Personal Data if:
  • You dispute the accuracy of the Personal Data or the legality of the processing (the restriction will be in effect while the dispute process is ongoing);
  • The processing of personal data is illegal, but you object to the deletion of personal data;
  • Strek Personal Data is no longer needed, but you need it to bring, exercise or defend legal claims
  • You have objected to the processing and until it has been verified that Strek's legitimate reasons do not override your legitimate reasons.
  • The right to object to processing. Based on reasons related to your particular situation, you have the right to object at any time to the processing of your Personal Data based on the legitimate interests and public interests specified in section 4, as well as profiling or automated decision-making described in section 11. Strek has the right to continue processing your Personal Data, despite the objections received, if Strek indicates compelling legitimate reasons for processing that are more important than your interests, rights and freedoms, or to establish, exercise or defend legal claims.
  • In cases where Strek uses your Personal Data for direct marketing purposes, you have the right to object at any time to the processing of your Personal Data for such purposes if it involves profiling (as specified in Section 11 of the Policy).
  • Right to withdraw consent. In cases where you have given your consent to the processing of certain personal data, you have the right to withdraw it at any time. If consent is provided via a web page, you may withdraw your consent on the respective web page located at the bottom of the website. In other cases, you can use the Strek contact information specified in Section 2 of the Policy to withdraw consent.
  • If you withdraw your consent, including consent to the use of cookies, Strek has the right to limit the functionality and scope of its Services, the framework of the web page, as well as the provision of related services, if it depends on the existence of the corresponding Personal Data. Withdrawal of consent does not affect data processing that was carried out during the period of validity of the given consent.
  • Right to portability. You have the right to receive your Personal Data, which you have provided to Strek, in a structured, widely used and machine-readable format and have the right to request that said data be sent to another controller (service provider) if this Personal Data is processed on the basis of a contract by automated means or on the basis of consent (as set out in Section 4 of the Policy).
  • Right to lodge a complaint. You have the right to file a complaint with the State Inspectorate of Strek and Data if you believe that your Personal Data Protection rights have been violated. However, before contacting the Data State Inspectorate, please contact Strek to find a solution if your right to Personal Data Protection has been violated. Strek takes care of the protection of your personal data and will provide you with the necessary support.

You can use the Strek contact information specified in section 2 of the Policy to exercise the aforementioned rights, except for cases where this section specifies otherwise.

10. Request submission procedure

To exercise all the above-mentioned rights, you can use Strek's contact information specified in this Policy, specifying the following personal data in the request: name, surname, personal identification number, postal address (if you want to receive the answer by registered letter) or e-mail address (if you want to receive the answer by e-mail - the postal address from which you sent the request).

We invite you to submit your request in one of the following ways:

  • send a free-form submission electronically to e-mail riga@strek.net, by signing the submission with a secure electronic signature;
  • send your signed free form application by mail to the address: STREK, Zila str. 23, Riga, LV-1007.
11. Automated decision-making, including profiling, in the processing of Personal Data

With regard to your Personal Data, automated decision-making, including profiling, may take place in the following cases:

  • analysis, accounting and forecasting of activities for the development and offering of Services corresponding to the wishes and interests of Customers, and for sending personalized messages, is based on the information that has been transferred to Strek and created during the use of the Services, as well as depending on your interests and habits of using the Services, e.g. , based on the type of Service chosen by the Customer and the habits of using the Service and the type of communication channel;
  • within the framework of settlement monitoring, creditworthiness assessment and debt management, to ensure that you are provided with timely information about the delay in the fulfillment of obligations arising from already concluded contracts, and in order to fully evaluate the possibility of concluding other contracts, automated customer data profiling is carried out in relation to the customer's payment and billing habits. The customer's payment and settlement habits (including negative payment history) may affect the content of alerts and the range of Services available to you. Your payment history for Strek Services may affect your right to make installment payments. If you have a positive payment history, you will have access to the function to pay for Services in installments;

You have the right to object to an automated decision, including profiling, and the right to invite Strek to review the decision and ask to involve Strek employees in the evaluation of the decision, in accordance with the procedures set out in Section 10.

Annex no. 1. - Personal data processing purposes, personal data categories and legal basis

Purpose of personal data processing

Categories of personal data

Legal basis for personal data processing

Strek Provision of Services

Identification information

contact information

Delivery address

Information about the contract

Payment information

Purchase history

Credit information

Credit rating

Information about your opinion

Information contained in communication materials (e.g. questionnaire, correspondence, including social networks, e-mails or other communication channels chosen by the Customer)

Information about the Service and/or product/goods

Information about the information system, web page.

Information about orders and their statuses

Information specified in the insurance certificate/information sheet/policy

Information obtained as part of a customer inspection for the purpose of compliance with regulatory acts

Necessary cookies

Audio recordings (e.g. phone call recordings)

Video recordings

Photos

Authentication information

Visit details

Access information

Vehicle information

Company represented (if applicable)

As part of the purpose, we will process Personal data to conclude a contract with you and ensure the fulfillment of contractual obligations.

In the cases specified in the regulatory acts, we will process Personal Data to fulfill the legal obligations set by Strek, as well as process the data to realize, for example, the following legitimate interests of Strek:

  • protect their rights by using the services of authorized and competent institutions;
  • ensure the provision of Services and/or communication with the actual recipient of the Service and/or communication;
  • prevent legal and security risks, i.e. detect, investigate and secure evidence (for example, in the event of a potential dispute, to store personal data for a certain period of time to resolve the dispute);
  • prevent potential financial and organizational risks (for example, to manage debts);
  • respond to Customer information requests and ensure communication;
  • perform credit risk management and prevent payment execution risks by assessing the creditworthiness of the Customer or potential Customer;
  • ensure the operation of the information system, web pages, develop and implement their improvements, as well as ensure their use for Customers.

Development and quality assurance of Strek Services

Identification information

contact information

Delivery address

Information about the contract

Payment information

Purchase history

Credit information

Credit rating

Information about your opinion

Information contained in communication materials (e.g. questionnaire, correspondence, including social networks, e-mails or other communication channels chosen by the Customer)

Information about the Service and/or product/goods

Information about the information system, web page.

Information about orders and their statuses

Information specified in the insurance certificate/information sheet/policy

Information obtained as part of a customer inspection for the purpose of compliance with regulatory acts

Necessary cookies

Audio recordings (e.g. phone call recordings)

Video recordings

Photos

Authentication information

Visit details

Access information

Vehicle information

Company represented (if applicable)

As part of the purpose, we will process Personal Data on the basis of the concluded contract, as well as to realize, for example, the following legitimate interests of Strek:

  • provide, develop and develop the Services, ensure their improvement and commercial development, analysis and planning, including implementing measures to increase efficiency by measuring the use and efficiency of the digital channel and offering Services suitable for the Customer's needs and granting individualized additional benefits;
  • would protect the interests of the Client and Strek and would know the quality of the Services provided and provide evidence for communication.

Protection of security and other legal interests

Identification information

contact information

Delivery address

Information about the contract

Payment information

Purchase history

Credit information

Credit rating

Information about your opinion

Information contained in communication materials (e.g. questionnaire, correspondence, including social networks, e-mails or other communication channels chosen by the Customer)

Information about the Service and/or product/goods

Information about the information system, web page.

Information about orders and their statuses

Information specified in the insurance certificate/information sheet/policy

Information obtained as part of a customer inspection for the purpose of compliance with regulatory acts

Necessary cookies

Audio recordings (e.g. phone call recordings)

Video recordings

Photos

Authentication information

Visit details

Access information

Vehicle information

Company represented (if applicable)

Legal information

Message content

We will process personal data on the basis of your consent if you wish to disclose your identity as a whistleblower to other persons or if your submitted report of a possible violation will not be recognized as a whistleblower report, but you would like your personal data to be processed for the purpose of contacting you about the content of the report .


In the cases specified in the regulatory acts, we will process personal data to fulfill the legal obligations set by Strek, as well as process the data to realize, for example, the following legitimate interests of Strek:


protect their rights by using the services of authorized and competent institutions;

prevent legal and security risks, i.e. detect, investigate and secure evidence (for example, in the event of a potential dispute, to store personal data for a certain period of time to resolve the dispute);

ensure openness and honesty in cooperation with third parties, as well as identify and mitigate possible cases of fraud and corruption risk;

prevent potential financial and organizational risks;

prevent and detect security risks (for example, by conducting video surveillance in objects and their adjacent territories, providing a pass system and controlling visitor access, creating audit records).

Marketing activity and promotion of loyalty

Identification information

contact information

Information about the contract

Purchase history

Credit rating

Information about the communication channels used

Information about your opinion

Information contained in communication materials (e.g. questionnaire, correspondence, including social networks, e-mails or other communication channels chosen by the Customer)

Information about the Service and/or product/goods

Information on consent to receive news and offers/surveys

Delivery address

Information about the use of information systems, web pages

Cookies

Audio recordings (phone call recordings)

Video recordings

Photos

Social media information.

We will process personal data on the basis of your consent if you have agreed to the collection of cookies and/or expressed your wish to participate in Strek's various marketing activities, such as surveys and opinion surveys.

As part of the purpose, we will process Personal Data to realize, for example, the following legitimate interests of Strek:

  • ensure the provision of Services and/or communication with the actual recipient of the Service and/or communication;
  • ensure the maintenance of positive relations with Customers, as well as raising Customer satisfaction;
  • retain and attract customers;
  • provide, develop and develop the Services, ensure their improvement and commercial development, analysis and planning, including implementing measures to increase efficiency by measuring the use and efficiency of the digital channel and offering Services suitable for the Customer's needs and granting individualized additional benefits;
  • carry out marketing activities, including advertising of Services and events.

Ensuring economic activity

Identification information

Contact information

Delivery address

Information about the contract

Payment information

Information about the object (real estate)

Information contained in communication materials (e.g. correspondence, including social networks, e-mails or other communication channels chosen by the Customer)

Information about the Service and/or product/goods

Audio recordings (e.g. phone call recordings)

Video recordings

Authentication information

Access information

Number of bonds and related tax amounts

Vehicle information

Company represented (if applicable)

Professional eligibility, experience and education data

In the cases specified in the regulatory acts, we will process personal data to fulfill the legal obligations set by Strek, as well as process the data to realize, for example, the following legitimate interests of Strek:

  • prevent potential financial and organizational risks;
  • ensure the continuity of operations and the registration of operational activities for the activities performed during a specific period of time;
  • establish and maintain a supplier qualification system.


Fulfilling the requirements of regulatory acts or exercising Strek's rights in accordance with regulatory acts

Any of the above Personal Data

In the cases specified in the regulatory acts, we will process personal data in order to fulfill the legal obligations set by Strek and to fulfill the task that Strek performs in the public interest.


As part of the purpose, we will process Personal Data to realize, for example, the following legitimate interests of Strek:

  • protect their rights by using the services of authorized and competent institutions;
  • would protect their rights by using the information available from third parties in accordance with regulatory enactments and fulfilling the obligation set forth in the Law on the Prevention of Money Laundering and Financing of Terrorism and Proliferation.



Strek has the right to make additions to the Policy, making its current version available to you on the web page.


The policy was renewed on 20.03.2023.