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1.2 Think Intermedia SIA is committed to protecting and respecting Your Privacy.
1.6 Data control is carried out by Think Intermedia SIA (registration number 40103671346; legal address: Skanstes iela 7 k-1, LV-1013, Riga, Latvia) which trades on behalf of Sendberry. Data control is conducted with the aim to fully observe EU General Data Protection Regulation 2016/679 (the GDPR) as well as any subsequent Latvia legislation regarding data protection.
2. Personal data collection and processing2.1 We collect and process the information provided by You. This information could be collected while You:
• register on Our Platform;
• create a Sendberry account, subscribe to our Service,
• fill in forms,
• submit contact details,
• search for a product or service,
• place an order for Credits,
• report a problem connected with our Website or Service.
This information could include:
• Your name and surname,
• address, e-mail address, phone number,
• financial and credit card information,
• personal description and other media and whether or not you consent to being tracked.
2.2 Failed provision of necessary personal data may result in disability to perform the Services according to the contract.
2.3 You guarantee accuracy, precision and completeness of provided personal data.
2.4 The following information is collected automatically during each of your visits to Our official Website:
• technical information including the Internet protocol (IP) address;
• Your log-in information;
• browser type and version;
• time zone setting;
• browser plug-in types and versions;
• operating system and platform;
• information about Your visit including the full Uniform Resource Locators (URL) clickstream to, through and from Our Websites;
• viewed products and services;
• page response times, download errors, page visit length, page interaction information (scrolling, clicks, mouse-overs etc.);
• methods used to browse away from the page;
• phone numbers used to call our customer service number.
2.5 Your personal data could be received not only directly (which shall mean from Your usage of Our Website) but also indirectly (which shall mean from various third parties and public sources). Indirect collection of information is based on terms set out below.
2.6 Your personal information could be received from Your usage of the other operated by Us Websites or other provided by Us services. You will be immediately informed about such data. Your personal information could be also received from third parties involved into provision of Our Service (business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
2.7 Technical data, analytics etc. are received from the different providers based inside and outside of the EU such as Facebook, Google and LinkedIn.
2.8 Different sorts of ‘Aggregated Data’ including statistical or demographic data could also be collected, used and shared. While being able to be obtained from Your personal data, ‘Aggregated Data’, lacking the possibility to reveal directly or indirectly Your personality, is not identified as personal data according to the law.
2.9 No sorts of Your “Special Categories of Personal Data” including race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinion, trade union membership, health, genetic and biometric data as well as information about criminal convictions and offences, are collected.
2.10 Personal data of those under 18 years is not collected (see clause 7.4 of Our Terms and Conditions).
3.3 The Sendberry website uses six types of cookies; necessary, performance, functional, analytics, advertisement and others. These include first and third party cookies: first party cookies are set and controlled by Us, while third party cookies are set and controlled by a third party tool or service. The duration of a cookie varies.
If you decide to not allow cookies on this site, the site may not function as conceived.
4. Personal data treatment4.1 Information provided by You is treated in the following way and for the following purposes:
• fulfilment of obligations stipulated in contracts between You and Us;
• provision of the information, products and Services the requested by You;
• provision (by Us or by a third party in permitted) of the information about services relied to Your interests;
• notifications about changes and updates about the Services;
• ensure that content from our site is presented in the most effective manner.
4.2 Information collected after Your visit to Our official Website will be used for:
• administration of our Platform including such internal operations as troubleshooting, data analysis, testing, research, statistics etc.;
• platform improvement, ensuring efficient content presentation;
• interactive Service features availability;
• safety and security of Platform;
• verifying your identity;
• measurement of advertising efficiency, delivery of relevant advertising.
5. Personal data disclosure5.1 Your Personal data could be shared by Us with Our group members both inside and outside Latvia and EEA including our parent companies.
5.2 Your Personal data could be shared by Us with the following third parties:
• analytics and search engine providers which help us to improve and optimise our Platform;
• advertisers and advertising networks that require the data to serve relevant adverts.
5.3 In addition to clause 5.2, We take responsibility to provide advertisers with anonymous and aggregate information solely. We guarantee not to disclose any information about identifiable individuals.
6. Regulatory due diligence checks which may involve your personal data6.1 Disclosure of Your Personal data to third parties may be executed in case:
• the disclose your Personal data is necessary in the process of selling or buying any business or asset;
• Your Personal data held by Think Intermedia SIA is transferred as an asset in the process of Think Intermedia SIA acquisition by another entity;
• the disclosure of Your Personal data is required according to any legal obligation, Our Terms of Service and other agreements;
• it is necessary to protect rights, property and/or safety of Think Intermedia SIA, our parent companies, our customers, or others including the exchange of the information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7. Personal data storage7.1 Your Personal data in its whole or in its parts is stored on Our secure servers. You take full responsibility for the confidentiality of accessible by Your personal password parts of Platform. It is Your responsibility to store Your password safely without sharing it with third parties.
7.2 Despite Our efforts to operate your Personal data as safe as possible, data transmission throughout the Internet cannot be completely secure which means We cannot guarantee exhaustive security of Your transmitted data. Transmission of Your Personal data to Our Platform via Internet is at your own risk. Immediately after receiving Your information We strictly process and secure it preventing Your Personal data from any possible unauthorised access.
7.3 Your Personal data is stored not longer than is necessary under terms of its collection, unless required otherwise according to any legal reason. It is our responsibility limited by the borders of reasonable to eliminate all unnecessary data. Your Personal data is stored on Our Platform from the moment Your Sendberry account activation and until the 30th day after the termination of Our agreement.
8. Your rights8.1 Your Personal data is processed in accordance with Your rights under the GDPR.
8.2 Your specific rights under the GDPR are the following:
8.2.1 Withdrawing the consent to processing Your Personal data in case Your consent is required. Consent withdrawing is performed by contacting Our Client Support Centre via its official DPO e-mail address which is [email protected]. The processing of Your Personal data could be performed, in accordance with the lawful processing GDPR requirements, without Your consent in certain circumstances including, among others, execution of Our contractual obligation, compliance with a legal obligation, protection of Your vital interests etc.
8.2.2 Requesting inaccurate or incomplete Personal data rectification. In this case, the rectification is carried out as soon as possible and usually within one month, unless the rectification is complex.
8.2.3 Requesting Personal data elimination. According to the right to be forgotten, data elimination could be requested in case the processing of Your Personal data is identified as unreasonable. In the opposite case We may explain You the reason(s) of retaining Your Personal data, unless otherwise stipulated by law.
8.2.4 Restricting the processing of Personal data. We retain Your Personal data and do not process it further without Your consent in case Your Personal data:
• is processed unlawfully;
• is no longer relevant to the specific purpose of processing;
• is for used for establishing, exercising or defending a legal claim;
• is used to protect the rights of other individuals;
• is used for public interest reasons.
8.2.5 You will receive a notification about the lift of restriction in case any of circumstance described above in clause 8.2.4 occurs.
8.2.6 Requesting the access to your personal data via. Requests are accepted in writing only, sent to Our DPO officer to official [email protected] e-mail address. You will be needing to prove Your identity before You being provided with request information. The procedure is mostly fee-free unless administrative costs appear. In this case We will charge You for the amount of administrative costs spent to execute Your request.
8.2.7 Requesting Personal data non-processing for marketing purposes.
8.2.8 Obtaining and reusing Personal data for individual purposes throughout different services. Data portability right is applicable in those situations only when all following conditions are met:
• We are provided with the data by You;
• Data processing is performed under Your consent;
• Data processing is required to fulfil the contractual obligations between Us;
• Data processing is carried out by automated means.
8.2.9 After all requirements described in clause 8.2.8 are successfully met, You will be provided with requested data in a structured, commonly used and machine-readable format.
9. Responsibility limitationAs far as You follow any link, contained on Our Platform, to any of Our partners’ websites, it is Your responsibility to check their specific Privacy Policies before submitting any Personal data. We do not take any responsibility or liability for Our partners’ Policies.
12. General Data Protection Regulations (GDPR)The General Data Protection Regulation (GDPR) requires that businesses are accountable and transparent about the personal customers data they hold, how the data is used, and gives the customers control over whether to allow that data processing to take place. GDPR came into force on 25th May 2018.
It is our customers’ responsibility as data controller (data controller refers to the person or people who determine the purpose (why) and means (how) of the processing of personal data) of their contact database to ensure they are compliant with GDPR. As the Data processor, Sendberry recommend customers not to upload any data to the Sendberry platform to process unless they know its compliant and consent has been received.
Sendberry are fully compliant with GDPR and have processes to deliver for and comply with the the GDPR regulations.