Goal of the Privacy Policy The goal of the Privacy Policy is to provide information about how and why Keepers Club collects, processes, and uses your personal data. It elaborates on the purpose, legal basis, processing volume, protection, and processing term to a natural person who is a data subject.

1. Controller and Contact Details

1.1 The Personal Data Controller is Keepers Club, registered address: Miesnieku 14-21, Riga LV-1050 

1.2 Contact information for inquiries regarding personal data processing: +371 25257143, e-mail: [email protected] 

1.3 Contact information of the assigned person to inform and consult Keepers Club staff in matters related to personal data processing and inform about potential data protection violations: +371 25257143, e-mail: [email protected]

2. General Terms and Conditions

2.1 The purpose of the Keepers Club Privacy Policy is to provide a natural person with information on the purpose of personal data processing, legal basis, processing volume, data subject’s rights, protection, and processing time during data acquisition and when processing personal data of the data subject. 

2.2 Privacy policy is applied to personal data protection regarding: 

2.2.1 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as – Regulation); 

2.2.2 Personal Data Processing Law of the Republic of Latvia; 

2.3 This Privacy Policy applies to ensuring privacy and personal data protection for: 

2.3.1 Natural persons – customers of Keepers Club (including potential, former, and existing customers); 

2.3.2 Visitors of the website of Keepers Club; 

2.3.3 Persons whose data are processed in social media in relation to marketing activities of Keepers Club (henceforth – Members). 

2.4 The Privacy Policy applies to data processing collected regardless of the form and/or media used for data sourcing from the member (on-site, website, hard copy, or by phone). 

2.5 Keepers Club may establish additional regulations for certain types of data processing, of which persons are informed at the time of providing the relevant data.

3. Purposes of Personal Data Processing

3.1 Keepers Club processes personal data in accordance with applicable external and internal laws and regulations, including for the following purposes: 

3.1.1 To provide retainer maintenance services: • to identify the member; • to schedule appointments; • to prepare records according to statutory requirements; • to send reminders to members about scheduled visits; • to evaluate the suitability for retainer usage; • to administer settlements; 

3.1.2 To recover debts; 

3.1.3 To examine member objections and control quality; 

3.1.4 To promote member loyalty, to measure satisfaction; 

3.1.5 To maintain the website and improve its functions; 

3.1.6 To plan business and perform analytics; 

3.1.7 To provide information to state administration and operative subjects in cases and to an extent laid down in laws and regulations; 

3.1.8 To ensure safety and property protection of Keepers Club and to evaluate staff service quality.

4. Legal Basis of Personal Data Processing

4.1 Keepers Club processes personal data of members on the following legal bases: 

4.1.1 For the purposes of providing retainer maintenance services, the processing shall take place in line with a consent from the data subject (member); 

4.1.2 To comply with laws and regulations – to comply with obligations stated in the laws and regulations binding on Keepers Club; 

4.1.3 Processing is needed to exercise or defend the legal interests of Keepers Club in courts; 

4.1.4 Processing is necessary to ensure legitimate interests of Keepers Club (to organize efficient provision of services, to ensure efficient scheduling and canceling of visits, to receive payment for provided services, to promote Keepers Club in mass media and social networks); 

4.1.5 Processing is necessary to perform contracts with data subjects (members) or to take measures at the request of data subjects before entering into the contract; 

4.1.6 Processing is necessary to protect vital interests of data subjects (members) or other natural persons.

5. Personal Data Processing

5.1 Obtaining personal data from persons depends on the content of the transaction. 

5.2 Personal data may be obtained in the following ways: 

5.2.1 Clear and unambiguous consent of the person has been obtained; 

5.2.2 Information provided to Keepers Club by the person themselves (or by an authorized person), to wit by, by contacting or cooperating with Keepers Club, such as concluding a contract, requesting information, or applying for a specific issue or request, by visiting Keepers Club, communicating through information channels, including social networks, 

5.2.3 When visiting the Keepers Club website, cookies may be used, about which information is provided during the visit to the website; 

5.2.4 From information systems auditing records (access time, activities performed, etc. in the information system). 

5.3 Keepers Club stores and processes personal data as long as at least one of the following criteria exists: 

5.3.1 As long as the obligations arising from the consent signed by Keepers Club and the member are being performed or the member is receiving services; 

5.3.2 As long as Keepers Club has a statutory obligation to store the data; 

5.3.3 As long as the member’s request/application is being reviewed and/or performed; 

5.3.4 As long as the member’s consent for processing of relevant personal data is in force, unless there are other legal grounds for data processing. 

5.3.5 As long as Keepers Club or the person may exercise their legitimate interests in accordance with the procedures laid down in external regulatory enactments (for example, to submit objections or to bring/lead an action before the court); 

5.4 Upon expiry of circumstances under Clause 5.3, the member’s personal data are deleted. Auditing records are stored for one year since their recording. 

5.5 Keepers Club processes member data with modern technologies, considering existing privacy risks and organizational, financial, and technical resources available to Keepers Club. 

5.6 Keepers Club may take automated decisions regarding the member. The member is privately notified about such acts of Keepers Club according to laws and regulations. 

5.7 Automated decision-making, which causes legal consequences to the member (for example, transfer to collection companies for debt recovery), may take place during the performance of the consent between Keepers Club and the member or on the basis of obvious consent of the member.

6. Personal Data Protection

6.1 Keepers Club protects member data with modern technologies, considering existing privacy risks and organizational, financial, and technical resources available to Keepers Club.

7. Transfer / Disclosure of Personal Data

7.1 Keepers Club does not disclose personal data to third parties, except:

 7.1.1 In line with a written consent from the member; 

7.1.2 To persons stipulated in laws and regulations (including institutions) at a reasonable request from them in accordance with the procedure and to the scope stated in such laws and regulations; 

7.2 Keepers Club does not disclose other personal data (which are not member data) to third parties, except: 

7.2.1 In line with a clear consent from the member;

 7.2.2 To persons stipulated in laws and regulations at a reasonable request from them in accordance with the procedure and to the scope stated in such laws and regulations; 

7.2.3 To protect legal interests of Keepers Club, for example, by bringing an action in the court or other public institutions against the person who has infringed the legal interests of Keepers Club, and transferring the debts of natural persons for collecting.

8. Transfer of Personal Data

8.1 Keepers Club transfers personal data to third parties, ensuring that third parties retain personal data confidentiality and provide sufficient protection. 

8.2 Keepers Club is entitled to transfer personal data to subcontractors of Keepers Club, which allows performing its functions. 

8.3 In case under Clause 8.2, the subcontractors of Keepers Club receiving and processing personal data are deemed to be data processors for the purpose of the Regulation. They are bound under a written contract where Keepers Club demands data recipients to use the received information solely for the purposes they have been transferred and according to the applicable laws and regulations in data processing and data regulation field.

9. Access to Personal Data by Third Country Subjects

Keepers Club does not transfer personal data to third countries (countries located outside the European Union and European Economic Area).

10. Access to Personal Data and Other Rights of the Member

10.1 The member is entitled to receive statutory information regarding his or her data processing. 

10.2 The member is entitled to request from Keepers Club access to his or her personal data, and also request from Keepers Club to supplement, edit, or delete them, or to restrict their editing regarding the member, or rights to object to processing as well as rights to data portability. These rights are exercisable insofar as the data processing does not exceed the scope of obligations of Keepers Club, imposed on it under applicable laws and regulations. 10.3 The member may submit a request to exercise his or her rights: 

10.3.1 In a written form when present in person at Keepers Club, by presenting an ID document; 

10.3.2 Electronically by signing the letter with a safe digital signature and sending it to e-mail: [email protected] 

10.3.3 By sending a written letter to Keepers Club; 

10.3.4 By phone or sending an e-mail letter to Keepers Club to e-mail address: [email protected] 

10.3.5 At a request that the member has coordinated his communication with Keepers Club regarding the member data via that particular e-mail address or phone number. Such consent must be written in person on-site (by presenting ID document) or signed with a safe digital signature;

10.4 When receiving a request from the member to exercise his or her rights, Keepers Club verifies the member’s identity, evaluates the request, and performs it according to laws and regulations. 

10.5 Keepers Club provides a response to the member to an extent possible, taking into account the type of provision of answer specified by the member. 

10.6 If the answer is sent in a registered mail, it is addressed to the data subject (person whose personal data are requested). If the answer is sent electronically, it is signed with a safe digital signature (if the submitted application was signed with the safe digital signature). 

10.7 Keepers Club ensures the meeting of data processing and protection requirements under the laws and regulations and in case of objections from the member takes reasonable steps to solve the objection. However, failing to do so entitles the member to the supervision authority – State Data Inspectorate. 

10.8 The member is entitled to receive one copy of his or her personal data processed by Keepers Club free of charge. 

10.9 Receiving and/or use of information stated in Clause 10.8 hereunder may be restricted with an aim to prevent adverse effects on rights and freedoms of other persons (including employees of Keepers Club). 

10.10 Keepers Club undertakes to ensure the accuracy of personal data and relies on its members, suppliers, and other third parties delivering personal data, making sure the completeness and accuracy of personal data is in place.

11. Member’s Consent to Data Processing and Right to Withdraw It

11.1 The member gives consent to personal data processing in person while at Keepers Club or by sending an e-mail signed with a safe digital signature. 11.2 The member provides consent for personal data processing (for example, for sending commercial information) in person while at Keepers Club, by sending an e-mail signed with a safe digital signature, as well as by phone or in a regular e-mail, if Keepers Club and the member have agreed on the use of the relevant e-mail address and/or phone number for mutual communication. 11.3 The member is entitled to withdraw the given consent for data processing in the same way it was given, and in this case, any further data processing based on the previously given consent for this particular purpose will not be made. 11.4 Withdrawal of the consent does not affect data processing which was performed while the member’s consent was in force. 11.5 By withdrawing the consent, data processing may not be discontinued if such processing is based on another legal basis (for example, according to external laws and regulations or the consent signed between Keepers Club and the member).

12. Commercial Information

12.1 Communication containing commercial information about services of Keepers Club complies with the external laws and regulations or member consent. 

12.2 The member may provide written consent to receive commercial information during an on-site visit, at the website of Keepers Club, and mobile apps. 

12.3 Member’s consent to receive commercial communications is valid until revoked. The member may refuse from further reception of commercial information at any time in one of the following ways: 12.3.1 By sending an e-mail to the address [email protected]; 12.3.2 By calling +371 25257143; 12.3.3 During an on-site visit to Keepers Club; 12.4 Keepers Club discontinues sending commercial information as soon as the member’s request is processed. Consent processing time may depend on technological possibilities, potentially up to three days. 

12.5 When expressing his or her opinion in surveys and leaving the contact information (e-mail, phone), the member agrees that Keepers Club may contact him or her via the provided contact information in relation to feedback provided by the member.

13. Visiting the Website and Processing of Cookies

13.1 The website of Keepers Club may use cookies. 

13.2 Cookies are files placed by the websites on user’s computers to recognize the user and make the website experience simpler. Internet browsers can be configured to warn the visitor about the use of cookies and to allow choosing if the visitor wants to accept them. If the user does not accept cookies, he or she will still be able to use the site, however, user experience may be restricted. 

13.3 The website of Keepers Club may contain links to third parties’ websites, which have their terms of use and personal data protection, and Keepers Club is not responsible for it.

14. Other Terms and Conditions

Keepers Club is entitled to supplement the Privacy Policy, making it available to members, placing it on the website of Keepers Club.