This Privacy Policy tells you everything you need to know about how Digital Mind JSC and/or its affiliates, subsidiaries and newly acquired companies protect the personal data we process and control relating to you and which rights you have in relation to the processing of your personal data.
The “data controller” means the entity that will make the decisions about how your data is used and that is responsible for deciding how it holds personal information about you.
All Digital Mind entities for the purposes of compliance with data privacy laws are represented by:
Digital Mind JSC, registration No. 40003761569, legal address: 11 Sporta street, Riga, LV-1013, Latvia, privacy@digitalmind.lv.
Digital Mind attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure that when you deal with Digital Mind, your personal data are in good hands.
We process your personal data only in accordance with the applicable privacy legislation, which means that the personal information we hold about you must be:
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We collect, use, store and transfer different kinds of personal data about you depending on the situation. For more specific information on the processed data, please see the specific privacy notices provided on this website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
We do not generally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. In the limited cases where we do process such data, we do this in accordance with the applicable legislation or our legitimate interest.
We collect personal data of our employees, potential employees, clients, suppliers, business contacts, shareholders and website users. This data is collected using different methods to collect data from and about you including through direct interactions, automated technologies or publicly available sources. If the data we collect are not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used.
We will only use your personal information when the law allows us to. We will use your personal information in the following circumstances:
We may also use your personal information in the following situations, which are likely to be rare:
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at privacy@digitalmind.lv.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise and for system maintenance support and hosting of data.
We may transfer personal data to our service providers, professional advisors, public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws.
We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.
Unless you are otherwise notified, any transfers of your personal data from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses. Any other non-EEA related transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and standards.
Please contact us at privacy@digitalmind.lv, if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Under certain circumstances, by law you have the right to:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data or request that we transfer a copy of your personal information to another party, please contact us at privacy@digitalmind.lv.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us at privacy@digitalmind.lv. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making unless we have a lawful basis for doing so and we have notified you.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
Digital Mind reserves the right to amend this General Privacy notice and specific privacy notices at any time, for any reason, without notice to you, other than the posting of the amended privacy notices on this website. You must review this Privacy Notice from time to time for any amendments.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
This privacy notice aims to give you information on how Digital Mind collects and processes your personal data and tells you about your privacy rights and how the law protects you, when you:
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not generally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. In the limited cases where we do process such data, we do this in accordance with the applicable legislation. If you choose to provide us with unsolicited sensitive personal data through our websites, you are consenting to the processing of that personal information to the extent necessary and to the extent permitted by applicable legislation.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
To manage our relationship with you, including
| 1. Performance of a contract with you 2. Necessary to comply with a legal obligation 3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this website, including
| 1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
Marketing and marketing analytics, including
| 1. Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) 2. You have given consent to the processing of your personal information for one or more specific purposes. |
Administrative reasons and legal compliance
| Necessary for our legitimate interests (for the purposes of satisfying any legal, accounting, or reporting requirements) |
We will only use your personal information when the law allows us to. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at privacy@digitalmind.lv. if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You can ask us or third parties to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at privacy@digitalmind.lv at any time. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
We may use your personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have given your consent to us sending marketing communication to you, or if you (or the company you represent) have purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we disclose your personal data with any company outside the Digital Mind group of companies for marketing purposes.
We send commercial e-mails that typically include technologies (web beacons, cookies or similar) that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from us, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.
We may combine the data collected about you from publicly available sources, and from our different e-mail, website, and personal interactions with you. We combine this data to better assess your experience with Digital Mind and to perform the other activities described in our privacy notice.
When you visit our Website, we may employ cookies that contain information (such as a unique cookie ID) used to track your usage of our Website. This enables our systems to recognize your browser and tell us how, when and which pages in our Website are visited and by how many people, and also enables us to recognize a return visitor as a unique user. For more information about the cookies we use, please see our separate Cookies Policy.
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