Principles for Personal Data Processing by Elektrum Energy Efficiency Centre
Pursuant to Article 13 of Regulation (EU) 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as – Regulation), we inform you about the processing of personal data when submitting online questions, receiving advice, applying for and attending educational lessons on energy efficiency, training, guest lectures, and seminars at the Elektrum Energy Efficiency Centre (hereinafter referred to as – Energy Efficiency Centre), as well as webinars.
Controller
Public Limited Company Latvenergo, registration number: 40003032949, registered office: Pulkveža Brieža iela 12, Riga, LV-1230 (hereinafter also referred to as – Latvenergo AS, Controller or We)
Contact details of the Controller
Registered office: Pulkveža Brieža iela 12, Riga, LV-1230;
Personal data may be processed for the following purposes:
to prepare and provide an answer to your question submitted on the website administered by the Controller and in the webinar environment (hereinafter referred to as – webinars), and/or a verbal or written consultation request received from you, including in order to contact you to clarify the submitted question;
to organise energy efficiency education lessons, training, guest lectures (hereinafter jointly referred to as – event) at the Energy Efficiency Centre, including for the purposes of communication regarding an event and the organisation of a customised event programme for the specific target audience;
to organise seminars and/or webinars of the Energy Efficiency Centre, including to contact you about the seminars and webinars;
to cover educational energy efficiency lessons, training, guest lectures, seminars and webinars (hereinafter jointly referred to as – activities) organised by the Energy Efficiency Centre on the websites, mass media and social networks administered by the Controller in order to inform and educate the public about the activities, energy efficiency and operation of the Energy Efficiency Centre;
to send you news about the activities of the Energy Efficiency Centre and Elektrum products, as well as offers if you have expressed such a wish;
to prepare reports on the activities performed by the Energy Efficiency Centre in order to prove the fulfilment of the energy efficiency obligations specified in Cabinet Regulation No. 226 “Regulations Regarding the Energy Efficiency Obligation Scheme”.
Personal data that we process
If you submit a question in the online consultation tool of the website administered by the Controller, and/or a verbal or written request for a consultation, we will process the data indicated by you – name, e-mail address, telephone number and question, in order to prepare and provide an answer, and to contact you and clarify additional information related to the question, if necessary. After providing the answer, we will save your personal data in order to prove the fulfilment of the energy efficiency obligations specified in Cabinet Regulation No. 226 “Regulations Regarding the Energy Efficiency Obligation Scheme”.
If you apply for any of the events organised by us at the Energy Efficiency Centre, we will use the data you provide – name, surname, telephone number, e-mail address and company name to include you on the list of event participants and to contact you in order to clarify matters related to the event, if necessary. If your participation in the event is confirmed, we will process the information about your participation in the specific event. After the event, we will save your personal data in order to prove the fulfilment of the energy efficiency obligations specified in Cabinet Regulation No. 226 “Regulations Regarding the Energy Efficiency Obligation Scheme”.
If you apply for any of the seminars organised by us at the Energy Efficiency Centre, or webinars, we will use the data you provide – name, surname, company name, telephone number and e-mail address to include you on the list of participants and to contact you and clarify matters related to the seminar or webinar, if necessary. If you participate in a seminar or a webinar as a lecturer, we will process the data submitted by you – name, surname, telephone number and e-mail address, job description, position and experience to inform the seminar or webinar participants about the lecturer and their experience, as well as to contact you regarding matters related to the seminar or webinar.
If your participation in the seminar or webinar is confirmed, we will process the information about your participation in the specific seminar or webinar. When you connect to one of our webinars on the onlineZoom platform, we will process the data submitted by you – name, surname and company name for the purpose of preparing reports on the activities performed in order to prove the fulfilment of the energy efficiency obligations specified in Cabinet Regulation No. 226 “Regulations Regarding the Energy Efficiency Obligation Scheme”. Please be informed that your personal data specified in the webinar joining form is processed on the Zoom platform in accordance with the provisions of the Zoom Privacy Statement , Zoom and the European Union’s General Data Protection Regulation (GDPR) and the Zoom Terms of Service.
If you add a question and/or comment to a webinar organised by the Energy Efficiency Centre or Elektrumduring the webinar or later to the archive recording of the event, we will process the information you provide to prepare and provide a response to your question and/or comment.
If you have expressed a wish to receive news about the activities of the Energy Efficiency Centre, and/or Elektrumproducts and offers, we will process your e-mail address to send you the above information and/or telephone number to contact you and specify additional information related to the offer, if necessary.
During the activity, the Controller may take photographs and video recordings, processing your image and other information that can be visualised and heard on the record, name, opinion and/or company name and position if you give an interview or ask a question during the activity, as well as information about your participation in the specific activity. Relevant videos and photos may be published in the mass media and on websites administered by the Controller, such as, but not limited to, elektrum.lv, latvenergo.lv, as well as on social network profiles administered by the Controller (e.g., facebook.com, instagram.com, linkedin.com, x.com, youtube.com) and the archive records access platform, as well as stored in the Controller’s archive.
When choosing the information to be published in the mass media, on websites, social networks administered by the Controller, and the archive records access platform, the Controller always tries to ensure that the published materials do not infringe your rights and freedoms as a data subject, and the Controller respects your right to privacy. At the same time, the Controller understands that it may not be aware of all the facts and circumstances of the possible impact, so in order to ensure fair personal data processing, you have the right to contact us and object to the processing of your personal data by using the contact details of the Controller and/or Data Protection Officer indicated above.
The legal (juridical) grounds for processing
To organise our activities, including to communicate with you regarding their progress, the legal basis for the processing of your personal data is Article 6(1)(b) of the Regulation, i.e., taking action to ensure your participation in an activity according to your application.
In order to send you news about the activities of the Energy Efficiency Centre and/or Elektrumproducts, as well as offers, the legal basis for the processing of your personal data is Article 6(1)(a) of the Regulation, i.e., your consent to such processing of personal data.
In order to prepare and provide a reply to a consultation request that has been submitted in writing or verbally and/or an answer to your question/comment submitted on the website managed by the Controller and at the webinar and/or its recording, as well as to reflect the activities organised by the Energy Efficiency Centre in the mass media, on the websites and social networks, and on the archive records access platform administered by the Controller, thus providing information and education to and educating the public on energy efficiency and the operation of the Energy Efficiency Centre, the legal basis for the processing of personal data is Article 6(1)(f) of the Regulation (for compliance with the legitimate interests of the controller or a third party). Based on the legitimate interests of the Controller, we will review possible complaints about the provided service, as well as turn to law enforcement institutions in the case of a violation of legal interests. Also, pursuant to Article 6(1)(f) of the Regulation, information about the consultation request and/or question you submitted to the online consultation tool of the website administered by the Controller, and about the progress of activities and its participants, including lecturers, will be retained to keep evidence in the event of an inspection by the State Construction Control Bureau (SCCB) with a view to demonstrating compliance with the energy efficiency obligations laid down in Cabinet Regulation No. 226 “Regulations Regarding the Energy Efficiency Obligation Scheme”.
Who receives your personal data
Your personal data will be processed by the authorised employees of the Controller in accordance with the scope specified in their job responsibilities, observing the requirements of personal data protection and other laws and regulations, as well as the personal data processing requirements specified in the Controller’s internal regulations.
The information may be transferred to the Controller’s service providers and the Controller’s cooperation partners, who provide the performance of activities and organise the involvement of lecturers, law enforcement, supervisory and control institutions, courts, inspectors and auditors.
If you add a question/comment to a webinar organised by the Energy Efficiency Centre and/or Elektrum during the webinar or later to the archive recording of the relevant activity, it will be publicly available to the Controller and other viewers of the recording on the website and social media profile (e.g., facebook.com, instagram.com, linkedin.com, x.com, youtube.com) and archive records access platform managed by the Controller on which the archive recording of the relevant activity was published.
If, on the other hand, you have asked a question or made a comment during a live seminar in person or online in a webinar, you will be visible and audible to the attendees of the activity during the activity and in the archive recording of the activity posted on the website and social media profile administered by the Controller (e.g., facebook.com, instagram.com, linkedin.com, x.com, youtube.com), and the SlideShare.net. platform of the archive records access service manager.
The information on the websites, media, archive records access platform and social networks administered by the Controller will be accessible to any stakeholder, including the respective operator of the online communication solution, social networking website and/or archive records access service solution, and, consequently, personal data may be processed outside the European Union, the European Economic Area countries or countries and organisations regarding which the European Commission has not adopted a decision with regard to the adequacy of the level of data protection.
How long we keep your data for
Information about the consultation request and/or question, application for an activity submitted by you, as well as webinar joining information on the online Zoom platform will be included in the reports specified in Cabinet Regulation No. 226 “Regulations Regarding the Energy Efficiency Obligation Scheme”. The relevant reports shall be kept for a period of five years.
Personal data processed on the basis of consent will be processed until the withdrawal of consent. If you add a question/comment to a webinar organised by the Energy Efficiency Centre and/or Elektrum during the webinar or later to the archive recording of the relevant activity, the information you provide and other information identifying you that appears in the text you add will be available until you delete your question/comment.
The information published on the social networks and websites administered by the Controller, as well as the archive records access platform, will be stored until it becomes obsolete. The information stored in the internal archive on the most important historical events will be stored permanently for re-use in the preparation of publicity materials, for example, on the Controller’s historical news.
If a complaint is received or the Controller’s legal interest is breached, for example, harm has been inflicted during an on-site lessons, the relevant information may be retained until the completion of the resolution of the dispute, or, if the dispute is being resolved in court, until the date when the final court decision enters into force.
Rights of the data subject (You)
Right of access. You have the right of access to your personal data and to receive information from Latvenergo AS about the processing of your personal data. Using the contact details above, you may ask to provide information about the processing of your personal data, if the information provided in these Principles does not seem exhaustive to you.
Right to rectification. If you notice inaccuracies in your personal data, you have the right to request that Latvenergo AS corrects inaccurate personal data.
Right to erasure. You have the right to ask Latvenergo AS to delete your personal data, but we draw your attention to the fact that your request may be fulfilled if:
you withdraw your consent to process personal data, taking into account the fact that the withdrawal of consent does not affect the data processing carried out during the validity of the given consent;
personal data are no longer necessary in connection with the purposes specified in the Principles for which they were processed;
you have objected to the processing and the legitimate reasons of Latvenergo AS are not more important than your legitimate reasons or if the Personal Data is processed for direct marketing purposes;
personal data is unlawfully processed;
personal data shall be deleted in accordance with the requirements of regulatory enactments.
Please note that the right to erasure does not apply in cases where, in accordance with the laws and regulations, Latvenergo AS is obliged to process personal data or the processing is necessary for archiving, public interest or statistical purposes, as well as due to bringing an action, implementing or defending a lawful requirement.
Right to restrict the processing of data. You have the right to request Latvenergo AS to restrict the processing of your personal data if:
you believe that the data is being processed illegally or is inaccurate (the restriction will be effective while the non-contentious appeal process is in progress);
you believe that the processing is illegal but you do not wish to delete these personal data;
Latvenergo AS no longer requires your data for achieving a certain purpose, but you need it to raise, implement or defend legal claims;
you have objected to processing and as long as it is not verified that the legitimate reasons of Latvenergo AS are more important than your legitimate reasons.
Right to object to processing. You have the right to object to the processing of your personal data at any time based on the legitimate interests set out in the Principles. Latvenergo AS has the right to continue processing your personal data if Latvenergo AS indicates compelling legitimate reasons for processing that are more important than your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
The 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 you add a question/comment to a webinar organised by the Energy Efficiency Centre or Elektrumduring the webinar or later to the archive recording of the activity, you may revoke your consent to data processing by deleting the question/comment you have added. If your consent is given via the Elektrum portal, mobile application or websites, you may revoke your consent via the Elektrum portal, the application, websites or, in the case of cookies, by using the cookie management tool in the lower left corner of the website, or in the browser, as well as by clicking the unsubscribe link in a particular e-mail message accordingly, thus unsubscribing from the receipt of further commercial communications. In other cases, you can use the contact information of Latvenergo AS specified above to withdraw consent. The withdrawal of consent does not affect the data processing carried out during the validity of the given consent.
Right to portability. You have the right to receive your personal data, which you have provided to Latvenergo AS, in a structured, commonly used and machine-readable format and you have the right to ask to transmit those data to another controller if the legal basis for the processing of your personal data is your consent, pursuant to Article 6(1)(a) of the Regulation, or if these personal data are processed based on a legal relationship, pursuant to Article 6(1)(b). Please note that you can only claim portability rights in relation to the personal data you have provided to us.
Right to lodge a complaint. You have the right to lodge a complaint with Latvenergo AS, as well as with the Data State Inspectorate (Elijas iela 17, Riga; pasts@dvi.gov.lv) if you believe that Latvenergo AS has violated your rights or has not sufficiently protected your personal data. However, before contacting the Data State Inspectorate, please contact Latvenergo AS or the Data Protection Officer. Latvenergo AS takes care of your personal data protection and will provide you with the support you need.
Procedure for the submission of requests
In order to exercise all the above-mentioned rights you can use the contact information of Latvenergo AS specified in these Principles, specifying the following personal data in your request: name, surname, personal code, postal address (if you want to receive a reply in a registered letter) or e-mail address (if you want to receive a reply by e-mail), as well as additional information identifying you, for example, name, date, place of the lessons, training event, guest lecture or seminar/webinar, and information characterising your appearance.
Please submit your requests in one of the following ways specified below:
send your signed free-form application by post to: Latvenergo AS; Pulkveža Brieža iela 12, Riga, LV-1230;
submit your application in free form in person to the Energy Efficiency Centre at Jomas iela 4, Jūrmala, by presenting a personal identification document.
Additional data processing
In addition to these Principles, the Controller shall process personal data in accordance with:
Principles of Customer Personal Data Processing, which are accessible here.
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