Privacy Policy
The purpose of this Privacy Policy is to provide natural persons (data subjects) – customers of SIA “DATEKS GRUPA” (Subscribers) who purchase Dateks Gaming School training subscriptions and other services on the website www.dgschool.lv and learners(Students), for whose benefit and for whose training the Subscriber concludes a subscription agreement, information on the purposes, scope, protection, duration of processing and the data subject’s rights regarding the processing of their personal data in accordance with Regulation 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 (hereinafter referred to as the “GDPR”). Information on the website www.dgschool.lv cookies used is available at this link.
1. Who processes personal data?
The personal data controller is a limited liability company “DATEKS GRUPA”, registered in Latvia, registration No 40103229720 (hereinafter – DATEKS). Contact details of the Data Controller: legal address: 9 Zemitāna Street, Riga, LV-1012; tel. +371 67275758; +371 26117175; e-mail: dpo@dateks.lv.
2. What personal data does DATEKS process?
Categories of personal data | Description, examples |
Identification data | Name, surname, personal identification number, signature, year of birth. |
Contact | Address, phone, e-mail. |
Settlement details | Name of the credit institution or other payment institution, current account number, whether the payment was made by payment card, payment card details, billing address, country of residence, payment amount, etc. payment details specified in the bank payment order. |
Remuneration | Payment or consideration for purchased subscriptions and other transactions made on the basis of a distance contract or other transaction, incl. estimated tax payments |
Video image | Video image of a person, incl. appearance, behaviour, movements, location, time of recording, date. |
Subscription details | Subscription data for purchased subscriptions and other transactions on www.dgschool.lv, incl. the training programme and training period chosen, the date of purchase. |
Consent and communication choices | Your consent to receive marketing and/or other communications, information about subscribing to and/or unsubscribing from communications. |
Browsing data | Pages viewed, subscriptions viewed, date and time of viewing, duration of browsing, subscriptions placed in the shopping basket and/or wish list, date and time of insertion, banner ad clicks, other clicks and engagement with content, information about where users come from on the website. |
Technical data | IP address, session ID, browser used, device type, resolution. |
Registration, login and account technical/administration details | The subscriber’s www.dgschool.lv user ID, account status (active, blocked, etc.), IP address, technical details of the account login and account activity. Created or captured automatically (including through cookies or similar technologies) when a Subscriber registers, logs in or uses their www.dgschool.lv account (e.g. technical data). |
Correspondence | In correspondence with the Subscriber. |
Commitment performance data | Information on commitments, incl. the time of settlement, the exercise of the right of withdrawal provided for in laws and regulations. |
Data describing the learning process of the learner | Information about the lessons attended, information in the logbooks, Student’s performance and the content of the tasks completed. |
Data communicated by the Subscriber DATEX | Additional information about the Student that the Subscriber, at its sole discretion, provides to DATEKS when purchasing a subscription and which the Subscriber believes may be relevant for DATEKS to provide instruction to the Student. |
3. For what purposes does DATEKS process personal data?
3.1. DATEKS for financial and accounting records.
Personal data is processed:
- for billing (identification data, billing data, subscription data, remuneration);
- for banking transactions and records (identification data, billing data, subscription data, rewards);
- for keeping and maintaining accounting records (identification data, contact details, subscription data, remuneration, performance data, billing data);
- reporting to public authorities as required by laws and regulations (identification data, remuneration).
What is the legal basis for processing the above personal data?
- taking into account that financial and accounting records are strictly regulated by laws and regulations, the legal basis for the processing of these personal data is to comply with the legal obligations laid down in the applicable laws and regulations DATEX (Article 6(1)(c) GDPR), incl. keeping the accounts, reporting to the State Revenue Service;
- for the performance of a contract to which the data subject is a party or for taking measures at the request of the data subject before the conclusion of the contract (Article 6(1)(b) GDPR), including. administering payments
- DATEKS for the pursuit of legitimate interests (Article 6(1)(f) GDPR), i.e. to ensure efficient financial and business accounting.
3.2. Conclusion of a subscription agreement and fulfilment of obligations.
Personal data is processed:
- For subscription agreements, incl. concluding a distance contract (identification data, contact details, subscription data, billing data, remuneration, as well as data communicated by the Subscriber to DATEKS);
- for the purpose of exercising the right of withdrawal provided for in the laws and regulations governing consumer protection (identification data, contact details, billing data, reimbursement, subscription data).
What is the legal basis for processing the above personal data?
- the fulfilment of legal obligations imposed by laws and regulations (Article 6(1)(c) GDPR), incl. ensuring the consumer’s right of withdrawal;
- for the performance of a contract to which the data subject is a party or for taking measures at the request of the data subject before the conclusion of the contract (Article 6(1)(b) GDPR), including. conclusion of the contract and administration of payments, termination of the contract in case of exercise of the right of withdrawal;
- DATEKS for the pursuit of legitimate interests (Article 6(1)(f) GDPR), incl. providing proof of purchase of the subscription of your choice, improving the quality of service.
3.3. Providing the learning process for the Student.
Personal data is processed:
- for the implementation of the curriculum (identification data, contact data, data describing the learning process of the learner, subscription data, as well as data communicated by the Subscriber to DATEKS);
- for the issuance of a document certifying completion of the curriculum (identification data, contact details, subscription data, data describing the learner’s learning process).
What is the legal basis for processing the above personal data?
- the fulfilment of legal obligations imposed by laws and regulations (Article 6(1)(c) GDPR), incl. Proof of completion;
- for the performance of a contract to which the data subject is a party (Article 6(1)(b) GDPR), including. Implementation of the training programme chosen by the subscriber;
- DATEKS for the pursuit of legitimate interests (Article 6(1)(f) GDPR), incl. Ensuring the quality and efficiency of the learning process, improving the quality of teaching, and taking into account the interests of the Student.
3.4. DATEKS to protect your interests and manage your legal affairs.
Personal data is processed where necessary:
- referrals to law enforcement authorities and courts, including. debt collection and police referrals related to damage to property or person (identification data, contact details, video image, subscription data, billing data, performance data);
- handling applications and complaints, providing answers (identification data, contact details, subscription data, billing data, performance data, education data)
What is the legal basis for processing the above personal data?
- the fulfilment of legal obligations imposed by laws and regulations (Article 6(1)(c) GDPR), incl. providing information requested by the competent national authorities, handling consumer complaints and providing answers;
- DATEKS for the pursuit of legitimate interests (Article 6(1)(f) GDPR), incl. securing evidence, detecting and preventing criminal offences in order to protect the DATEKS and/or the interests of third parties.
3.5. sales promotions
Personal data is processed:
- for marketing campaigns and promotion of services (identification data, contact details)
- for sending commercial communications (contact details, consent and communication preferences)
What is the legal basis for processing the above personal data?
- The Subscriber has provided consent to the processing of his/her personal data (Article 6(1)(a) GDPR), i.e. to receive commercial communications, which is valid until revoked. The Subscriber shall be entitled at any time to unsubscribe from receiving further commercial communications by using the contact details of DATEKS indicated in paragraph 1 or by the means indicated in the commercial communication itself.
- for the performance of a contract to which the data subject is a party or for taking measures at the request of the data subject before the conclusion of the contract (Article 6(1)(b) GDPR);
- DATEKS for the pursuit of legitimate interests (Article 6(1)(f) GDPR), incl. promote www.dgschool.lv services, encourage sales.
3.6. for the maintenance and functionality of the www.dgschool.lv website.
Personal data is processed:
- for the creation and maintenance of the Subscriber’s profile on www.dgschool.lv (identification data, contact details, subscription data, correspondence, browsing data, billing data, performance data, consent and communication preferences, registration, login and account technical/administration data, as well as Data communicated by the Subscriber to DATEKS);
- for the administration of cookies to ensure the functionality of www.dgschool.lv, to analyse the history of visits to social networks (browsing data, technical data). For more information, see. Cookies Policy, available at www.dgschool.lv.
What is the legal basis for processing the above personal data?
- The subscriber has given consent to the processing of his/her personal data (Article 6(1)(a) GDPR);
- DATEKS for the pursuit of legitimate interests (Article 6(1)(f) GDPR), incl. providing evidence that a visitor to the DATEKS website (Subscriber) has accepted a particular category of cookies; improving the quality of services provided by the DATEKS website; promoting the sale of DATEKS services and subscriptions.
3.7. maintaining a data processing and protection system
Personal data is processed where necessary:
- to inform the subscriber about the processing of personal data (identification data, contact details) by DATEKS;
- data for incident investigation (identification data, contact details, technical data, subscription data) in the event of an incident;
- informing data subjects (identification data, contact details) should DATEKS be obliged to do so due to a data incident;
- handling of applications and complaints from data subjects (identification data, subscription data, contact data, education data, billing data, correspondence, performance data, data communicated by the Subscriber to DATEKS, browsing data, technical data, consent and communication preferences, registration, login and account technical/administration data), if received by DATEKS.
What is the legal basis for processing the above personal data?
- the fulfilment of legal obligations imposed by laws and regulations (Article 6(1)(c) GDPR), incl. providing information requested by the competent national authorities, informing data subjects and providing the information requested;
- DATEKS for the pursuit of legitimate interests (Article 6(1)(f) GDPR), incl. providing evidence that the DATEKS has taken all necessary precautions and complied with the obligation to inform; improving the security and quality of systems.
3.8. Video surveillance
Video data is processed for the purposes of the DATEX and the legitimate interests of third parties (Article 6(1)(f) GDPR), i.e. for the prevention and detection of criminal offences in relation to the protection of property.
4. Cases where the processing of personal data is provided for in laws and regulations
Where DATEKS is required to process personal data by law or contract, or as a precondition for entering into a contract, DATEKS cannot ensure the sale of subscribers and the provision of services without processing all necessary personal data.
- Who are the recipients of personal data?
- state and local authorities in cases when DATEKS provides the requested information in compliance with the obligations set out in regulatory enactments and/or legal requirements of these authorities;
- courts and law enforcement authorities when DATEKS provides personal data for the protection of its own interests or the interests of third parties, for the prevention and detection of criminal offences and other infringements;
- legal aid providers when you need them DATEKS;
- auditors and auditors carrying out financial and accounting audits and/or audits of DATEKS;
- credit institutions and payment service providers when administering settlements
- marketing service providers that receive data about individual cookies (see. For more information, see the Cookies Policy available at www.dgschool.lv);
- personal data may also be provided to other DATEKS cooperation partners if this is necessary for the performance of specific functions or tasks and if these partners provide DATEKS with appropriate guarantees in relation to the processing and protection of personal data.
The data subject shall have the right to obtain from DATEKS information on the fact of transfer of the data subject’s personal data to third parties and on the persons (natural or legal) and/or public authorities to which DATEKS has provided any information in relation to the personal data of the data subject (unless such information has been provided on the basis of a request by the subject of operational activity or another competent authority and DATEKS is expressly prohibited by law from disclosing the information).
6. Data storage
DATEKS keeps personal data for as long as DATEKS has a legal basis for keeping personal data:
- within the retention periods laid down in the laws and regulations governing financial and accounting records;
- until DATEKS or the Subscriber may exercise their legitimate interests (e.g., file objections, bring or pursue legal action, etc.) in accordance with the procedure established by external laws and regulations;
- as long as a contractual obligation exists between DATEKS and the Subscriber. For example, a Subscriber purchases subscriptions and conducts other transactions through a profile created on a website;
- video (CCTV) data is stored for 30 days. In the event of suspicion of criminal offences, data is necessary to protect the legitimate interests of DATEKS or third parties, or a request from law enforcement authorities, such data shall be stored as necessary.
7. Transmission of personal data
DATEKS does not transfer personal data to third countries or their international organisations.
8. Rights of the data subject
By using the contact details set out in paragraph 1 of this Privacy Policy, the data subject is entitled under the GDPR to request from DATEKS:
- access to the personal data of the data subject, to issue the personal data of the data subject held by DATEKS;
- rectification or erasure of personal data concerning the data subject;
- restrict (temporarily suspend) the processing of some or all of the data subject’s personal data or object to the processing of personal data;
- to stop automated processing of personal data of the data subject (automated individual decision-making with regard to the Subscriber). DATEKS does not carry out profiling;
- require portability of personal data in the cases set out in the GDPR.
9. Data subject consent
The data subject shall have the following rights in relation to the processing of personal data carried out by DATEKS, where the processing is based on the data subject’s consent:
- If the processing of personal data is based on the data subject’s consent, the data subject has the right to choose to what extent and what personal data to submit to DATEKS, as well as at any time to withdraw consent to the processing of his or her personal data in whole or in part by asking DATEKS to terminate the processing of all or a certain part of the data subject’s personal data. Withdrawal of consent shall not affect the lawfulness of processing based on consent given before the withdrawal.
- Given the need for DATEKS to unambiguously identify the data subject who withdraws consent to the processing of personal data, in whole or in part, the withdrawal, which shall include the data subject’s identification data, including. name, surname, date, as well as the extent to which the data subject’s consent to processing is withdrawn, may be submitted by the data subject in one of the following ways: 1) by sending a self-signed revocation to the registered office of DATEKS indicated in paragraph 1 of this Privacy Policy; 2) by sending a revocation signed with the customer’s secure electronic signature to the DATEKS email address specified in Section 1 of this Privacy Policy; 3) by appearing in person at the DATEKS office indicated in point 1 of the Privacy Policy and presenting an identity document; 4) by using the links provided in the commercial communication or cookie communication or other specified means of withdrawing consent.
10. Contacting DATEKS and lodging a complaint
In case of any questions concerning the processing or protection of personal data by DATEKS, the data subject may also contact DATEKS using the contact details of DATEKS indicated in Section 1 of this Privacy Policy. In case of disagreement in relation to the processing of personal data by DATEKS, the data subject is entitled to lodge a complaint with the supervisory authority – the Data State Inspectorate.
12. Changes to the Privacy Policy
DATEKS may make changes to this Privacy Policy if the amount, type or circumstances under which personal data are processed change. In such a case, DATEKS will provide the data subjects with the relevant information. This is the Privacy Policy as of: 03.04.2024.