Manager and its contact information
1. The controller of personal data processing is SIA iLearn (hereinafter - iLearn), unified registration No. 42103109986, legal address: 140, Brivibas Street, Riga, LV-1012
2. iLearn contact information on issues related to personal data processing is: email@example.com. Using this contact information or by contacting iLeran actual address (structural unit): Riga, Brīvības Street 137, LV-1012, you can ask a question about personal data processing. A request for the exercise of one's rights may be made in accordance with paragraph 24.
Purpose of the document
3. Personal data is any information about an identified or identifiable natural person. Definitions, explanations and categories of personal data are provided here.
• natural persons - customers, subscribers and other users of iLearn services (including potential, former and current), as well as third parties who receive or transfer any information to iLearn in connection with the provision of services to an individual (subscriber, customer, user) including contact persons, payers, etc.);
• Visitors to iLearn offices and other facilities, including those subject to video surveillance;
• Visitors to websites and mobile applications maintained by iLearn, and callers to the phones of the iLearn Support Center (hereinafter referred to as Customers).
5. iLearn takes care of Customers 'privacy and protection of personal data, respects Customers' right to the lawfulness of personal data processing in accordance with applicable law - Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data (Regulation) and the Personal Data Processing Act, as well as other applicable legislation in the field of privacy and data processing.
7. When performing specific types of data processing (for example, processing of cookies, etc.) for the purposes of its business activities, the environment, additional, specific rules may be set, of which the Customer is informed at the time he provides the relevant data to iLearn.
Purposes of personal data processing for the provision of one 's economic activity
8.iLearn processes personal data for the following purposes:
To provide services:
• customer identification;
• preparation, conclusion and proof of the conclusion of the contract;
• provision of services (fulfillment of contractual obligations);
• provision / maintenance of services;
• improvement of goods and services and development of services;
• promotion, advertising (marketing) and distribution of the service;
• customer service;
• for reviewing and processing applications and objections;
• customer retention, loyalty building, satisfaction analysis;
• settlement administration;
• creditworthiness assessment;
• debt recovery and recovery;
• maintenance and improvement of websites and mobile applications.
9. For business planning and analytics:
• statistics and business analytics;
• planning and accounting;
• measuring efficiency;
• data quality assurance;
• market and public opinion research;
• preparation of reports;
• conducting customer surveys as part of risk management activities.
For information, information systems and enterprise security.
For the provision of information to public administration institutions and subjects of operational activities in the cases and to the extent specified in external regulatory enactments.
For other specific purposes of which the Customer is informed at the time he provides the relevant data to iLearn.
Legal basis for personal data processing
10.iLearn processes the Client's personal data, ensuring the fulfillment of the following legal purposes:
• for concluding and executing the agreement - to enter into the agreement upon the Client's application and ensure its execution;
• to comply with regulatory enactments - to fulfill the obligation specified in iLearn binding external regulatory enactments;
• in accordance with the consent of the Customer - the data subject;
• legitimate interests - to realize the legitimate interests of iLearn arising from the obligations between iLearn and the Customer or from the concluded agreement or law;
• to safeguard the vital interests of the data subject or other natural person - to ensure the physical and property security of iLearn employees, Customers and visitors.
11.iLearn legitimate interests are:
• to carry out its economic activity in accordance with commercial law;
• to provide electronic learning environment (hereinafter e-learning environment) services;
• verify the Customer's identity before concluding the contract;
• verify the identity of the Client's representative (student's parent, guardian, etc.)
• to ensure the fulfillment of contractual obligations;
• to prevent unreasonable financial risks for its economic activity (incl., If necessary, to perform credit risk assessment before performing services and during the performance of the contract);
• save the Client's applications and submissions on the provision of services, other applications and submissions, notes on them, including those made in writing or orally, by calling the support phone, websites and the client's account;
• to negotiate with the Customer's record on the provision of services, maintenance, settlements in order to perform customer service quality control;
• to negotiate with the Customer in order to organize the fulfillment of the contractual obligations of the service;
• to negotiate with the Client a record during which an oral agreement is concluded to prove the fact of concluding the agreement;
• Analyze, develop and implement improvements to iLearn websites, websites and mobile applications.
• administer the Client's account on iLearn websites, websites and mobile applications;
• take actions to improve and maintain Customer communication;
• analyze the customer database to ensure service improvement;
• design and develop services;
• advertise services (marketing);
• to send other reports on the progress of the contract execution and events relevant for the execution of the contract, as well as to perform the Customer survey services and the experience of their use;
• to ensure the maintenance and development of the e-learning environment;
• maintain and develop the e-learning environment;
• monitor the operation of the e-learning environment to identify and prevent technical problems as well as illegal activities;
• prevent fraud
• provide corporate governance, financial and business accounting, and analytics;
• to ensure efficient business management administration processes;
• quality of service provision;
• to ensure and improve the quality of services;
• administer payments made and not made;
• apply to public administration and operational activities institutions and courts to protect their legal interests;
• to inform the public about its economic activity.
Processing of personal data
12. iLearn processes Customer Data using the capabilities of modern technology, taking into account existing privacy risks and the organizational, financial and technical resources reasonably available to iLearn.
13. iLearn may make automated decisions regarding the Customer. The customer is informed about such iLearn activities separately in accordance with regulatory enactments. The Client may object to automated decision-making in accordance with the law, however, being aware that in certain cases this may restrict the Client's right to use certain opportunities potentially available to him (for example, to receive commercial offers).
14. Automated decision-making that has legal consequences for the Customer (for example, approval or rejection of the Customer's application) may be performed only in the course of concluding or executing the agreement between iLearn and the Customer, based on the Customer's explicit consent or in external cases.
15. In order to ensure the quality and operative fulfillment of the obligations entered into with the Customer, iLearn may authorize its cooperation partners to perform certain service activities, such as performance of special service works, invoicing and the like. If, in carrying out these tasks, iLearn Partners process Customer's personal data held by iLearn, the relevant iLearn Partners shall be considered iLearn data processing operators (processors and custodians) and iLearn shall have the right to transfer to iLearn Partners the Customer's personal data necessary for these activities. as necessary to carry out these activities.
16. iLearn partners and iLearn (as processor and custodian of personal data) will ensure compliance with the requirements for the processing and protection of personal data in accordance with iLearn requirements and legislation, and will not use personal data for purposes other than fulfilling Customer's contractual obligations on iLearn behalf.
Categories of recipients of personal data
17. iLearn does not disclose to third parties the Customer's personal data or any information obtained during the provision of services and, during the term of the agreement, including information about the received iLearn e-learning environment or other services, except:
• in accordance with the Client's explicit and unambiguous consent;
• persons provided for in external regulatory enactments upon their justified request, in accordance with the procedures and to the extent specified in external regulatory enactments;
• in cases specified in external regulatory enactments, for the protection of iLearn legitimate interests, for example, by applying to a court or other state institutions against a person who has infringed these iLearn legitimate interests.
Access to personal data by third country entities
18. In some cases, in accordance with the requirements of regulatory enactments, iLearn personal data is accessed by developers or service providers located in third countries (ie countries outside the European Union and the European Economic Area) (transfer to third countries within the meaning of the Regulation) as a data controller (operator).
19. In such cases, iLearn shall ensure the procedures specified in regulatory enactments to ensure a level of processing and protection of personal data equivalent to that prescribed by the Regulation.
Duration of personal data storage
20.iLearn stores and processes the Client's personal data as long as at least one of the following criteria exists:
• only as long as the agreement concluded with the Client is valid (including, records of conversations in which an oral agreement / service application is concluded);
• the data are necessary for the purpose for which they were received;
• as long as iLearn or the Client can realize its legitimate interests in accordance with the procedures specified in external regulatory enactments (for example, to submit objections or bring or bring a lawsuit);
• as long as one of the parties has a legal obligation to store the data (for example, according to the Accounting Law, the company must keep the invoices issued for 5 (five) years, etc.);
• as long as the Customer's consent to the relevant personal data processing is valid, if there is no other legal basis for data processing.
• After the circumstances referred to in this paragraph cease, the Customer's personal data is deleted. Audit records are stored for at least one year from the date of their performance in accordance with the provisions of regulatory enactments.
• The Customer has not performed any actions on his / her customer's account within one year, the Customer's data is deleted.
• The Customer has not accurately registered his / her information or it does not correspond in accordance with the information provided by the Customer (for example, the Customer is a minor), the Customer's data is deleted within a week.
21. The record of the conversation with the Customer regarding the provision of services, maintenance, settlements based on iLearn legitimate interests shall be kept for 3 (three) months after the date of recording the conversation, and then it shall be deleted.
Access to personal data and other rights of the Customer
22. The Client has the right to receive the information specified in regulatory enactments in connection with the processing of his or her data. Most of the Customer's information is already placed in the Customer's account on iLearn websites and applications that the Customer uses to receive iLearn services and where the Customer can verify the accuracy of his data and, if necessary, manage it, including change it.
23. In accordance with regulatory enactments, the Customer also has the right to request iLearn access to its personal data, as well as to request iLearn to supplement, correct or delete them, or restrict processing in relation to the Customer, or the right to object to processing (including processing of personal data based on iLearn legitimate interests) as well as the right to data portability. This right shall be exercised in so far as the processing does not result from iLearn obligations under applicable laws and regulations which are in the public interest.
24. The Client may submit a request for the exercise of his / her rights:
• in writing in person at the actual address (department) of iLearn, presenting an identity document;
• in the form of electronic mail, signing with a secure electronic signature;
• by logging in to the Client's account on the iLearn portal.
• Upon receipt of the Customer's request for the exercise of its rights, iLearn verifies the Customer's identity, evaluates the request and executes it in accordance with regulatory enactments.
• iLearn reply is sent to the Customer by post to the contact address indicated by him in a registered letter or in the Customer's account on the iLearn portal, or depending on the method of receiving the reply specified by the Customer.
• iLearn ensures compliance with data processing and protection requirements in accordance with regulatory enactments and, in the event of a Customer's objection, takes the necessary steps to resolve the objection. However, if this fails, the Customer has the right to apply to the supervisory authority - the Data State Inspectorate.
Customer's consent to data processing and the right to withdraw it
25. The Customer may consent to the processing of personal data based on consent (eg analysis of service usage data, personalized advertising, etc.) by logging in to the Customer's account iLearn, iLearn service application forms, iLearn service portals / applications, iLearn and other Internet pages (such as newsletter subscription forms) by calling the iLearn information support line.
26. The Customer has the right to revoke the consent for data processing at any time in the same way as it was given, ie by logging in to the Customer's iLearn account, calling the iLearn information support phone, sending an e-mail to firstname.lastname@example.org and in that case further data processing based on the prior consent for the specific purpose will no longer be carried out.
27. Withdrawal of consent does not affect data processing performed at the time when the Customer's consent was valid.
28. Withdrawal of consent may not suspend the processing of data carried out in accordance with other legal purposes.
Communication with the Client
29. iLearn communicates with the Client using the contact information provided by the Client (telephone number, e-mail address, postal address, iLearn Client's account as well as using the application notifications (notifications)).
30. Communication on the fulfillment of service contractual obligations is performed by iLearn on the basis of the concluded contract (for example, coordination of service delivery or repair times, information on invoices, planned works, communication interruptions, changes in services, etc.).
31. Communication on commercial communications for iLearn and / or third party services and other communications not directly related to the provision of the agreed services (eg customer surveys) shall be performed by iLearn in accordance with external regulatory enactments or in accordance with the Customer's consent.
32. Communication, including commercial communications (marketing), can also be done by iLearn using automated calling machines.
33. The Customer may consent to the receipt of commercial communications by iLearn and / or its partners by logging in to the Customer's account on iLearn, iLearn service application forms, iLearn service portals / applications, iLearn and other websites (eg newsletter sign-up forms).
34. The consent given by the Client to receive commercial communications is valid until its revocation (also after the termination of the service agreement). The customer may at any time opt out of further commercial communications in one of the following ways:
• by making an appropriate note in your Client's iLearn account;
• by sending an e-mail to email@example.com;
• changing the settings for receiving notifications to devices;
• by using the automated option provided in the commercial communication to opt out of receiving further notifications by clicking on the opt-out link at the end of the relevant commercial communication (e-mail).
35. iLearn stops sending commercial communications as soon as the Customer's request is processed. The processing of the request depends on the technological possibilities, which can be up to seven days.
36. By expressing his / her opinion in the surveys and leaving his / her contact information (e-mail, telephone), the Customer agrees that iLearn may contact him / her in connection with the Customer's assessment using the contact information provided by the Customer.
Website visits and cookie handling
40. The examination video created by the iLearn Client has the right to retain 14 days from the moment of the examination, at the same time determining the 14-day term for contesting the examination, unless otherwise specified, which will be notified to the Client.
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Contact information of the personal data protection specialist: address: Rīga Brīvības iela 137., LV-1012, phone: +371 29000300, e-mail: firstname.lastname@example.org, Rihards Lakstīgals.