Personal Data Processing Principles

In force from May 25, 2018

Present Principles of the processing of personal data (further in the text – the Principles) describe the order in which the Home Angels SIA processes the personal data of the Client.

These Principles are applied, if the Client uses, has used or has expressed a desire to use the services provided by the Home Angels SIA or otherwise associated with the rendered by the Home Angels SIA services. Moreover, the Principles are applied in case of the relations with the Client that appeared prior to these Principles coming into effect.

1. Definitions

The Client - any natural person who uses, has used or has expressed a desire to use any services provided by the Home Angels SIA or otherwise connected with such services.

Personal data of the Client - any information (including information that is a subject to the bank secrecy and personal data), which is known to the Home Angels SIA about the Client or his/her representative.

Personal data – any information directly or indirectly related to the Client.

Processing - any action performed with the personal data (including collection, recording, storage, modification, provision of access, execution of requests, transfer, etc.).

Home Angels SIA – any legal entity or branch belonging to the Home Angels Group, which has a legal address in Latvia and acts as a manager of the personal data. The list of companies of the Home Angels SIA Group in Latvia is available on the website www.Home Angels.eu.

Home Angels is a registered in Latvia limited liability company – the Home Angels SIA.

2. General Provisions

2.1 These Principles outline whereby the Home Angels SIA carries out the processing of the personal data. More information on personal data processing might also be defined in contracts, other service-related documents and on the Home Angels website: www.Home Angels.eu

2.2 Under the applicable regulations, the Home Angels SIA ensures the confidentiality of personal data and applies appropriate technical and organizational measures to protect personal data against the unauthorized access, unlawful processing or disclosure, accidental loss, alteration or destruction.

2.3 For the processing of personal data, the Home Angels SIA may use authorized operators data. In such cases, the Home Angels SIA undertakes necessary measures to ensure the processing of personal data by such operators in accordance with the instructions of the Home Angels SIA and the applicable regulations, and requires operators to follow appropriate security measures.

2.4 The Home Angels cookie policy is available on the Home Angels website: www.Home Angels.eu.

3. Personal Data Categories

It is possible to get access to the personal data from the Client, owing to the use of the services by the Client and from the third sources, for example, from public and private registers or from the third parties. The categories of the personal data that Home Angels SIA collects and processes, primarily but not exclusively, are as follows:

Identity data, for example, name, surname, personal code, date of birth, identity document data (for example, passport copy, ID-card).
Contact information, for example, address, telephone number, e-mail, language.

Data on relationships with the legal entities, for example, data provided or received by the Client from the public registers.
Professional data, for example, education or professional career.

Data concerning reliability and study, for example, data on losses or damages caused to the Home Angels SIA or to the third parties, data allowing the Home Angels SIA to undertake due diligence measures regarding the study of the Client in connection with the prevention of money laundering and the financing of terrorism and the observance of international sanctions, including the purpose of business relations and the compliance of the Client with the status of a politically significant person.

Data received and / or created when performing statutory duties, for example, data obtained from the information requests from the investigatory agencies.
Data on the tax residence of the Client, for example, information about the country of residence, citizenship.

Data received during communication, for example, video and / or audio recordings, collected during the Client’s visits to Home Angels and other locations of the Home Angels services, when communicating with the Home Angels SIA by phone, as well as data received by e-mail, from the messages and other means of communication, for example, the data of social media channels received during the Client’s visits to the Home Angels SIA websites or when using other channels of the Home Angels SIA (for example, an internet bank and a mobile bank).

Data related to the services, for example, the performance or non-performance of contracts, operations conducted, agreements concluded and ineffective, applications submitted, requests and complaints, payment for services.

Data on habits, predilections and satisfaction, for example, activity of using services, used services, personal settings, answers at the interviews, Client’s satisfaction.

Data on participation in games and promotions, for example, points earned, awards received in games or promotions.
Data of a special category, for example, the health of the Client.

4. Objectives and Rationale for the Processing of Personal Data

Home Angels SIA carries out the processing of the personal data mainly:

4.1 For the general management of the relationship with the Client, provision and administration of the access to the products and services.
To conclude and execute contracts, for example, transactions with the Client; to ensure the relevance and correctness of the data by checking and supplementing them using external or internal sources, based on the execution of the contract or on the implementation of the precontractual measures on the request of the Client, or for the performance of a specific legal duty.

4.3 For the protection of the interests of the Client and / or Home Angels.

To protect the interests of the Client and / or Home Angels SIA and to assess the quality of the services provided by the Home Angels SIA and to provide the evidence of the commercial transactions and other commercial communications (recordings of the negotiations), based on the execution of the contract, or on the implementation of the precontractual measures on the request of the Client, or for the performance of a legal duty or with the consent of the Client, or on the basis of the legal interest of the Home Angels SIA to prevent, limit and investigate the misuse or illegal use of services and products of the Home Angels SIA or to interfere with its work; for internal training or in order to ensure the quality of services.

To guarantee the security of the Home Angels SIA and / or the Client, to protect the life and health of the Client and / or his/her representatives and other rights of the Home Angels SIA and the Client (video and / or audio recordings), based on the legitimate interests of the Home Angels SIA to protect its customers, employees, and owned by them and the Home Angels SIA assets.

4.4 For the provision of additional services, customer surveys, market analysis and statistics collection. To offer the Home Angels SIA services to the Client or to the carefully selected cooperation partners, including personal offers, based on the Client's agreement or on the legal interest of the Home Angels SIA related to the offer of the additional services.
To conduct customer surveys, market analysis and collection of statistics, to organize games and promotion actions for the Client, based on the legal interests of the Home Angels SIA to improve its services as well as the experience of using the services of the Client and to develop new products and services on the Client's consent.

4.5 To perform legal duties and verify identity

For the implementation of the applicable laws and international agreements;
to prevent, detect, investigate and report on the possible legalization of proceeds of crime, the financing of terrorism, if the Client is a subject to the financial sanctions or is a politically significant person, as well as for the identity verification, based on: the contract execution or the implementation of the precontractual measures on the request of the Client; or to perform a specific legal duty, or on the basis of the legal interest of the Home Angels SIA for the risk and the enterprise as a whole management.

4.6 To prevent unfair use of services and for proper services provision

To authorize and control the access to the digital channels and to ensure their operation, prevention of unauthorized access and unfair use of services and to ensure safety of the information, based on the execution of the contract or the implementation of the precontractual measures on the request of the Client or for the performance of a certain legal duty, or with the consent of the Client, or for the control based on the legal interest of the Home Angels SIA to provide control over authorization, access and operation of the digital services of Home Angels.

To improve technical systems, IT infrastructure, adaptation of service images in the
devices and development of the Home Angels services by testing and improving technical systems and IT infrastructure, based on the legal interests of Home Angels.

4.7 For the establishment, implementation and protection of the legal requirements

For the establishment, implementation and protection of legal requirements, based on the execution of the contract or on the performance of the precontractual measures on the request of the Client or for the performance of a certain legal duty, or based on the legal interest of the Home Angels SIA for the implementation of the legal requirements.

4.8 To execute transactions in the system of settlements

To meet commitments on the performance of the international transactions through the intermediation of credit institutions and local payments through the intermediation of the intra-state, European and international payment systems and to comply with the rules and obligations, for example, related to the payment cards and security, European and international standards and certification systems, based on the execution of the contract or the implementation of the precontractual measures on the request of the Client, or for the performance of a specific legal duty.

5. Profiling, Personalized Offers and Automated Decision-making

5.1 Profiling is an automatic personal data processing used to evaluate certain personal characteristics of the Client, for example, for analyzing or forecasting the economic situation of an individual, personal preferences, interests, place of residence.

Profiling is used to conduct analysis for Client's advice, marketing, automated decision making, for example, transaction control, to prevent fraud and it is based on the legal interests of Home Angels, legal obligations, performance of the agreement or the consent of the Client.

5.2 Home Angels SIA may process personal data to improve the Client's experience in the application of the digital services, for example, by adapting the service image in the device used and by preparing the offers appropriate for the Client.

If the Customer has not refused the direct marketing in relation to himself, the Home Angels SIA can produce personal data processing for the preparation of general and personalized offers of the Home Angels services. Such marketing might be based on the services used by the Client, on how the Client uses the services and which way the Client operates in the digital channels of Home Angels.

5.3 Home Angels, in accordance with its legal interests, when profiling based on personal offers and marketing, provides the Clients with the opportunity to choose and use convenient tools to manage the settings of their privacy.

5.4 Besides that, Home Angels may collect the statistical data about the Client, including habits, lifestyle, based on demographic and everyday data.

The statistics for creating segments / profiles can be obtained from the external sources and be combined with the internal Home Angels data.

6. Recipients of Personal Information

Personal data is transferred to other recipients, such as:

6.1 Institutions (for example, law enforcement agencies, legal executives, notaries, tax offices, supervisory institutions and financial investigation institutions).

6.2 Legal entities of the Home Angels Group.

6.4 Auditors, legal advisers, financial advisers or other authorized the Home Angels SIA data operators.

6.5 The third parties, containing registers (for example, credit registers, population registers, business registers, securities registers and other registers that contain or via which personal information of the Clients is delivered).

6.6 Collectors of debts in accordance with the cession of lawsuits, courts, extrajudicial institutions for resolving disputes, administrators of bankruptcy or insolvency.

6.10 Other persons involved into the provision of the Home Angels services, including service providers of archiving, mail, suppliers of services rendered to the Client for the services of which the Client has ordered the e-invoices.

7. Geographic Area of Processing

7.1 As a rule, personal data are processed in the European Union / European Economic Area (EU / EEA), but in some cases it can be transferred to and processed in the countries outside the EU / EEA.

7.2 The transfer and processing of the personal data outside the EU / EEA can be made, if there is a legal basis for this, for example, a legal requirement to enter into or execute a contract, or the Customer's consent has been obtained and appropriate security measures undertaken. The appropriate security measures as follows:

- an agreement has been concluded, including the standard provisions of the EU Agreement or other approved rules, the code of operation, certification, etc., that are approved in accordance with the General Data Protection Regulations;
- in a non-EU / EEA state in which the recipient is located, a sufficient level of data protection is provided, in accordance with the decision of the EU Commission;
- the recipient is certified in accordance with the Privacy Shield Data Protection rules (it is applied to the recipients in the United States of America).

7.3 Upon request of the Client, it is possible to obtain more detailed information on the transfer of the Client's personal data outside the EU / EEA.

8. Retention Period

8.1 Personal data is processed no longer than it is necessary. The period of retention can be based on the agreement with the Client, the legal interests of the Home Angels SIA or applicable legal acts (for example, laws on accounting, prevention of legalization of criminally obtained means, periods of limitation, civil law, etc.).

9. Rights of the Client as the Personal Data Subject

The Client (the personal data subject) with respect to the processing of his/her data, in accordance with applicable regulations classified as Personal Data, has the following rights:

9.1 To require correction of his/her personal data in case of their inconsistency, incompleteness or incorrectness.

9.2 To object to the processing of his/her personal data, if the use of the personal data is based on the legal interests, including profiling for the direct marketing purposes (for example, obtaining of the marketing offers or participation in the surveys).

9.3 To require to delete his/her personal data, for example, if the personal data is processed on the basis of the Client's consent. This right does not apply if the personal data that the Client requires to be deleted are also processed on the basis of another legal justification, for example, a contract or obligations arising from the relevant statutory acts.

9.4 To limit the processing of his/her personal data in accordance with the applicable regulations, for example, at a time when the Home Angels SIA evaluates whether the Client has the right to delete his/her data.

9.5 To receive information about the processing of the personal data by the Home Angels SIA and, if the data is processed, to get an access to it.

9.6 To receive his/her personal data provided by himself/herself and those processed on the basis of consent and execution of the contract in writing or in any of the most commonly used electronic formats and, if technically possible, transfer the data to other service providers (data portability).

9.7 To withdraw his/her consent for the processing of the personal data.

9.8 Do not obey the decision-making which is fully automated, including profiling, if such decision-making has legal consequences or significant effect on the Client.

This rule is not applied if a decision is necessary to enter into or execute the Contract with the Client, if the decision is authorized in accordance with the applicable statutory act, or if the Client has given his unequivocal consent.

9.9 To submit claims on the use of personal data to the State Data Protection Inspectorate (www.dvi.gov.lv), if the Client believes that the processing of personal data violates his rights and interests in accordance with the applicable regulations.

10. Contact Information

10.1 Clients can contact Home Angels SIA in connection with any questions, withdrawal of consent, requests, use of the rights of subjects and claims regarding the use of personal data.

10.2 Home Angels SIA contact information is available on the website of Home Angels: www.Home Angels.eu.

10.3 Contact information of a designated specialist on the data protection: datuaizsardziba @ Home Angels.eu

11. Action and Change of Principles

11.1 Present principles are available to the Clients on the website: www.Homeangels.eu

11.2 At any time the Home Angels SIA may unilaterally modify these Principles in accordance with the applicable statutory acts, notifying the Client of the relevant changes in the Home Angels branches, on the Home Angels website, by mail, by e-mails or otherwise (for example, in the mass media) no later than one month before the changes come into force.

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