Privacy Policy

Privacy policy

When processing personal data, the Controller complies with the laws and regulations in force in the Republic of Latvia, the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter– the Regulation), as well as other laws and regulations which applies accordingly.

The purpose of the Privacy Policy is to provide the data subject (hereinafter – the User) with the information about the purposes for which the Controller obtains personal data, the amounts of data and the period of data processing, data protection, as well as to inform the data subject about the rights and obligations of the data subject.

This Privacy Policy applies to any natural person whose personal data is processed by the Controller and it applies to the processing of personal data, regardless of the form in which the data subject or any other natural person has provided personal data to the Controller.

I Identity and contact details of the Controller

Identity and contact details of the Controller: CPB Real Estate Services SIA, registration number 40003945157, legal address Zaļā Street 1, Riga, LV-1010, Latvia (hereinafter “we” or “us”); e-mail: office.latvia@cpbgroup.eu, website address: www.cpbgroup.eu (hereinafter – the Website).

II Purposes of processing and legal bases

The Controller processes the User's personal data that the User browses, uses, contacts us or applies for services of the Website.

Your data is processed for the following purposes and on the following legal bases:

Request for services; User authentication (legal basis - Performance of a contract or necessary steps at the request of the User prior to entering into a contract);
Provision of information and answers to your questions (legal basis - legitimate interests of the Controller or third party);
Provision of services for which you have subscribed (e.g. newsletter subscription) (legal basis - consent of a data subject);
Anonymous statistics on the use of the Website (legal basis - consent of a data subject);
Maintenance and improvement of the Website (legal basis - legitimate interests of the Controller or third party);
Marketing communications (legal basis - legitimate interests of the Controller or third party);
Examination of complaints, suggestions and questions (legal basis - legitimate interests of the Controller or third party).

III Recipients of personal data

Users' personal data are processed by the Controller's employees and contractors who are authorized to work with personal data and are properly trained. Such persons process the User's data only for the purposes indicated above.

We do not disclose User’s personal data to third parties, except:

according to the clear and undeniable consent of User;
to persons provided for by regulatory enactments in the manner and amount established therein;
in cases provided for by regulatory enactments for the protection of legitimate interests.

The service providers that provide us with services that include the processing of Users' personal data, belong to the following categories: email marketing company, website analytics services, website hosting and maintenance.

The Controller guarantees and ensures that such third parties process the User's data in accordance with the agreement concluded between the Controller and such third party and requirements contained therein, as well as that the Controller always cooperates only with reliable partners who ensure compliance with data protection laws and regulations.

IV Data transfer outside the EU and the EEA

Some of our service providers may be located in countries outside the European Union which the European Commission has recognized as a country or territory, or one or more specific sectors as providing adequate protection. Such transfer does not require any special permission.

However, some of our service providers may be located in countries that are not recognized as providing adequate level of personal data protection as the EU. When transferring data to such service providers, we guarantee that we will take measures to ensure the protection of the personal data and rights of the Users, using legal tools approved in the relevant data protection legislation.

V Data retention period

We store Users' personal data for a limited period of time, which varies depending on the purpose of the data processing. After this period, the personal data of the Users will be permanently deleted or anonymized.

We store the received personal data until:

Data is necessary for the purpose for which it was obtained (for example, to fulfill User's request);
The User or the Controller can exercise their legitimate interests in the manner prescribed by regulatory enactments (for example, to file objections or to initiate legal proceedings);
User’s consent to the corresponding processing of personal data is valid unless there is another legal basis for the processing.

Users' personal data is stored in accordance with the following rules and criteria:

data collected in connection with the newsletter subscription: will be stored until the User unsubscribes from the newsletters;
data related to User requests to our customer service: will be stored until the User request is fulfilled.

VI Processing of personal data of Users for the purposes of communication

Type of personal data: name/surname, e-mail;

Purpose of data processing: commercial communication;

Legal basis for the processing of personal data: legitimate interests;

Personal data processing term: permanently until the person withdraws his / her consent or unsubscribes from newsletters; when processing is based on Controller’s legitimate interests - 10 years after the last purchase or until the person unsubscribes from newsletters (objects to the processing).

VII User rights

The User have the right to request from the Controller access to and rectification or erasure of personal data or restriction of processing, to object to processing as well as the right to data portability. Where the processing is based on User’s consent, User has the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise your rights please submit a written request using the Controller’s e-mail address: office.latvia@cpbgroup.eu. We will make commercially reasonable efforts to provide the User with reasonable access to any of his/her personal data we maintain within 1 month as of receipt of User’s access request.

To ensure safety and privacy protection, we will take appropriate measures to verify User’s identity before disclosing information about the requested personal data.

If the User has reason to believe that the Controller violates the rights of the User specified by law or these rules on data processing, the User has a right to submit a complaint to the supervisory authority.

VIII Protection and storage of personal data

The Controller applies various technical and organizational security measures to protect personal data of natural persons. Personal data are stored securely and are accessible to a limited number of persons–only authorized persons.

IX Final provisions

The Controller is entitled to make changes or additions to this Privacy Policy. The updated Privacy Policy will be published immediately on the Controller website www.cpbgroup.eu.

Cookie policy

“Cookie” is a small piece of data sent by the web server and stored on the user's computer.

X How we use cookie?

Our Website uses cookies to improve the quality of our services, as well as to prepare anonymous analytics and statistics on the use of the Website for marketing purposes. We use the necessary cookies, functional cookie and analytics cookies (cookies of the first and third parties (partners)) in order to:

• maintain and manage the security of the Website;

• remember whether you have consented to the use of cookies on our Website;

• summarize information on the use of the Website, which allows us to evaluate how well the Website meets the needs of Users, and make the necessary improvements;

• analyze which pages of the Website you are visiting.

Some cookies may be placed by third parties, a service provider that performs certain functions for us (for example, Facebook, Google).

XI Personal data transfer

The cookie information is not used for your personal identification. Cookies are not used for any purpose other than those described here.

We may share your information with third parties who provide us with website analytics or customer service services. These persons have the right to use your data only to the extent that it is necessary to provide us with these services.

We transfer your data to third parties only in the manner described in this Privacy Policy. We do not sell your data to third parties.

XII Analytical cookies

The Website uses analytical cookies, to summarize information on the use of the Website, to evaluate how well the Website meets the needs of Users, and make the necessary improvements and to analyze which pages of the Website you are visiting.

Some cookies may be placed by third parties - service providers that provide the Website with analytics features. By using third-party cookies, Website has no control over the information provided by the cookies and does not have access to this data. The Website only receives anonymized information.

The Website uses the following third-party cookies: Google Analytics.

To learn more about the aforementioned third-party cookies and decide whether to allow us to use them, please read the privacy or cookie policies of the respective third parties (https://policies.google.com/technologies/cookies?hl=en-US )

XIII How to control cookie?

You can control and manage cookies in your browser settings. You can delete or block all cookies that are already on your computer, but if you do so, some functions of this Website may not work as intended, and you may need to manually configure individual settings each time you visit the Website.

When User does not accept cookies for Controller’s analytics purposes, we do not process this information.

XIV Questions, applications and complaints

Users can send their questions about general data protection issues or the processing of their personal data to the Controller at: office.latvia@cpbgroup.eu .

Controller will, without undue delay and in any event within 1 month after receipt of the User's request, inform you of the action taken upon the request in accordance with the requirements of law. If necessary, this period may be extended by a further two months, taking into account the complexity and the number of requests.