- Personal Data– any information related to an identified or identifiable individual.
- Data Subject– identified or identifiable natural person (hereinafter – Customer).
- Profiling – automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person.
- Controller– SIA «STUDIO FREESTYLE».
- Processor– a natural or legal person, which processes personal data on behalf of the controller.
- Third Party– a natural or legal person, public authority, agency or body other than the data subject, controller, processor or persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- Consent of the Data Subject (Customer)– a freely given, specific, informed and unambiguous indication of the Customer by which he or she, by a statement or by a clear affirmative action, signifies that the Customer consents to the processing of his or her personal data.
- Cookies– text files stored on the device used by the user in order to personalise the usability of the website of SIA «STUDIO FREESTYLE» for each specific user of the website.
- General Provisions
1.1. SIA «STUDIO FREESTYLE» is committed to protecting and respecting your privacy. We use our best efforts to ensure that the processing of person data carried out by us corresponds to 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).
1.2. The Controller of your personal data is SIA «STUDIO FREESTYLE», unified registration number: 40003727145, registered address: Ierēdņū 2-19, Rīga, LV-1013; tel. No.: +371 29258686.
1.3. The Processors of your personal data shall be the legal persons which process personal data on behalf of and in accordance with the instructions of SIA «STUDIO FREESTYLE» and who are committed to complying with the requirements of the laws and regulations in the field of data processing.
1.4. When carrying out the processing of Personal Data, the Controller:
1.4.1. shall ensure the lawfulness and fairness of the processing of personal data;
1.4.2. shall observe the rights of the Customer;
1.4.3. the Customer shall be provided with transparent information about the collection, use, consultation or other processing of their Personal Data and the extent to which Personal Data are or will be processed, specifying the specific purposes of the processing;
1.4.4. shall ensure that Personal Data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. The Controller shall only process such data and to such extent that corresponds to the economic operation of the Controller in order to ensure the provision of services/selling of goods;
1.4.5. shall ensure that Personal Data are not stored for longer than necessary, i.e., while the contract concluded with the Customer is valid, while the Controller or the Customer can exercise their legitimate interests in accordance with the procedure established by external laws and regulations, while a legal obligation to store the data exists for either of the parties, while the Customer’s consent to the respective processing of personal data is valid, unless there is another lawful basis for processing the data. After the retention period has expired, Personal Data shall be permanently deleted;
1.4.6. shall ensure that Personal Data is accurate, and shall ensure that inaccurate Personal Data is rectified or erased;
1.4.7. shall ensure that Personal Data is processed in a manner that ensures appropriate security and confidentiality of Personal Data, including by preventing unauthorised access to or use of Personal Data and unauthorised access to systems and equipment used for processing;
1.4.8. shall ensure that Personal Data is not transferred without secure and adequate protection.
- Legal Bases for Processing Personal Data
2.1. Your personal data shall be processed on the following legal bases:
- Article 6(1)(a) of the General Data Protection Regulation – when your consent has been obtained;
- Article 6(1)(b) of the General Data Protection Regulation – to ensure the performance of a contract;
- Article 6(1)(c) of the General Data Protection Regulation – to ensure compliance with a legal obligation;
- Article 6(1)(f) of the General Data Protection Regulation – for the protection of our legitimate interests or the legitimate interests of Third Parties.
2.2. By choosing not to provide Personal Data in any part or by withdrawing consent in whole or in any part thereof (in relation to specific data provided), SIA «STUDIO FREESTYLE» will not be able to provide the Customer with the services for which the relevant Personal Data is necessary.
- Personal Data and Purposes of Processing Thereof
3.1. The Controller shall carry out the processing of Personal Data for the following purposes:
3.1.1. identification of the Customer;
3.1.2. preparation and conclusion of a contract;
3.1.3. supply of goods and provision of services (for the performance of contractual obligations);
3.1.4. advertising and distribution of goods or commercial purposes;
3.1.5. Customer service;
3.1.6. creating and managing a Customer profile;
3.1.7. review and processing of objections;
3.1.8. administration of payments;
3.1.9. improvement of the operation of the website;
3.1.10. statistics and market research;
3.1.11. ensuring security.
3.2. The Controller shall carry out the processing of the following Personal Data:
3.2.1. for the processing of registration data – name, surname, e-mail, password;
3.2.2. for the processing of delivery data – name, surname, e-mail, mobile phone, address, manner of delivery, manner of payment, payment information;
3.2.3. cookies – the Customer’s browsing history and behaviour on the website of the Controller;
3.2.4. for the processing of accounting data – order history, payment information, delivery information;
3.2.5. for marketing information – name, surname, telephone number, e-mail address, device identification number;
3.2.6. for claim rights – name, surname, contact details, order and delivery information.
3.3. The processing of Personal Data for commercial purposes shall only be carried out if a freely given, specific, informed and unambiguous indication of the Customer has been obtained that the Customer consents to such activities. The Customer may object to receiving commercial communications in accordance with the laws and regulations, by not giving his or her consent to the receipt of commercial communications (see Section 6 of the Terms and Conditions for more information on commercial communications).
3.4. The processing of Personal Data may be carried out in an automated manner, including by carrying out the profiling of the Customer, in order to provide new, specific, individual offers of the Controller to a particular Customer, taking into account the information obtained and automatically collected by the Controller from the Personal Data provided by the Customer and previous purchases on the Controller’s website, if the Customer has consented to this.
3.5. The Controller may carry out automated decision-making with respect to the Customer if a freely given, specific, informed and unambiguous indication of the Customer has been obtained that the Customer consents to such activities. The Customer may object to automated decision-making in accordance with the legal acts, by not giving his or her consent to the automated processing of Personal Data.
3.6. The Controller shall carry out automated decision-making, for example, to prepare and post commercial communications (pop-up banners) on the website to advertise the goods available on the website and to help Customers make their choice from the range of goods offered, including based on the information about favourite products posted in the commercial communications (pop-up banners). By consenting to the automated processing of Personal Data for this purpose, the Customer agrees that the Controller will use information about the goods purchased by a person on the website by posting commercial communications (pop-up banners) on the website containing the following data: information about the purchased product, an image of the product from the website and anonymised information about the person who has purchased a particular product, specifying in the pop-up banner, for example: “A customer from Riga has just purchased …(information about the product according to the above mentioned)”.
3.7. The Controller shall carry out automated decision-making to send the Customer a reminder about the products that have been added to the shopping cart in the Customer’s profile on the website.
3.8. The Controller shall carry out automated decision-making to ask the Customer to provide feedback on the product, which is included in the statistics on the evaluation of the product without information identifying the Customer.
3.7. Opting out of receiving commercial communications shall not create any legal consequences for the Customer and shall not prejudice the rights of the Customer to purchase goods and services on the website.
3.8. Opting out of automated data processing for the purposes referred to in the Terms and Conditions shall not create any legal consequences for the Customer and shall not prejudice the rights of the Customer to purchase goods and services on the website.
- What Personal Data We Transfer to Third Parties
4.1. We may transfer the Personal Data of the Customer to the following categories of data recipients:
4.1.1. The payment service providers of the Controller may process the financial operations related to the purchase of goods on the internet website. We disclose the financial operation data of the Customer to the payment service providers of the Controller to the extent necessary for the performance of payment operation, refunds and handling of complaints.
4.1.2. For the purposes of the provision of specific services we may transfer your Personal Data to other service providers, such as website hosting service providers, courier services, providers of server services and services for the technical maintenance thereof, email service providers, accounting service providers.
4.2. We may transfer the Personal Data of the Customer not only in the cases specified herein above, but also when performing our legal obligations and, if it becomes necessary, to protect the interests of the Customer or other persons, for example, when addressing the court or public authorities.
4.3. We may transfer the Personal Data of the Customer to public authorities in accordance with the laws and regulations in effect in the Republic of Latvia, under the procedure and to the extent prescribed by the laws and regulations.
4.4. For direct marketing purposes, we may transfer Personal Data to our partners providing marketing services to us with the consent of the Customer.
4.5. We will only attract such service providers who have put appropriate technical and organisational measures in place that would provide for an adequate level of security of data processing, which ensures the procedures set out in the laws and regulations – a level of processing and protection of personal data equivalent to the requirements set out in the General Data Protection Regulation.
4.6. In certain cases, in accordance with the requirements of the laws and regulations, Personal Data may be accessed by the cooperation partners of the Controller located in third countries (i.e., countries outside the European Union and the European Economic Area): developers or service providers in the capacity of a data processor.
4.7. in the cases referred to in Clause 4.6, the cooperation partners engaged by the Controller in the third countries shall ensure a level of data protection equivalent to the level of data protection ensured by the Controller.
- Commercial Communications
6.1. Commercial communication shall mean any form of communication in electronic form designed to advertise, directly or indirectly, the goods or services or to advertise the image of a company, organisation or person carrying out commercial activity, economic operation or regulated professional activity. Information allowing direct access to general information about the service provider and the activities thereof (domain name or electronic-mail address) shall not be regarded as commercial communication.
6.2. The Controller may use Personal Data to provide information about the services, promotional campaigns and other activities offered at www.tribal.lv.
6.3. When using www.tribal.lv, you can opt in (give your consent) to receive commercial communications.
6.4. The Customer’s consent to receive commercial communications is effective until revoked (even after the termination of the Service Agreement). The Customer may opt out of receiving further commercial communications at any time in any of the following ways:
6.4.1. by making a corresponding note to that effect in their user profile at www.tribal.lv;
6.4.2. by sending an e-mail to the address firstname.lastname@example.org;
6.4.3. on site at the outlet;
6.4.4. by using the automated option provided for in the commercial communication to opt out of receiving further communications by clicking on the opt-out link at the end of the relevant commercial communication (email).
6.5. SIA «STUDIO FREESTYLE» shall stop sending commercial communications as soon as the Customer’s request is processed. Request processing depends on technological capabilities; processing can take up to three days.
- Your Rights
7.1. the right to receive information about the processing of Personal Data;
7.2. the right to review your Personal Data that we store;
7.3. the right to request the rectification of your Personal Data that we hold (most of which you can rectify by logging in to your account);
7.4. the right to ask us to erase your Personal Data (“right to be forgotten”);
7.5. the right to restrict the processing of your Personal Data;
7.6. the right to object to the processing of your Personal Data;
7.7. the right to object to your Personal Data being processed for direct marketing purposes;
7.8. the right to object to the automated processing of Personal Data;
7.9. the right to data portability;
7.10. the right to withdraw consent to the processing of your Personal Data;
7.11. the right to lodge a complaint to the supervisory authority;
7.12. If you wish to exercise your rights, or if you have any questions about the processing of your Personal Data or the exercise of your rights, please contact us by email.
7.13. If you believe that we violate Personal Data protection legislation by processing your Personal Data, you have the right to lodge a complaint with the Data State Inspectorate at Elijas iela 17, Riga, LV-1050, https://www.dvi.gov.lv/lv/. In all cases, please contact us before lodging a complaint so that we can jointly find a suitable solution.
8.2. The revocation of consent does not affect the data processing performed during the period of the Customer’s consent.
8.3. Withdrawal of the consent cannot terminate the processing of data that is carried out based on other legal bases.
8.4. Upon receiving the Customer’s request for exercising his or her rights, the Controller shall verify the identity of the Customer, evaluate the request and execute it in accordance with the laws and regulations.
8.5. The Controller shall send a reply to the Customer by post to the contact address provided by him or her by registered mail, an electronically signed reply by e-mail at the Customer’s request, taking into account the method of receipt of the reply indicated by the Customer to the extent possible.
8.6. The Controller shall ensure the fulfilment of data processing and protection requirements in accordance with the regulatory enactments and, in the case of the Customer’s objections, shall takes reasonable steps to resolve the objection. However, if this fails, the Customer has the right to turn to the supervisory authority.
- Contact Us
9.1. To improve the quality of our services, we are always willing to receive feedback from our Customers and are ready to answer any questions that may arise.