Latviski

MRG PARTNERS GROUP COMPANY PRIVACY POLICY

1. Who will process your personal data:

The controller of your personal data (hereinafter – personal data) is the corresponding subsidiary of the MRG Partners group (hereinafter – Controller) that handles the processing of the personal data that it receives and currently processes as part of its business activities:

The Controller defines the purposes and means of the personal data processing, either independently or jointly with other subsidiaries of the group. The contact details for matters relating to the personal data processing are the phone number and e-mail address provided by each Controller.

Each of the Controllers is independently responsible for the processing of personal data for its own purposes, e.g. to perform contractual duties, for CCTV monitoring at the construction site, to perform legal obligations. The Controller may process personal data collected by another subsidiary of the group, for the same purposes, if there are legal grounds to do so.

2. The Controller processes or may process personal data for the following purposes:

2.1. Financial, accounting, and staff records: for the purpose of planning resources, keeping records on accounting, services provided, payments, tax and debt management; keeping track of goods/services received and respective payments; keeping records necessary for employment affairs and payroll; records of payments with the company.

Legal grounds for processing of this personal data: Article 6(1)(c) of 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 (hereinafter – Regulation): ‘processing is necessary for compliance with a legal obligation to which the Controller is subject’ — namely, the performance of duties and keeping of accounting records, in accordance with the laws and regulations of the Republic of Latvia, such as the Accounting Law, Law on Annual Statements and Consolidated Annual Statements, Cabinet Regulation 877 ‘Regulations on accounting records’, Labour Law, laws and regulations governing taxes and other mandatory state contributions, Civil Procedure Law. The personal data is stored for the time and in the manner prescribed by the laws and regulations of the Republic of Latvia.

2.2. Record keeping and handling of administrative and legal affairs: for the purpose of processing incoming and outgoing correspondence, document records and management of documents necessary to perform a concluded contract, to fulfil legal obligations; in cases where the following actions are necessary to uphold the legitimate interests of the Controller or third parties: to protect their rights using the services of authorised and competent authorities, to engage in business management, analysis, and planning, to ensure proper fulfilment of contractual obligations, to prevent legal risks (for example, to store personal data for a certain period in the event of a potential dispute until the dispute is resolved).

Legal grounds for processing of this personal data: Article 6(1)(c) of the Regulation: ‘processing is necessary for compliance with a legal obligation to which the Controller is subject’, namely, the provisions of the Commercial Law, Civil Law, etc. and to fulfil obligations assumed by the Controller and Article 6(1)(f) of the Regulation: ‘processing is necessary for the purposes of the legitimate interests pursued by the Controller’: the personal data is retained in accordance with the Controller’s file nomenclature, in compliance with the periods and procedure set by the laws and regulations of the Republic of Latvia. If circumstances arise that were not originally foreseen but are possible, such as judicial proceedings, the retention period for the pertinent personal data may be revised and a new retention period may be set.

2.3. Staff management: for the purpose of managing the Controller’s employee bonus and wage system, the upskilling of its staff, the recruitment process, and the establishment, maintenance, and termination of official employment.

Legal grounds for processing of this personal data: Article 6(1)(c) of the Regulation: ‘processing is necessary for compliance with a legal obligation to which the Controller is subject’, namely, the provisions of the Labour Law, Accounting Law, etc. Article 6(1)(a) of the Regulation: ‘the data subject has given consent to the processing of their personal data for one or more specific purposes’. The personal data is stored for the time and in the manner prescribed by the laws and regulations of the Republic of Latvia.

2.4. CCTV monitoring at construction sites: for the purpose of protecting the property of the Controller and third parties located at the construction site or its grounds, ensuring the safety of individuals, preventing possible offences, recording criminal offences, identifying a possible offender, as well as monitoring of the progress of construction, and of compliance with work safety and work regulations at the construction site. The data made available within this context can be used to assess the performance of the contractor or person in terms of the requirements of their contract.

Legal grounds for processing of this personal data: Article 6(1)(d): ‘processing is necessary in order to protect the vital interests of the data subject or of another natural person.’ Article 6(1)(f): ‘processing is necessary for the purposes of the legitimate interests pursued by the Controller’ - ensuring the security of property and individuals, prevention of fraud, contacting public authorities and law-enforcement entities and courts for the purpose of protecting own legitimate interests, streamlining of the provision of services, ensuring and improving of the quality of services. The conducting of CCTV monitoring at construction sites is in the general public interest as a legitimate interest of the company and thus if more important than the limitation of the data subject rights of the individual. Video surveillance recordings are retained for up to 60 days. If personal data is requested by competent state or local agencies, or if security violations are detected, then personal data will be retained for as long as necessary.

2.5. Electronic worktime accounting at construction sites; access and access control: for the purpose of recording, keeping, and storing electronic worktime data of persons employed at the construction site (employees of a contractor or subcontractor, who perform work at the construction site as part of a construction contract), for handing over the recorded data to a single electronic worktime records database, and for enabling access control at the construction site in accordance with the Law on Taxes and Fees.

The legal grounds for the processing of these data is Article 6(1)(c) of the Regulation: ‘processing is necessary to comply with a legal obligation to which the Controller is subject’, namely, the provisions of the Law on Taxes and Fees. The personal data is stored for the time and in the manner prescribed by the laws and regulations of the Republic of Latvia.

2.6. If a purpose for processing personal data arises due to unforeseen work and non-standard situations that is not mentioned in this Privacy Policy, the data subject is informed of these circumstances at the time of providing the corresponding data to the Controller. In such a case, the data subject may give or refuse to give their consent to the purpose of the personal data processing in question.

3. How we receive your personal data and why you must provide your personal data:

We mainly receive personal data directly from our clients, employees, and business partners, as part of concluding and performing a contract, in the form of identity documents, correspondence, video surveillance recordings, website cookies, etc. In an indirect manner, from subcontractors and clients, we receive, process, and may transfer to third parties personal data about persons employed at our construction sites or visitors at our construction sites as part of the electronic worktime system, subject to the laws and regulations of the Republic of Latvia.

Providing and receiving this information is necessary for us to provide an appropriate and high-quality service, and to fulfil our legal obligations under applicable law. In certain cases, failure to receive information may make it difficult or impossible to provide services.

The Controller does not disclose personal data or any information obtained as part of the provision of the services and the Contract to third parties, unless:

The Controller may transfer personal data to its business partners for certain activities, such as the provision of security services, website maintenance. Personal data are transferred in the smallest amount possible and only for the performance of the specific task for which there is a legitimate purpose and legal grounds.

The Controller does not transfer personal data to third countries (i.e. countries outside the European Union and the European Economic Area). In the event that a situation arises that requires the transfer of personal data to a third country, the Controller ensures that the safety guarantees and legal grounds for the transfer of personal data are obtained as required by the laws and regulations of the Republic of Latvia.

Your personal data will not be used for automated decision making.

4. The right to access own personal data:

A person may receive information pertaining to the processing of their personal data that is specified in the laws and regulations of the Republic of Latvia in order to verify the accuracy of this data, and to correct such data.

Anyone is entitled to request access to their personal data held by the Controller, to request the Controller to expand, correct, erase such data, to restrict access to it or to object to the processing of the personal data, unless the duty to process the data is imposed on the Controller by the laws and regulations of the Republic of Latvia or if the personal data processing takes place in the interest of the public.

A request to exercise one’s rights can be submitted in the form of:

The Controller sends their reply to the person:

Whenever the Controller receives and responds to a person’s request for access to their personal data, the Controller verifies the identity of the person and asks them to provide proof of identity.

5. How a person consents to data processing and revokes such consent:

A person can give their consent to the processing of personal data in writing, verbally, or through specific informed and uncoerced actions. A person is entitled to withdraw their consent to data processing at any time, in the same way as the consent was given, or by the Controller of the data via e-mail. In such a case, no further processing based on the consent previously given for the purpose in question will take place. The revocation of consent does not affect the data processing carried out when the consent was still in effect.

The revocation of consent does not terminate the personal data processing that is carried out on the basis of the Regulation and other legal grounds for processing of necessary personal data set in the laws and regulations of the Republic of Latvia.

6. Miscellaneous:

This Privacy Policy is binding to all of the Controller’s current or former business partners or clients, current or former employees, management board members, shareholders, authorised representatives, contact persons, or any third party.

The Controller is entitled to amend this Privacy Policy. The current version of this Privacy Policy is available on the Controller’s website.

This Privacy Policy is valid for an indefinite period.


Effective since 01.08.2024. Version:01