1. Controller of personal data processing
1.1. The controller of personal data processing is SIA "FLEBOMEDIKA" (hereinafter referred to as the Clinic), registration number: 40003570396, legal address: Jaunā Mežaparka iela 4, LV-1014.
1.2. You can contact us by phone: +37167374747 or by email at: .
2. Contact information for personal data protection matters
2.1. If you have any questions regarding this notice or the processing of your personal data, you can contact us using the communication channels specified in section 1.2 or by reaching out to our data protection specialist via email at: .
3. General description of our personal data processing
3.1. This notice describes how we process the personal data of our cooperation partners and their contact persons.
3.2. This is the current version of the notice. We reserve the right to make amendments and update this notice as necessary.
3.3. The purpose of this notice is to provide you with a general overview of our personal data processing activities and purposes. However, please note that additional information regarding the processing of your personal data may also be provided in other documents (e.g., service agreements, cooperation agreements).
3.4. In addition to these provisions, you may also review the additional personal data processing notice, specifically the cookie policy, which is available on the Clinic’s websites www.maurinaklinika.lv and www.ameda.lv (hereinafter – the website) under the Cookies section.
3.5. Please note that the personal data processing provisions contained in this notice apply only to the processing of personal data of natural persons.
3.6. We recognize that personal data is your valuable asset, and we will process it in accordance with confidentiality requirements, ensuring the security of your personal data in our possession.
4. Purposes and legal basis for personal data processing
We ensure fair and lawful personal data processing by processing your personal data only for specific, predefined purposes, and based on an appropriate legal basis. We process your personal data for the following purposes:
4.1. Conclusion and execution of contracts
4.1.1. To conclude and execute certain types of contracts (e.g., for the purchase of goods or services, business agreements, cooperation agreements, supply contracts), we need to process the following personal data of cooperation partners (including sellers, service providers, suppliers): identification data (e.g., name, surname, personal identification number); contact information (e.g., email, phone number, address); payment details (e.g., bank account number, contract amount). During the conclusion and execution of a contract, we also process other types of information provided by the cooperation partner (e.g., any information included in the contract or information provided prior to contract conclusion regarding experience, completed work, and fulfilled orders).
4.1.2. For this purpose, we also need to process the following data of cooperation partners’ representatives, including contact persons and employees: identification data (e.g., name, surname); contact information (e.g., email, phone number, workplace address).
4.1.3. Documents related to contract conclusion and execution are stored as evidence in case of potential claims and to fulfill our legal obligation to retain certain types of documents.
4.1.4. The main legal bases for this data processing are:
· Processing necessary for taking steps prior to contract conclusion and for contract execution (General Data Protection Regulation (GDPR) Article 6(1)(b));
· Compliance with legal obligations (GDPR Article 6(1)(c)) – e.g., to fulfill requirements under the Accounting Law;
· Legitimate interests of the controller or a third party (GDPR Article 6(1)(f)).
4.2. Ensuring security, preventing threats to property interests, and protecting other legitimate interests of ours or third parties
4.2.1. Detection of unlawful activities
[1] The Clinic conducts video surveillance within its premises and surrounding areas to detect criminal offenses related to the safety of visitors and the controller’s property protection. Video surveillance involves processing the following personal data – appearance (image), behavior, location, and time. The data obtained through video surveillance is not used for any other purposes except for detecting unlawful activities.
[2] The main legal basis for this data processing:
- Compliance with the legitimate interests of the controller or a third party (GDPR Article 6(1)(f)).
4.2.2. Control of vehicle traffic in the parking lot
[1] The Clinic conducts video surveillance of the parking lot adjacent to the building using a video recorder that captures vehicle registration plates upon entry and exit. This processing is carried out to control the flow of vehicles in the parking lot and to enforce parking regulations.
[2] The legal basis for this data processing:
- Compliance with the legitimate interests of the controller (GDPR Article 6(1)(f)).
5. How we obtain your personal data and why you need to provide it?
5.1. We primarily obtain your personal data from you – from your provided business card, email, contract, or invoice. If you are a representative of a cooperation partner, we obtain your personal data from you or from the cooperation partner via a contract, invoice, delivery document, or email.
5.2. In certain cases, when you visit our service location, we may also obtain your personal data through video surveillance if you enter the surveillance camera’s zone.
5.3. If the collection of data is necessary for contract conclusion and execution, as well as for fulfilling legal obligations applicable to the Clinic, failure to provide such information may impede the initiation, performance, and execution of contractual obligations. If the data is not mandatory but could improve our cooperation, we will indicate that providing the data is voluntary.
6. Possible recipients of personal data
6.1. We process your personal data in accordance with applicable legal regulations and ensure that unauthorized third parties do not have access to your personal data.
6.2. If necessary, your personal data may be accessed by:
6.2.1. Our employees or directly authorized persons who require this information to perform their work duties or assigned tasks, such as accountants, employees responsible for contract execution, contact persons specified in the contract, department managers, board members, legal advisors;
6.2.2. Data processors providing services under a written agreement and only to the extent necessary, such as auditors, financial management and legal consultants, database developers/technical maintainers, and other persons related to the Clinic’s service provision;
6.2.3. Regulatory and law enforcement authorities upon justified request in cases stipulated by law.
7. Are your personal data transferred outside the European Union (EU) or European Economic Area (EEA)?
Your personal data is not transferred outside the European Union (EU) or European Economic Area (EEA).
8. Are your personal data used for automated decision-making?
Your personal data is not used for automated decision-making.
9. How is the period for storing your personal data determined?
9.1. We will store personal data related to the conclusion and execution of a contract for as long as the contract remains in force and for a certain period thereafter to comply with legal requirements regarding document retention periods. For example, the Accounting Law stipulates that supporting documents must be kept until they are necessary to establish the beginning of each economic transaction and track its progress, but not less than 5 years.
9.2. Data necessary to prove the fulfillment of obligations or to request the fulfillment of obligations by the other party will be stored in accordance with the statutory limitation periods – 3, 5, or 10 years.
9.3. Video surveillance recordings will be stored for 20 days, while vehicle registration plate recordings will be stored for 3 days if the parking rules have been followed or for 60 days if the parking rules have not been followed, payment has not been made, unless the data has been previously requested by competent state or law enforcement authorities, a criminal offense has been detected, or a data subject has submitted a request for data processing restriction. In such cases, the relevant data will not be deleted and will be stored for as long as necessary to achieve the processing purpose or to comply with the instructions of competent state or law enforcement authorities.
10. What are your rights as a data subject regarding the processing of your personal data?
10.1. In accordance with the provisions of the General Data Protection Regulation, you have the right to access your personal data held by us, request its correction, deletion, restriction of processing, object to the processing of your data, as well as the right to data portability in the cases and manner prescribed by the General Data Protection Regulation.
10.2. We respect your rights to access and control your personal data; therefore, upon receiving your request, we will respond within the time limits set by legal acts and, if possible, correct or delete your personal data accordingly.
10.3. You can obtain information about your personal data held by us or exercise other rights as a data subject in one of the following ways:
10.3.1. By submitting an appropriate application in person and identifying yourself at our registered address: Jaunā Mežaparka iela 4, Rīga, LV-1014, on working days from 9:00 AM to 6:00 PM.
10.3.2. By submitting an appropriate application by mail to our registered address: Jaunā Mežaparka iela 4, Rīga, LV-1014.
10.3.3. By submitting an appropriate application, signed with a secure electronic signature, by sending it to our email: .
10.4. Upon receiving your application, we will evaluate its content and your identification possibility, and depending on the situation, we reserve the right to request additional identification to ensure the security of your data and its disclosure to the relevant person.
10.5. Withdrawal of consent. If the processing of your personal data is based on your consent, you have the right to withdraw it at any time, and we will no longer process your personal data that we processed based on consent for the respective purpose. However, we inform you that withdrawing consent does not affect the processing of personal data that is necessary for compliance with legal requirements, is based on a contract, our legitimate interests, or other legal bases for lawful data processing established in legal acts.
11. Where can you turn for the protection of your rights?
11.1. If you have any questions or objections regarding the processing of your personal data by us, we encourage you to contact us first to resolve the situation.
11.2. If you believe that we have not been able to resolve the issue and that we have violated your rights regarding personal data protection, you have the right to file a complaint with the Data State Inspectorate. Sample applications for the Data State Inspectorate and other related information can be found on the Data State Inspectorate’s website.
Prepared by: SIA “Protectum” Data Protection Specialist S. Zīrāka
[1] 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).