Privacy Policy

Last updated: March 1, 2024. This Privacy Policy (“Privacy Policy”) explains how “Digitālās Ekonomikas Attīstības Centrs” Ltd, registration number 40003455216, legal and actual address: Čuibes street 17, Riga LV-1063 (hereinafter referred to as the “DEAC” or “Company”) processes personal data of a Customer, which DEAC may collect, or Customer may provide to DEAC when visiting website or creating an account at DEAC customer digital platform myDEAC or using online services, and other available services (collectively “Services”). DEAC invites any Customer to review this Privacy Policy carefully.

The company DEAC, “Digitālās Ekonomikas Attīstības Centrs” Ltd., registration number 40003455216, legal and actual address: Čuibes Street 17, Riga LV-1063. DEAC (“us”, “we”, or “our”) operates my.deac.eu (the “myDEAC”) digital platform. This page informs customers of DEAC’s policies regarding the collection, use, and disclosure of personal information DEAC receives from users of myDEAC. By using myDEAC, the customer agrees to the collection and use of information by this policy.

1. GENERAL INFORMATION

1.1. This Privacy Policy outlines the procedures by which the Company handles personal data and is intended for use when working with personal data. This Policy aims to give an overview and details about the handling of personal data in DEAC. The stated policy is to inform data subjects and DEAC customers about the data processing practices used by DEAC.

1.2. The purpose of developing and publishing the Privacy Policy is to explain what personal data DEAC collects and uses.

1.3. DEAC ensures the confidentiality of personal data in its work and carries out appropriate technical and organizational measures to protect personal data from unauthorized access, illegal processing or disclosure, accidental loss, alteration, or destruction.

1.4. This Policy is applicable in all situations when the Customer is subject to the processing of personal data that the Company performs in its capacity as a manager for the handling of personal data, whether the Customer is using or wants to use DEAC or myDEAC services.

1.5. DEAC processes personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (the General Data Protection Regulation) (“GDPR”) and other legal acts governing personal data protection (together – Personal Data Protection Laws) and this Privacy Policy. The Processing of personal data by DEAC occurs in the territory of the European Union / European Economic Area. The personal information of customers and others is not passed on to or processed in any country outside of the European Union or the European Economic Area.

2. GENERAL INFORMATION

2.1. Company securely stores customers data in DEAC data center located in the European Union. DEAC data centers are equipped with high security technologies and are ISO 27001:2013 compliant that proves high information security management and protection standards.

2.2. Company will keep customers Personal Information for as long as it is necessary to achieve the objectives of data processing and to provide data subject with information and services. Once this time period has expired, customers data will be deleted from databases.

3. RIGHTS OF THE CUSTOMER AS THE DATA SUBJECT

3.1. The Customer has the following rights with respect to the processing of his personal data in accordance with the provisions of the Regulations:

3.1.1. Ask to correct the personal data if it is inappropriate, incomplete or incorrect.

3.1.2. To request the removal of personal data if personal data is processed on the basis of consent, and the Customer withdrew his consent. This right is invalid if the personal data whose correction is requested are also processed on the basis of another legal basis, such as legitimate interests or obligations arising from relevant normative acts;

3.1.3. Receive information about whether the Company processes the personal data of the Customer and, if they are processed, also access it.

3.1.4. Obtain the given personal data processed on the basis of consent in written format.

3.1.5. Restore Customers consent to the processing of personal data.

3.1.6. Complain about the use of the personal data to the State Data Inspectorate (www.dvi.gov.lv), if the Customer believes that his personal data is being processed in violation of the rights and interests of users.

4. ACCOUNT CREATION ON myDEAC

4.1. Customer has the choice to register in myDEAC to be able to use the myDEAC digital platform and buy services (my.deac.eu). Company shall use the data Customer enters only for the purpose of using the respective offer or service that customer has registered for. The required information Company requests at the time of registration must be entered in full otherwise registration is not possible to finish.

4.2. To notify customer of any important changes to the scope of DEAC portfolio or in the event of technical modifications, DEAC shall use the email address provided during the registration process.

4.3. By signing up, the customer agrees to receive various types of send-outs from DEAC and can unsubscribe from them at any time.

4.4. DEAC shall process the data entered during the registration process on the basis of customers consent. Customer has the right to revoke at any time any consent that has already been given to DEAC. To do so, customer needs to send an informal notification via email on [email protected]. This shall be without prejudice to the lawfulness of any data collection that occurred prior to customers revocation.

4.5. The data recorded during the registration process shall be stored by DEAC as long as customer is registered on myDEAC digital platform. Subsequently, such data shall be deleted. This shall be without prejudice to mandatory statutory retention obligations.

4.6. When customer creates account in myDEAC and agree to our Privacy Policy, as well as creating workspace later on, Company will collect the information needed for using offered Services:

4.6.1. Customers name and surname

4.6.2. Contact information (telephone number, e-mail address, physical address)

4.7. myDEAC also uses additional third-party tracking technologies and cookies. DEAC, like other websites, collects certain information automatically and stores it in log files. In addition, when customer uses Services, DEAC may gather certain information automatically from customers devices. That information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, landing page, and referring URL are examples of this information. When customer accesses DEAC’s Services, a cookie may be placed on customers computer or device to collect this information. More information about cookie collection options can be found in the myDEAC Cookie Policy.

4.7.1. Website visitors can opt out of data gathering at any time in any way convenient for them.

4.8. Company will process the received information based on the contractual arrangement concluded between customer and DEAC for the use of Services as well as company’s legitimate interests to protect the DEAC’s legal rights and prevent fraud and/or criminal activities.

5. USE OF SERVICES IN myDEAC

5.1. DEAC may collect certain data when customer uses Services in myDEAC to facilitate and monitor the use of Services.

6. PROCESSING OF PAYMENTS

6.1. To comply with DEAC’s legal requirements, for example, for accounting, anti-money laundering, payment processing and maintaining other payment-related documentation, DEAC processes customers data related to payments and fulfillment of customers financial obligations towards Company. For this purpose DEAC will process the following data:

6.1.1. Customers name and surname

6.1.2. Contact information (phone number, e-mail address, physical address)

6.1.3. Payment card information (card type, card number, validity period, CVC code),

6.1.4. Information on the payments made to company, and bank account details.

6.2. DEAC will process this information based on the contractual Terms of Service (“ TOS”) concluded between customer and myDEAC for the use of DEAC Services and to comply with legal obligations applicable to DEAC.

6.3. Customer may transfer funds to the myDEAC only from a bank account or bank card, which is registered on customers name as a natural person or on legal person’s name. myDEAC through Stripe supports several card brands, they are: Mastercard and Visa cards, American Express, China UnionPay (CUP) Discover & Diners, Japan Credit Bureau (JCB). The DEAC shall have the right to request documents, which confirm customers identity tied to the bank account for compliance purposes.

7. ADDITIONAL FEATURES

7.1. DEAC may add additional features to enhance the user experience when using services in myDEAC at no additional charge. However, these free features may be withdrawn without further notice.

7.2. DEAC is able to change the pricing policy for services and/or any additional fees by notifying the customer 30 days in advance. Any notifications will be available for registered customers in myDEAC.

8. COMMUNICATION BETWEEN CUSTOMER AND DEAC

8.1. To communicate with customer, provide customer service, consultations, inform about updates of DEAC’s TOS agreement and prices, newsletters, services updates and/or reminders, resolve any issues in relation to our Service and other information, Company may process customers data that it already has and the data customer provides during communication. If customer contacts DEAC’s customer service by phone, DEAC will record the call to be able to fully process request and monitor the quality of customer service. For this purpose DEAC will process:

8.1.1. Customers name and surname,

8.1.2. Customers contact details (phone number, e-mail address),

8.1.3. Customer voice recording, if he has contacted DEAC by telephone,

8.1.4. Any other information, which customer has provided during the communication.

8.2. Company will process this data based on legitimate interests to provide customer with quality service and to solve any related problems as well as protect Companys interests in case of any disputes between parties.

8.3. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

8.4. The provided mobile phone number might be used for direct communication:

8.4.1. to be contacted by DEAC representatives to validate customers accounts,

8.4.2. to be contacted by DEAC representatives for service improvement purposes.

9. TERMINATION

9.1. Customer is free to stop using DEAC Services at any time. Company reserves the right to suspend or terminate customers access to the Services with notice if: customer is in breach of these Privacy Policy terms, use of the Services would cause a real risk of harm or loss to company or other users, or customer doesn’t have an amount for charging fees from myDEAC account and haven’t refilled account for 2 weeks.

9.2. DEAC will provide customer with reasonable advance notice via the email address associated with account to remedy the activity that prompted DEAC to contact customer and give the opportunity to export customers data from DEAC infrastructure. If after such notice customer fails to take the steps company asks, DEAC will terminate or suspend customers access to the Services.

9.3. DEAC won’t provide notice or an opportunity to export customers data before termination or suspension of access to the Services where:

9.3.1. Customer is in material breach of these Privacy Policy terms

9.3.2. Doing so would cause company legal liability or compromise ability to provide the Services to other users, or DEAC is prohibited from doing so by law.

9.3.3. Validity of the Policy and its Amendments

9.4. These Terms will be governed by Latvian Republic law.

10. MODIFICATIONS

10.1. DEAC may revise these Terms from time to time to better reflect:

10.1.1. Changes to the law

10.1.2. New regulatory requirements,

10.1.3. Changes in the cost of services, or

10.1.4. Improvements or enhancements made to our Services.

10.2. This Privacy Policy is available on the DEAC website at my.deac.eu.

10.3. This Privacy Policy is effective as of 1st September of 2020 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this Site.

10.4. DEAC reserves the right to update or change our Privacy Policy at any time and customer should check this Privacy Policy periodically. Customers continued use in myDEAC after DEAC posts any modifications to the Privacy Policy on this Site will constitute customers acknowledgment of the modifications and his consent to abide by and be bound by the modified Privacy Policy.

10.5. If DEAC makes significant changes to this Privacy Policy, the company will notify the customer by email using the contact information provided by the customer.

11. CONTACT US INFORMATION

If customer has any questions about this Privacy Policy, please contact DEAC by email to: [email protected] or [email protected].