Privacy Policy
INTRODUCTION
To ensure better customer service, SOL Baltics OÜ (“SOL”) processes the personal data of its customers in accordance with the principles set out in this Privacy Policy (“Privacy Policy”) and the applicable law on the processing of personal data.
The purpose of the Privacy Policy is to explain what personal data SOL collects about its customers and for what purposes, and what rights do SOL customers have in relation to SOL’s processing of their personal data. The Privacy Policy does not address or protect the processing of anonymous data or data of legal entities.
PROCESSORS OF PERSONAL DATA
Data Controller
The “data controller” is a legal entity that determines the purposes and means of the processing of personal data.
Data Controller: SOL Baltics OÜ Latvijas filiāle
Company registration code: 40103933760
Address: Raiņa iela 75 – 59, Jūrmala, LV-2011, Latvija
Contact: +371 6750 6404, privacy@sol.lv
Authorized Processors of Personal Data
In the course of providing its services, SOL may process your personal data in relation to third parties and transfer your personal data to them (e.g., in the course of providing courier services). An “authorized processor” of personal data is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller (SOL). SOL will not disclose personal data to third parties unless required by law, necessary for the performance of a contract, or with the data subject’s consent.
LOYALTY PROGRAMME
For the purposes of this Privacy Policy, “loyalty programme” refers to SOL’s loyalty programme in Estonia, and a “loyalty customer” refers to an individual participating in the programme. SOL Loyalty Customers have the opportunity to receive loyalty discounts or offers on various SOL services through the Loyalty Programme. Registration as a loyalty customer is completed by submitting an application on SOL’s website (https://www.pesumaja.ee/registreeri-pusikliendiks/) or in person at SOL’s laundries.
SOL processes the personal data of loyalty customers participating in the loyalty programme in an aggregated loyalty register for the purpose of identifying the loyalty customer based on an ID card and offering loyalty services under preferential conditions.
The data processed in the loyalty register consists of personal data collected via the loyalty registration form or subsequently updated by the customer. Purchases registered by a loyalty customer will also be recorded in the loyalty register to allow for more precise targeting of direct marketing. Purchases are recorded by registering an ID card at the time of purchase.
The categories of personal data processed by SOL are outlined in this Privacy Policy. For loyalty customers, as data subjects, the rights set out in this Privacy Policy apply.
PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA
SOL will process your personal data in accordance with the principles set out in this Privacy Policy:
– **Transparency** – SOL will process your personal data in a fair and transparent manner and only where permitted by law.
– **Purpose limitation** – SOL will collect your personal data for specified, explicit, and legitimate purposes. We will not process your personal data in a way that is incompatible with the original purposes unless legally justified or with your consent.
– **Data minimisation** – SOL will ensure that the personal data processed is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.
– **Accuracy** – SOL will make every effort to ensure that your personal data is accurate and up to date, correcting or deleting inaccurate data without undue delay.
– **Storage limitation** – SOL will retain your personal data only for as long as necessary for its intended purposes, in compliance with applicable laws, contracts, or legal obligations.
– **Security** – SOL processes your personal data securely to protect against unauthorised or unlawful processing.
– **Data protection by design and by default** – SOL considers the need to protect personal data when developing, selecting, and using applications, services, and products that involve the processing of personal data.
SOL keeps all personal data confidential and protects customers’ personal data from unauthorised access by implementing effective IT, technical, and organisational security measures.
DATA SUBJECT RIGHTS
You have the right to request access to your personal data processed by SOL.
– If you notice that your personal data is outdated, incorrect, or incomplete, you can contact SOL to update it.
– You have the right to request the deletion of your personal data. SOL will delete your data unless it has a legal basis to continue processing it.
– You have the right to object to the processing of your personal data. If you object, SOL may only retain existing data but must cease further processing.
– You have the right to request the transfer of your personal data from SOL to another data controller, where technically feasible.
– You have the right to object at any time to the processing of your personal data. SOL will stop processing unless it has compelling legitimate grounds to continue.
– If you believe that the processing of your personal data does not comply with legal requirements, you may lodge a complaint with Estonia’s Data Protection Inspectorate.
– If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time by informing SOL.
To exercise your rights, contact SOL by email at privacy@sol.lv.
PURPOSES FOR WHICH PERSONAL DATA IS PROCESSED
SOL processes personal data for the following purposes:
– Sales activities and related services;
– Marketing and direct marketing for loyalty discounts and campaigns;
– Data analysis for marketing purposes;
– Billing and customer correspondence.
CATEGORIES OF PERSONAL DATA PROCESSED
The personal data processed by SOL includes:
– Name and surname;
– Personal identification number;
– Telephone number, email, and address (for courier services);
– Data related to customer purchases;
– Any other data necessary for the performance of a contract, provision of a service, or voluntarily provided by the customer.
LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
SOL processes personal data on the following legal bases:
Contract
Processing is necessary for the performance of a contract, such as the provision of services.
Consent
For sending loyalty and promotional offers, SOL processes personal data based on the customer’s consent.
In relation to information society services, stricter rules apply regarding the consent of children. If a child is under 16 years of age (or under the age specified by applicable law), processing is lawful only if consent is given by a parent or legal guardian.
PROFILING AND MARKETING
Profiling at SOL refers to the automated processing of personal data to evaluate certain personal aspects of data subjects. SOL may conduct profiling to analyse customer consumption patterns for marketing and sales purposes. Based on profiling, SOL makes targeted service offers to customers.
SOL may use various profiling techniques. For instance, offers may be differentiated based on age (to provide age-appropriate offers) or previous purchases (to suggest relevant services).
If personal data is processed for direct marketing purposes, data subjects may “opt out” of such processing at any time. For example, if SOL sends you newsletters or SMS offers and you do not wish to receive them, you can opt out by notifying SOL. Customers who opt out may later choose to receive such offers again.
SOL reserves the right to amend this Privacy Policy. Changes will be periodically reviewed and updated as necessary. Any amendments will be announced on SOL’s website.
For questions or concerns regarding this Privacy Policy or data processing, please contact us at privacy@sol.lv.