Food Society privacy policy

This Privacy Policy aims to provide an individual – a Client of Food Society LLC (hereinafter referred to as the Company) – with information on purpose, scope, protection, processing of personal data and rights of the data subject at collection, as well as processing of the Client’s personal data.

DATA ADMINISTRATOR AND ITS CONTACT INFORMATION

Data administrator responsible for processing of your data is Food Society Ltd., reg. No. 40203077301. The Company is responsible for safe storage, processing and deletion of your data. If you have any questions about personal data processing, please, contact the Company by e-mail: gdp@foodsociety.lv or by phone: 20021022.

SCOPE OF THE DOCUMENT

Personal data is any information about the identified or identifiable individual. Here are categories and examples of personal data:

The Privacy Policy covers protection of privacy and personal data regarding the following data subjects (hereinafter referred to as the Clients):

• individuals – Clients and other users of the Company’s services (including potential, former and existing), as well as third parties that, due to provision of individual (customer, partner) with the services, receive or provide the Company with any information (including information about contact persons, payers, etc.),

• visitors of the Company’s restaurant, bar and other premises, including the ones subject to video surveillance,

• visitors of the Company’s website, as well as the ones calling to the Company’s phones,

• individuals – job candidates for vacancies in the Company.

The Company ensures privacy and protection of the Clients’ personal data, respects the Clients’ rights to legitimate processing of personal data in compliance with the current legislation – 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 (hereinafter referred to as the Regulation) and other effective laws in the field of privacy and data processing.

The privacy policy applies to data processing regardless of the form and/or media how the Client provides personal data (on the website, in mobile applications, self-service portal, on paper or by phone), or in which system of the Company or in paper form the data is processed.

In additional, special regulations may be established regarding specific types, media, purposes of data processing (e.g. cookies processing, etc.), about which the Client is informed upon providing the Company with the relevant data.

PURPOSES OF PERSONAL DATA PROCESSING

Food Society processes data for the following purposes:

• For provision with services and selling goods:

  • to identify the Client,

  • to prepare, sign and prove the fact of signature,

  • to supply goods and provide with services (meet contractual obligations),

  • to ensure operation of the services,

  • to meet warranty obligations,

  • to improve goods and services, develop new goods and services,

  • to promote, advertise and promote use of the services,

  • to attend Clients,

  • д to review and process applications and objections,

  • to retain Clients, increase loyalty, assess satisfaction,

  • to administrate payments,

  • to repay and collect debts,

  • to maintain and improve operation of websites and mobile applications.

• For planning and analysis of business activities:

  • for statistics and analysis of business activities,

  • for planning and accounting,

  • for performance assessment,

  • for data quality provision,

  • for conducting market and public opinion research,

  • for reporting,

  • for Client surveys,

  • for risk management.

• For security of information, information systems and the Company.

• For provision of information to government and law enforcement bodies in events and to the extent established by the regulations of the government bogies and local governments.

• For assessment of candidates’ suitability for vacancies.

• For other specific purposes about which the Client is informed upon providing the Company with the relevant data.

LEGAL BASIS FOR PROCESSING PERSONAL DATA

The Company processes personal data based on the following legal grounds:

• the Client’s consent – the Client, as a subject of personal data, gives his consent personal data for collection and processing for certain purposes. The Client’s consent is the Client’s free will and independent decision, which can be given at any time, thereby allowing the Company to process personal data for certain purposes. The Client’s consent is mandatory for him if it is given orally (during a telephone conversation after identification of the Client) or in writing (when filling out a form in the Company’s premises, sending an electronic request after identification of the Client). The Client has the right to withdraw the previously given consent at any time using the specified communication tool with the Company. Withdrawal of the consent does not affect legality of the processing based on the consent given before the withdrawal.

• Job candidate’s consent – a job candidate for a vacancy in the Company, as a subject of personal data, gives his consent for personal data collection and processing to allow the Company to assess as accurately as possible the candidate’s suitability for the vacancy. The job candidate’s consent is his free will and independent decision, which can be given at any time, thereby allowing the Company to process personal data for certain purposes. The Client’s consent is mandatory for him if it is given orally (during a telephone conversation after identification of the Client) or in writing (when filling out a form in the Company’s premises, sending an electronic request after identification of the Client). The Client has the right to withdraw the previously given consent at any time using the specified communication tool with the Company. Withdrawal of the consent does not affect legality of the processing based on the consent given before the withdrawal.

• Signature and execution of the contract – in order to allow the Company to sign and fulfil the contract with the Client, providing high-quality services and attending the Client, the Company needs to collect and process certain personal data before signature of the contract with the Company or during fulfilment of already signed contract.

• Fulfilment of legal obligations – the Company has the right to process personal data in order to comply with the legal requirements as well as to give response to the legal requests of the government bodies and local governments.

• Protection of vital interests – the Company has the right to process personal data to protect vital interests of the Client or other individual, for example, if processing is necessary for humanitarian purposes, to monitor natural and man-made disasters, in particular to monitor epidemics and spread thereof, or in humanitarian emergencies (terrorist acts, man-made disasters, etc.).

• Performance of official powers or public interests – the Company has the right to process data for performance of tasks to be carried out in the public interest or in the exercise of official powers granted to the Company by the law. In such cases, the grounds for personal data processing are stipulated in the legal regulations.

• Legitimate (legal) interests of the Company or a third party – in compliance with the Company’s interests based on provision with high-quality services and timely support to the Client, the Company has the right to process the data of an individual to the extent objectively necessary and sufficient for the purposes specified in this Policy. The Company has the following legitimate interests:

• to carry out business activities,

• to provide the Company’ services,

• to verify identity of the Client before signature of the contract,

• to ensure fulfilment of the contractual obligations,

• to prevent from unreasonable financial risks for its business activities (including to assessthe credit risk before selling goods and services and during fulfilment of the contract),

• to save the Clients’ orders and applications for purchase of goods and provision with services, other orders and applications, references thereto, including the written or oral ones, made by calling to the Company’s phones, and on homepages in the Internet,

• to record conversations with the Clients about support, provision of services, payments for the purpose of monitoring quality of the service to the Clients,

• to record conversations with the Clients to ensure fulfilment of the contractual obligations associated with the service,

• to record conversations with the Clients during which an oral agreement is concluded in order to prove signature of the contract,

• to analyse operation of the Company’s home pages, websites and mobile applications, to develop and implement updates thereof,

• to carry out Client retention activities,

• to segment the Client database for more efficient provision with the services,

• to develop and improve products and services,

• to promote he Company’s products and services,

• to send other messages about progress of the contract fulfilment and about events important for fulfilment of the contract, as well as to carry out the Clients surveys about goods and services and about experience of using thereof,

• to prevent fraud,

• to ensure corporate governance, financial and business accounting and analysis,

• to ensure effective Company management processes,

• to ensure efficient provision with services and sale and delivery of the goods,

• to ensure and improve quality of the services,

• to administrate payments,

• to administrate outstanding payments,

• to choose the best candidate for job in the Company,

• to contact the government and law enforcement bodies and the court to protect legitimate interests of the Company,

• to inform the public about activities of the Company.

PERSONAL DATA PROCESSING

The Company processes the Client’s data using the modern technologies, taking into account the current privacy risks and the organizational, financial and technical resources available to the Company.

In order to ensure fulfilment of the contractual obligations to the Client in a high-quality and prompt manner, the Company may authorize its partners to carry out certain tasks on delivery of goods or provision with services, such as, for example, delivery of goods, sending out invoices, etc. If, in performing these tasks, the partners process the Client’s personal data available to Food Society, the relevant partners are considered as data processors (processors) of Food Society and the Company has the right to transfer the Client’s personal data necessary for performance of these tasks to the partners, to the extent necessary for performance of these tasks.

The Company’s partners (in the status of personal data processors) will ensure compliance with the requirements for processing and protection of personal data in accordance with requirements of the Company and legal regulations and will not use the personal data for the purposes other than for fulfilment of the contractual obligations signed with the Client on behalf of Food Society.

PROTECTION OF PERSONAL DATA

The Company protects the Client’s data using the modern technologies, taking into account the current privacy risks and the organizational, financial and technical resources available to the Company, including use of the following security measures:

• data encryption during data transmission (SSL encryption),

• data encryption on servers,

• firewall,

• intrusion detection and prevention software,

• other security measures in accordance with the modern technologies.

CATEGORIES OF PERSONAL DATA RECIPIENTS

The Company does not disclose to third parties the Client’s personal data or any information received during provision with the services and validity of the contract, including information about the services received, except for:

• if the data must be transferred to the relevant third party under the signed contract for performance of any function necessary for fulfilment of the contract or delegated by the law (for example, to a bank as a part if payments or for provision with the services, such as delivery of goods, and the Client is informed about it),

• under clear and unambiguous consent of the Client,

• to parties provided for by external legal regulations, at their reasonable request, in the manner and to the extent established by these external legal regulations,

• in events provided for by the external legal regulations to protect legitimate interests of Food Society, for example, by applying to the court or other government bodies with a claim to a person who violated these legitimate interests of the Company.

PERSONAL DATA STORAGE PERIOD

The Company stores and processes the Client’s personal data as long as at least one of the following criteria exists:

• as long as the contract signed with the Client is valid only (including conversation records whereby the oral agreement is concluded/order for provision with a service is made),

• the data is necessary for fulfilment of the purpose it was obtained for,

• as long as Food Society or the Client can realize their legitimate interests in accordance with the procedure provided for by the external legal regulations (e.g., to submit objections or claim to the court),

• as long as one of the parties has a legal obligation to store the data (e.g., according to the laws of the Republic of Latvia the Company must store invoices for 5 years, etc.)

• as long as the Client’s consent for processing the personal data by the relevant party is valid, unless there is another legal basis for processing the data.

• After terms and conditions mentioned herein cease to exist, the Client’s personal data will be deleted. Audio recordings are stored for at least one year from recording thereof in accordance with the legal regulations.

ACCESS TO PERSONAL DATA AND OTHER RIGHTS OF THE CLIENT

In accordance with the legal regulations, the Client has the right to request from Food Society the access to own personal data, as well as to request from the Company to supplement, correct or delete the same, or limit processing thereof, or the right to object to processing (including the processing of personal data based on the legitimate interests of the Company) as well as the right to data portability. These rights are exercised as far as the data processing does not arise from obligations of Food Society delegated to the Company by effective legal regulations and fulfilled in the interests of the Company.

The Client may request to exercise its rights:

• in writing in person in premises of the Company at the address: 3 Smilsu Street, Riga, against the identity document,

• by sending a request by e-mail to the e-mail address: gdp@foodsociety.lv and signing it with the secure electronic signature.

After the Client’s request to exercise the rights is received, Food Society verifies identity of the Client, assesss the request and fulfils it in accordance with the legal regulations.

The Company respond to the Client by mail to the specified contact address by the registered mail or in compliance with the response manner specified by the Client.

Food Society ensures compliance with the data processing and protection requirements in accordance with the legal regulations and, if the Client’s objections, takes the appropriate measures to remedy the objections. However, if a failure, the Client has the right to contact the supervisory authority – the State Data Inspectorate.

CLIENT’S CONSENT TO DATA PROCESSING AND WITHDRAWAL RIGHT

The Client may, by telephone or in person at the Company’s premises, give consent to processing of personal data on the Company’s Internet homepage, the legal basis for which is the consent (e.g. a newsletter subscription form).

The Client has the right to withdraw the consent to the data processing at any time in the same way as it was given, i.e. by phone, by sending an email or in person at the Food Society premises, and in such event, further data processing based on the previously given consent for the specific purpose will not be carried out.

Withdrawal of the consent does not affect the data processing carried out at the time when the Client’s consent was valid.

Withdrawal of the consent will not suspend the data processing carried out based on other legal grounds.

COMMUNICATION WITH THE CLIENT

The Company communicates with the Client using the contact information specified by the Client (phone number, email address, postal address).

The Company communicates on issues associated with fulfilment of contractual obligations under the signed contracts (e.g. for goods or services delivery, invoice information, changes in services, etc.).

COMMERCIAL ANNOUNCEMENTS

Food Society carries out communication regarding commercial announcements about services of the Company and/or third parties, as well as other announcements not directly related to provision of services under the contract (e.g. customer surveys), in accordance with the external legal regulations or consent of the Client.

The Client may give the Company and/or its partners the consent to receive commercial announcements on the Company’s website (e.g. a news subscription form) by phone or in person at the Company’s premises.

The Client’s consent to receive commercial announcements is valid until it is withdrawn (even after termination of the contract for provision with the services). The Client may at any time withdraw from further receipt of commercial announcements in any of the following manners:

• by sending an e-mail to the e-mail address: gdp@foodsociety.lv,

• by phone: 20021022,

• in person at the Company’s premises,

• by using the automatic option provided in the commercial announcement to unsubscribe from further mail receiving by clicking on the withdrawal link at the end of the relevant commercial announcement (e-mail).

The Company will cease sending commercial announcements as soon as the Client’s request has been processed. Processing of the request depends on technological potential and may take up to seven days.

Sharing own opinion in surveys and leaving contact information (e-mail, phone number), the Client agrees that Food Society may contact the Client regarding assessment made by the Client, using the contact information of the Client.

VISITING SITES AND COOKIES PROCESSING

The Company’s homepages may use cookies. Cookies are small pieces of information that a website stores on your computer or mobile device when you visit a company website, such as www.barents.lv. They help the website function by storing information on your device and on our servers. The Company uses cookies as far as it is necessary for operation of Food Society websites and to enable additional data analysis by Google Analytics.

Enabling these cookies is not strictly necessary for fulfilment of basic functions of the website, but will give you a more convenient browsing experience. You can delete or block these cookies at any time, but if you do so, some features of the website may not work as well as intended.

With the help of cookies, we process your data about use of the website and learn which services are important to you. This helps us to improve our services and offer the information you are concerned in social media, mobile applications and other websites.

Food Society homepage may contain links to third-party websites that have their own terms of use and personal data protection, for which the Company is not responsible.

OTHER TERMS

The Company has the right to make amendments to the Privacy Policy by publishing the current version for the Clients on the Company’s website – www.barents.lv.