Privacy policy

SIA “Titul” data privacy policy

The controller and its contact information

The controller of personal data processing is SIA “TITUL” (hereinafter referred to as the SIA “TITUL”), unified registration No. 40003601751, Legal address: Riga, Slokas street 49-1, LV-1007.

The scope of the document

Personal data is any information relating to an identified or identifiable natural person - the SIA “TITUL” client, cooperation partner or their employees, job candidates name, surname, identity number, residence address, personal phone number, personal e-mail, occupation, income amount received and planned services, billing information, phone, electronic communication’s information and other information that is related to a natural person.

The Privacy Policy is applicable to provide privacy and personal data protection, in relation to:

  • natural persons - clients, guests and other recipients of services (including potential, past and present), as well as third parties in the context of provision of services to a natural person (client, user) to receive or transfer to the SIA “TITUL” any information (including, contacts, payers, etc.);
  • the SIA “TITUL” office and hotel visitors, including in respect of whom surveillance is carried out;
  • the SIA “TITUL”’s maintained internet website visitors (hereinafter referred to as the "Clients").

The SIA “TITUL” cares for the Clients' personal data privacy and protection, complies with the Clients' right to lawfulness of the personal data processing in accordance with applicable legislation - laws of the Republic of Latvia and subordinate legislation, the European Parliament and Council Regulation 2016/679 of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data (Regulation) and other applicable laws in the field of privacy and data processing.

The Privacy Policy is applicable to the processing of data, regardless of the form and / or environment where the Client provides personal data (the SIA “TITUL”’s website on the internet, in paper format or electronically) and in which of the company's systems or on paper they are processed.

Purposes of personal data processing

The SIA “TITUL” processes personal data for the following purposes:

  • Provision of services:

- identification of a client;
- preparation and conclusion of an agreement;
- provision/maintenance of services;
- improving services and development of new services;
- advertising of services and distribution or commercial purposes;
- client service;
- consideration and processing of objections/claims;
- retention of clients, loyalty lifting, satisfaction measurements;
- administration of payments;
- collection and recovery of debts;
- website maintenance and improvement of operation.

  • For business planning and analytics:

- statistics and business analysis;
- planning and accounting;
- performance measuring;
- data quality assurance;
- research of the market and public opinion;
- reports preparation;
- clients’ opinion polling
- in the framework of risk management activities.

  • Provision of information to state administration authorities and operational emergency operators in cases and amount stated by regulatory enactments.
  • In the framework of video surveillance of the SIA “TITUL” property and safety of individuals, with the purpose of protecting the SIA “Titul” and third-party’s property, located in the Hotels’ (office’s) premises and on the territory, to ensure individual’s safety, prevent possible violations of the law, fix a fact of criminal offence, as well as to monitor the Hotel service process and quality. In the framework of video surveillance, the data is stored up to 7 days. After this deadline, the SIA “TITUL” ensures complete automatic deletion of data if the data has not been previously claimed or criminal offenses or other breaches of security were not detected. If the data was previously requested from competent national or local authorities or security breaches were detected, the data is stored as needed.
  • For other specific purposes, about which the Client is informed when the relevant data is given to the SIA “TITUL”.

The legal basis for personal data protection

The SIA “TITUL” processes personal data of Clients, based on the following legal grounds:

  • conclusion and enforcement of a contract - in order to conclude the contract after the Client’s application and ensure its implementation;
  • execution of regulatory enactments - to meet the SIA “TITUL”'s obligation related to the binding external regulatory enactments;
  • in accordance with the Client’s - data subject’s consent;
  • in legitimate (legal) interests - in order to realize existing obligations between the SIA “TITUL” and the Client or the contract entered into, or the SIA “TITUL”’s legitimate (legal) interests, arising from the law.

The SIA “TITUL”’s legal (legitimate) interests are:

  • to carry out commercial activities;
  • to verify the Client’s identity before entering into a contract;
  • to ensure execution of contractual obligations;
  • to prevent unwarranted financial risks of its commercial activities;
  • to keep the Clients’ forms and applications for the provision of services, other forms, and applications, notes about them, including which were oral, made by calling, e-mail, website etc;
  • to analyze the SIA “TITUL”’s website, application performance, to develop and implement their improvements;
  • to take action related to retention of Clients;
  • to segment the clients’ database for the provision of more efficient services;
  • to design and development services;
  • to advertise its services, by sending commercial information;
  • to send other messages about the process of the contract’s execution and performance of the contract’s significant events, as well as to perform clients’ polling related to services and the user experience;
  • to prevent fraud;
  • to ensure corporate management, financial and business records and analytics;
  • to ensure effective corporate management processes;
  • the efficiency of service provision;
  • to provide and improve service quality;
  • to administer payments;
  • to administer late payments;
  • to turn to public administration and operations offices and courts to protect the legal interests;
  • to inform the public about its activities.

Personal data processing

The SIA “TITUL” processes the Client’s data using possibilities of modern technologies, taking into account existing privacy risks and to SIA “TITUL” reasonably available organizational, financial and technical resources.

The SIA “TITUL”, with respect to the Client, can take automated decisions. About such SIA “TITUL” activities, the Client shall be informed individually in accordance with laws and regulations. The Client may object to automated decision-making in accordance with the law, however, recognizing that in some cases it may restrict the Client’s right to use the Client’s separate potentially available options (for example, to receive commercial offers).

To ensure qualitative and operative enforcement of contractual obligations, concluded with the Client, the SIA “TITUL” may empower its cooperation partners to carry out a separate delivery or services provision activities, such as individual work contracts, catering services, sending invoices and the like. If, while performing the tasks, the SIA “TITUL” cooperation partners process Client’s personal data, available to the SIA “TITUL”, the relevant SIA “TITUL” partners are regarded as the SIA “TITUL”’s data processing controllers, and the SIA “TITUL” has the right to forward to the SIA “TITUL”’s cooperation partners the Client’s personal data that is necessary for carrying out the activity in the amount necessary for performing the operations.

The SIA “TITUL”’s cooperation partners (having the personal data controller’s status) will provide processing of personal data and the protection requirements under the SIA “TITUL” requirements and laws, and will not use personal data for purposes other than execution of contractual obligations, concluded with the Client, on behalf of the SIA “TITUL”.

Personal data protection

The SIA “TITUL” protects the Client’s data, by using modern technology options, taking into account the existing privacy risks and to SIA “TITUL” reasonably available organizational, financial and technical resources, including the use of the following safety measures:

  • Where possible, use data anonymously;
  • Firewalls;
  • Intrusion protection and detection programs;
  • Other protective measures in accordance with current technology development.

Categories of personal data recipients

The SIA “TITUL” does not disclose to third parties the Client’s personal data or provision of any services and information, obtained during the period of validity of the contract, except:

  • if the data has to be transferred to a third party within the framework of the concluded contract, in order to perform a necessary or statutory delegated function (for example, within the framework of bank payments);
  • in accordance with the Client’s clear and explicit consent;
  • persons envisaged by external regulatory enactments according to their reasoned request, and procedure and volume stated by the external regulatory enactments;
  • in certain cases stated in external regulatory enactments, as well as for protection of the SIA “TITUL”’s legitimate interests, such as turning to court or other state institutions against a person who has violated the SIA “TITUL”’s legitimate interests.

Access to personal data by subjects of third countries

The SIA “TITUL”’s personal data can not be accessed by existing third country (i.e. countries outside the European Union and European Economic Area) developers or service providers (within the meaning of Regulation - dispatch to third countries) as if having the data controller’s (operator’s) status.

Personal data retention period

The SIA “TITUL” stores and processes the Client’s personal data while at least one of the following criteria is present:

  • only as long as the contract, concluded with the Client, is valid;
  • while according to the external regulatory enactments, the SIA “TITUL” or the Client may realize their legitimate interests (for example, submit an objection or initiate or bring a claim to the court);
  • until one of the parties has a legal obligation to keep the data;
  • while the Client’s consent is valid for the relative person’s data processing if there is no other legitimate basis for data processing.

When the above conditions are terminated, the Client’s personal data is deleted.

Access to personal data and other Client’s rights

The Client is entitled to receive information, stated by the regulatory enactments, relating to the Client’s data processing, making sure of the data accuracy and ability to correct them.

The Client, in accordance with the regulatory enactments, also has the right to request access from the SIA “TITUL” to the personal data, as well as request the SIA “TITUL” to make data supplementation, correction or deletion, or treatment limitation with respect to the Client, or rights to object to the processing (including processing of personal data carried out on the basis of the SIA “TITUL”’s legitimate (legal) interests), as well as the right to data portability. This right is enforceable in so far as data processing is not apparent from the SIA “TITUL”’s obligations that are imposed by applicable laws and regulations, and which are made in the public interest.

The Client may submit a request for the rights:

  • in written form in person at the SIA “TITUL” Hotel, presenting a personal identification document;
  • while according to the external regulatory enactments, the SIA “TITUL” or the Client may realize their legitimate interests (for example, submit an objection or initiate or bring a claim to the court);
  • as an electronic mail, by signing with a secure electronic signature;

Upon receipt of the Client's request for the rights, the SIA “TITUL” verifies the Client's identity, examines the request and executes it in accordance with the regulatory enactments.

The SIA “TITUL”’s response to the Client shall be sent by mail to his indicated contact address by registered post, as far as possible taking into account the Client's indicated type of receiving replies.

The SIA “TITUL” provides that data processing and protection requirements are met in accordance with the regulatory enactments and, in case of the Client’s complaints, takes useful steps to resolve the objection complaint. However, if this fails, the Client has the right to apply to the supervisory authority - the Data State Inspectorate.

The Client's consent to data processing and the right to withdraw

The Client can give consent to processing of personal data, for which the legal basis is the consent, on the SIA “TITUL”’s web pages or in person at the SIA “TITUL”’s hotel.

The data subject has the right at any time to withdraw the consent given for data processing in the same manner, in which it is given and in this case the future processing of data, based on the previously given consent for the concrete purpose, will no longer be carried out.

The withdrawal of consent does not affect data processing, carried out at the time the Client’s consent was valid.

By withdrawing the consent, data processing cannot be stopped, which is carried out based on other legal grounds.

When applying for a job you wish the submitted applications with curriculum vitae to be stored, please, when submitting the application, select: "I agree that my application and curriculum vitae are saved at SIA"SIA “TITUL””, and it can be used for future selection of other vacancies at SIA" SIA “TITUL”“

Communication with the Client

The SIA “TITUL” is in contact with the Client by using the Client’s contact details (phone number, e-mail address, postal address)

A communication regarding contractual obligations is performed by the SIA “TITUL” on the basis of a concluded contract (such as job execution time matching, information about invoices, changes of services, etc.).

Commercial statements

The communication on commercial statements about the SIA “TITUL”’s and/or third-party’s services, and provision of statements, unrelated to other direct contracted services (for example, client surveys), the SIA “TITUL” carry out in accordance with external regulatory enactments or in accordance with the Client's consent.

The communication, including about commercial statements, can be performed by the SIA “TITUL” by using automatic dialing equipment.

The Client’s consent to the SIA “TITUL”’s and/or its cooperation partners' reception of commercial statements can be given to the SIA “TITUL” and on other websites (such as in the forms for subscribing to updates) or by submitting a separate document.

The consent, given by the Client, to receive commercial statements shall be valid until its withdrawal (even after termination of the contract). The Client may at any time withdraw from receiving further commercial statements in one of the following ways:

  • in person at the SIA “TITUL”’s office/ Hotel;
  • using an automated option to withdraw from future notifications of commercial statements, by clicking the withdrawal indications at the end of the commercial statement (e-mail).

The SIA “TITUL” stops sending commercial statements as soon as the Client’s consent for withdrawal request regarding the commercial statements is processed.