The processor of personal data is Smart Electric Technology SIA (reg. Nr.40203265643, Mārupes nov., Mārupes pag., Jaunmārupe, Ozolu iela 28 k-1, LV-2166) (hereinafter SET).

1. What does the privacy notice entails?

The privacy notice:
explains what we do to protect and respect the privacy of your personal data;
explains how we collect, use and protect your personal data;
helps you to understand how your personal data is collected and used and what your rights are regarding your personal data.

When processing your personal data, we comply with Latvian and European Union legislation.

We use this data for the purpose for which we collected the data and to the extent, that is necessary to achieve that purpose. Once the objective has been attained, we delete the personal data.

The privacy notice provides you with information and guidelines when you use our services, products, applications and e-environments or visit our websites. The privacy statement does not include information concerning the processing of data on the websites of other companies or services provided by them, even if you use those services through SET’s e-environments or services.

You may use our services and e-environments either as a contractual client, solely as a service user on the basis of a contract entered by someone else, or simply by visiting our e-environments as a user, without having to have signed a contract with us. We are guided by the privacy notice in all of the following cases. If the client of our services allows the user to use services on the basis of a contract between them and SET, the client must also ensure that the user is familiar with the privacy notice.

We refer to the privacy statement and enable you to read it at the time of conclusion of a contract, as well as when providing a service, product and/or use of an e-environment to you. The privacy notice is a document that conveys information to you and is not part of the contract signed with you or of the General Terms and Conditions of SET.

Just as modern e-services are evolving at a fast pace, so are the data processing activities necessary to provide the above-mentioned e-services. We will do our best to keep the privacy statement up-to-date and available to you on SET website or via the SET stores. We will notify you of the most significant changes that concern you in the privacy notice on our website, by email or in any other reasonable manner.

2. On what grounds and objectives do we process your personal data?

SET processes Your personal data for the following purposes: performance of a legal obligation, performance of a contract, legitimate interest of SET and your consent.

2.1. Compliance with an obligation arising from legislation
Compliance with the obligations arising from the law stipulates data processing that we are required to conduct, as we as a service provider/merchant are required to do so by law.
If data processing is necessary for the performance of an obligation arising from law, we in SET cannot decide on the collection and recording of such personal data, nor can you.

2.2. Performance of a contract
The processing of personal data in order to perform a contract primarily related to allowing a certain result for our services and products and this cannot be achieved by avoiding the processing of personal data.

2.3. Legitimate interest
Legitimate interest means that we want to use personal data first and foremost to improve our services and service quality, for the development of services, products and e-environments, and for the promotion of client communication and business activities, all of which is not strictly necessary for the performance of a contract. This way we can provide our client with services, products, price solutions, servicing, etc. just like clients expect us to do. Additionally, we will be able to compile statistics necessary for making the right business decisions. We also process data on the basis of this ground, if it is necessary for documenting transactions made in the course of a business activity and for other business information exchanges. Based on legitimate interest, we will also process your basic data for the purpose of marketing analysis.
Legitimate interest is, above all, the balance between your and our rights. In modern client relations, it is assumed that the service provider will make the use of the service and servicing as simple and accurate as possible for the client. However, this can be the best achieved if we are able to use your personal data. However, we still need additional data processing, for example, for the best use of the services channels, for improvment and development of our charging station network and systems, usage statistics, etc.
This overview concerning the processing of personal data on the basis of legitimate interest is not exhaustive. In the event of reasonable necessity and to a reasonable extent, we may process data on the basis of legitimate interest for other purposes as well, provided in compliance with legislation.

2.4. Consent based data processing
First and foremost, we ask for your consent for the use of data (incl. location data), without which we could provide our services, goods and e-environments, but without which personal service, user experience and convenience, as well as marketing would not be complete or personalized.
We wish to use, with your consent, your data to determine your purchasing behavior and consumer habits and/or to derive, by using profiling methods, your consumer related expectations, preferences and needs in order to make marketing offers and send messages to you and select the suitable marketing channel to do so.

3. What is personal data and what kind of personal data does SET process?
Personal data (hereinafter also data) is data that is directly or indirectly linked to you as a private individual. For the sake of clarity, we group your personal data into the categories based on their nature and sources. The source of personal data refers to through which channels or through whom the personal data reached SET.

3.1. Basic data
Basic data includes, for example: username, e-mail address, payment details, etc.

Data collection sources: we obtain information from you and through your use of services.

3.2. Location data
Location data refers to information about the geographic location of terminal equipment or the place of service provision. For example: location coordinates (GPS).

The data listed above may be associated with you directly or indirectly. Direct association means that the data refers directly to you as one specific natural person. Indirect association means that the data can be associated with you by using additional information or additional processing.

Location data does not refer to your place of residence, service provision or invoicing address, contact address, etc. That information is part of your basic data.

Data collection sources: We obtain data through your use of services that require the determination of geographic location.

3.3. Message content
Message content – if you contact us as a service provider, by using the aforementioned means of communication, for example by calling our customer service line or by sending us an e-mail, we are one of the parties to the communication and therefore have the right to use and store the message content data (e.g., to prove the transaction, improve our customer service, etc.). The same applies to situations in which SET has initiated communication with you.

Sources of data collection: we obtain data if you provide it to us by contacting us.

3.4. Non-personal Data
Anyone can visit without registering and entering his/her personal data. In that case, the only information he/she shares with SET is related to his/her visit. This type of information is called non-personal and transferred in the automatic mode through the analytics tools, such as Google Analytics, Google Tag Manager, Google Maps, Yandex Metrica, Facebook Widget. Such information is only used to improve the performance of SET, and not to collect personal data.

Non-personal data includes date and time of visit, region, city, views, login page, logout page, last traffic source, advertising transitions, search engine, advertising system, IP address, and search history.

4. On using cookies in our e-environments

Similarly to other websites, SET’s websites and e-environments use the technology of cookies.

Cookies are small text files uploaded to the user’s computer via the e-environment’s server. As a result, the web browser can send information of the cookie back to the e-environment during every new visit to the e-environment, in order to recognize the user.

Cookies may be disabled in your browser settings, if you have selected this option. Keep in mind that in some cases it may slow down the browsing of a website, reduce the functionality of certain websites or prevent access to them.

We may combine the information obtained with cookies with information about you in other ways, e.g., with information about services used.

Our websites may have links to third-party websites, products and services, as well as social media extensions (e.g., Facebook plugins, Google Analytics) for marketing and statistics purposes. Third-party services or third-party applications on our websites are subject to the privacy protection rules of third parties. We recommend that you acquaint yourself with the personal data protection practices of those third-parties.

As a rule, we use data collected with cookies for the following purposes:

4.1. Functional cookies and provision of services
Cookies are very important for the functioning of our website and electronic services and allow us to streamline user experience. For example, if the user wants, he/she does not have to enter his/her username, password and personalization options every time they log into our service.

4.2. Development of services
By tracking cookies, we can improve the functioning of our e-environment and electronic services. For example, we can get information on what are the most popular parts of our website, which websites our users will pass by, from which websites they come from and how much time they spend in our e-environment.

4.3. Usage analysis
We use cookies to compile statistics on the number of visitors to our e-environments and online services, and we also evaluate the effectiveness of advertisements.

4.4. Directing marketing
By using cookies, we can also collect information about the displaying of advertisement or specific browser-targeted content by creating different target groups.

5. Who does SET transfer the personal data?
SET is entitled to transfer personal data to third parties to fulfill contractual obligations. The third parties are business partners of SET, who provide and/or use postal services or render leasing and/or payment transfer services.

For the purposes of performing marketing activities, SET is entitled to transfer personal data to third parties. The third parties are business partners from whom SET purchases advertising services.

6. Your rights
You have the right:
to obtain information on the personal data processed
to get access to his/her personal data
to submit a request to correct improper/incomplete personal information or to modify/supplement his/her personal data in his/her personal account. You are responsible for the providing correct or modified data
delete his/her personal data as soon as this data is no longer required or if the personal data processing is illegal, except when SET has a legal right to store the Client’s data
to submit a request to refuse the personal data processing for marketing purposes
to not give his/her consent to the personal data processing for use in direct marketing, when registering
to ask for limitation of the personal data processing

To request information on the processing, modification/correction, deleting of the personal data, as well as on limitation or refusal of your personal data processing you can send an e-mail to SET is entitled to request a copy of the your personal data to identify a person. SET undertakes to respond to your requests within 30 days from the date of submission.