Version of 1 January 2020
1. General Matters
1.1. This Policy is an official document of SIA «Antiqon» (LLC) (registration No. 40103941382, Latvia, LV-1011, Rīga, Brīvības iela 52-1B) (hereinafter referred to as the Administrator) and determine the processing, protection and use of personal information about natural persons (hereinafter referred to as the User/Users) using website www.antiqon.com and/or the Antiqon application (hereinafter referred to as the Service).
1.2. The aim of this Policy is to ensure adequate protection of information about Users, including their personal data, against unauthorized access or disclosure. Relationships related to the collection, storage, distribution and protection of information about Users shall be regulated by this Policy, as well as the User Agreement, the Terms and Conditions of the Service, as well as the effective regulatory enactments of the Republic of Latvia.
1.3. The Administrator may unilaterally make amendments and/or supplements to this Policy without providing any separate notice to the Users. The User undertakes to regularly check the provisions of this Policy with regard to any amendments and/or supplements thereto. The User"s continued use of the Service after making such amendments and/or supplements to this Policy shall be construed as the User"s consent and his/her consent to the amendments and/or supplements. In the event of significant changes or amendments to this Policy, the Administrator shall send a notice to Users to review and accept the current version of this Policy.
1.4. This Policy has been developed and is being applied in accordance with the Terms and Conditions of the Service. In the event of a contradiction between this Policy and the Terms and Conditions of the Service in regards to the protection of information about the Users of the Service, this Policy shall prevail.
1.5. By using the Service and its functionalities, the User agrees to the terms of this Policy. In case the User does not accept them, the use of the Service and its functionality must be stopped immediately by deleting all data from his/her Personal Cabinet, as well as any and all of his/her Advertisements.
2.1. By providing Users with the opportunity to use the Service, the Administrator, acting reasonably and in good faith, shall consider that the User: • possesses all the necessary rights to register and authorize the Service, as well as use it, • provides reliable information about him/herself to the extent required to use the Service • is aware that the information posted by the User about himself/herself in the Service, in particular his/her surname, first name, location, is or may become available to other Users of the Service or Internet users, and these Users may copy or distribute this information; that the User may not delete certain types of information that he/she has passed on to other Users, • has read this Policy, accepts it and assumes the rights and obligations specified therein
2.2. The Administrator shall not verify the accuracy of the received (collected) information about the Users, except in cases when such verification is required to comply with the provisions of applicable laws and regulations and/or perform obligations towards the User. The Administrator may request the required personal information from the Users; in case of registration, the Users shall fill in all the required fields. Users shall not be required to provide personal data, but in this case, the use of the Service and its functionality must be stopped immediately, as the Administrator shall not be able to complete the registration of such Users or provide certain Goods or Services
3. Purposes of Processing of Information
3.1. The Administrator shall process the information about Users, including their personal data, for the following purposes:
- User identity verification;
- Processing of registration of natural persons as Users, providing Users with ID to access the Service, for maintenance and management of User registrations;
- Providing customer service to Users, providing answers to User questions, as well as providing feedback, requirements or handling complaints;
- Ensuring interaction between buyers and sellers using the features of the Service, processing of transactions and payments;
- Ensuring interaction between customers and Delivery services for the purposes of delivery;
- Personalization of User communication with the Administrator based on User search query records, information collected by the Administrator on the User order history, research and statistical analysis in order to improve the content and appearance of the Service, as well as improve the assortment of goods and services.
- Defining, developing and promoting products and services that the Administrator considers to be of value to Users, including various browsers and devices, in accordance with applicable laws. Cookies and other similar technologies may be used to display advertisements to Users based on Users" search queries and interests in accordance with Section 9 of this Policy. The Administrator undertakes to obtain the consent of the Users for the receipt of advertising messages in the cases provided for in regulatory enactments;
- To perform the obligations of the Administrator towards the Users in relation to the use of the Service;
- To improve and perfect the Service and its functional possibilities, as well as to develop new functional possibilities and tools of the Service;
- Notifying the User about the development of the Service and its functional possibilities, advertising own activities.
3.2. The Administrator may use the User personal data for other purposes not related to the above (e.g., archiving in the name of public interest, conducting scientific or historical research, statistical research) in cases where this is permissible in accordance with applicable data protection laws and regulations.
4. Content of User Information
4.1. User personal data:
- Data provided by users in the minimum required extent for registration in the Service: name, surname, mobile phone number, e-mail address, password;
- Data that becomes available to the Administrator when the User logs in to the Service using other Internet resources (for example, User names on social networks and photos of User profiles in these Internet resources);
- Data further provided by the Users at the request of the Administrator and which is sent to the Users if necessary, for example, in order to prevent violations of the rights and protect the legitimate interests of third parties. The Administrator may, in particular, request from the User a copy of an identity document or other document containing the User"s name, photograph, as well as other additional information that the Administrator deems necessary and sufficient to identify such User and exclude abuse and violations of third party rights;
- If the User is a registered seller or service provider then, in addition to the information listed above, the Administrator may collect information about the User"s identity documents, taxpayer identification number, business information, such as registration information, actual cargo delivery/collection address;
- In connection with any transaction and payment services or the execution of orders, the following data may be collected, but this list is not exhaustive: bank account numbers, payment and delivery information, credit/debit card numbers, expiration dates and security codes; data on checks and payment orders, in order to facilitate buying and selling, as well as to align the purchase price of goods sold and services sold via the Service.
- The Administrator shall register information about consumer activities within the Service. Information related to the following activities, including, but not limited to: product types and characteristics, prices, delivery information and information on all dispute records, as well as information disclosed in all discussion forums obtained while using or transacting with the Service.
4.2. Other information about Users to be processed by the Administrator:
5. Processing Information about Users
- Standard technical and other data automatically received by the Administrator when the User accesses the Service and other subsequent actions of the User on the Service (location within a certain period of time, IP address, type of operating system of the User"s device, sections of the Service visited by the User).
- The Administrator shall record data about Users" activities on the Service during purchase or search, including, but not limited to: IP addresses, search patterns, customer behaviour patterns, and equipment data.
- The Administrator shall collect statistical information about the Service and its visitors, including, but not limited to: IP addresses, web browser program, operating system, software and hardware, pages visited, information about the number of visits and visitors.
- Information that Users have further posted on the Service, including photos, comments, and other information about themselves;
- Information obtained as a result of the User"s activities in the Service;
- Information obtained as a result of the actions of other Users of the Service.
5.1. The processing of personal data is based on the following principles:
(a) the lawfulness of the purposes and methods of the processing of personal data;
(b) good faith;
(c) the compliance of the purposes for which the personal data are processed with the purposes previously defined and declared at the time when the personal data are collected, as well as the powers of the Administrator;
(d) the adequacy of the amount and type of personal data processed, the methods of personal data processing for the purposes of personal data processing;
(e) the prevention of the aggregation of databases containing personal data created for purposes that are incompatible.
5.2. Conditions and purposes of personal data processing. The Administrator shall process the User personal data for purposes of performance of the License Agreement entered into by the User and the Administrator.
5.3. Conditions and purposes of personal data processing. The Administrator shall process the User personal data for purposes of performance of the License Agreement entered into by the User and the Administrator.
5.4. The collection of the User personal data shall be performed within the Service after registration and/or authorization, as well as in cases when the Service is used by the User and/or the User provides additional information about himself/herself using the Service tools.
5.5. User personal data shall be stored only in electronic data carriers and processed using automated systems, unless non-automated processing of personal data is required for purposes of ensuring compliance with the regulatory enactments.
5.6. The User personal data shall be deleted from the Service when the Administrator deletes the information published by the User, as well as the User Personal Cabinet at the User"s request or on own initiative in the cases provided for in the License Agreements. After deleting the User personal data from the Service, the Administrator shall store them in its electronic data carriers for a period stipulated in the regulatory enactments of the Republic of Latvia. After expiry of the said period, the Administrator shall destroy the personal data.
5.7. The Administrator undertakes to delete the User personal data if there is no substantiated commercial need to process such data.
6. Disclosure of Personal Data
6.1. The User personal data shall not be transferred to any third parties, except in cases expressly provided for in this Policy, License Agreements or applicable laws and regulations.
6.2. The Administrator may transfer information about Users (including cross-border transfers to a foreign territory that ensures adequate protection of the rights of personal data subjects), including their personal data, to third parties who are Users (to ensure the use of the Service to the extent provided for by its functionality and architecture, and for the Administrator to meet its obligations under the License Agreements) and the Administrator"s counterparties. The provision of such information to the Administrator"s counterparties shall be possible provided that the transfer of this information is required to ensure the operation of the Service and provision of the User with access to its use, as well as provided that such counterparties have undertaken to ensure the confidentiality of information received.
6.3. The Administrator may disclose or transfer information about the Users to its partners and service providers for the purposes of providing services to the Users as described in this Policy or information communicated by the User in the process of collecting Personal Data. Such partners or service providers may include, for example: • Administrator"s business partners (for example, to provide discounts or offers that may be of interest to Users) • Marketing platforms such as Google, Twitter, Facebook, Instagram and VKontakte, and providers of user behaviour analysis services in order to tailor the content that Users see when visiting the Service. Such marketing platforms may combine data received from the Service, data obtained from other sites or other sources to place targeted advertising. The activities of such third party marketing platforms shall be governed by their privacy policies and not by this Policy. • The payment service providers in order to process payment for transactions. The activities of payment service providers may be governed by their privacy policies, not this Policy • Logistics partners to provide delivery services to customers, including return and exchange of goods, warehousing services • Customs agents for customs clearance • Cloud programming service providers to provide cloud storage services • Warranty service providers for warranty service provision • Customer support after-sales service providers • Risk management service providers to assess User profile and operational risks.
6.4. The above-mentioned Service Providers shall be obliged to comply with the requirements of the Administrator in the field of data confidentiality and security, and they may use the User personal data only for the above-mentioned purposes and not for personal needs.
6.5. The Administrator shall retain the User personal data for as long as the Administrator has a substantiated commercial need to retain the data in order to provide Services to the Users or deliver the Goods, or for as long as necessary or permitted by law, in particular in the field of taxation and accounting.
6.6. The information that Users send for publication on the Service shall be publicly available on the Service and therefore available to all Internet users. Users should exercise caution when deciding what information to send to the Administrator for publication.
7. User Rights and Obligations
7.1. Users have the following rights:
7.1.1. to provide free, unhindered access to the information they have sent about themselves by placing it in their Personal Cabinet on the Service;
7.1.2. to independently make changes and corrections to information about oneself in one"s Personal Cabinet in the Service, when such changes and corrections contain relevant and reliable information;
7.1.3. on the basis of a request to the Administrator, to receive information regarding the processing of personal data;
7.1.4. to send a request to the Administrator regarding the deletion of personal data;
7.1.5. to object to the processing of personal information if it is justified by a legitimate interest, as well as the right to opt out of direct marketing;
7.1.6. in certain cases, to request the Administrator to restrict the processing of personal data or a request to transfer personal information;
7.1.7. to opt out of marketing materials sent by the Administrator at any time. The user can exercise this right by clicking on the "Unsubscribe from news" link in the electronic marketing messages sent by the Administrator.
7.1.8. to withdraw his/her consent to the collection and processing of personal information at any time. The withdrawal shall not affect the lawfulness of the processing which took place before such withdrawal, nor the lawfulness of the processing carried out based on other legal grounds other than consent;
7.2. The User is aware that the interface of the Service provides that part of the information about the User shall be available to other Users of the Service and Internet users.
7.3. The Administrator shall not be responsible for the disclosure of the User personal data to other Users of the Service and Internet users who have gained access to such data. The Administrator advises the Users to act responsibly when deciding on the amount of information about themselves to be published on the Service.
7.4. The User acknowledges that by deleting personal data (including other information about the User) from the User Personal Cabinet or deleting the User Personal Cabinet from the Service, information about the User copied by other Users may be retained.
8. Measures Taken to Protect the User Information
8.1. The Administrator shall implement technical and organizational legal measures to ensure the protection of the User"s personal data against unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other illegal activities in regard to personal data.
8.2. The User"s username (e-mail address) and password which the User creates when registering with the Service shall be used for authorization in the Service. The User shall be responsible for the security of this information. The User shall not be entitled to transfer his/her username or password to third parties, and he/she shall also be obliged to implement measures to ensure their confidentiality. The User may authorize the Service using his/her account created with other Internet resources through which may serve as means of authorization with the Service.
9.2. Cookies are small amounts of data that are sent from a website to a web browser and stored on the hard drive of the User"s computer or mobile device. If the User blocks and fails to delete cookies, each time the same browser or mobile device is used to access the Service, the Service"s web servers shall be notified of the user"s access to the Service, and the Service Administrator shall receive data about the User"s visit and service usage pattern. Cookies help to analyse the use of the website, including understanding of the visitor"s activities, thus improving the site and making it more convenient.
9.3. Cookies allow the Administrator to remember information so that Users do not have to re-enter it each time they use the Service.
9.5. For the additional purposes described above, the User may determine how and in which cases cookies shall be accepted by changing the privacy settings of the Internet browser used by the User to access the Service or by changing the privacy settings on the User"s mobile device.
Since the way to block cookies in the browser settings depends on the browser used, the User should refer to the "Help" section of the browser used for more information.
If the User changes the browser"s privacy settings, the User"s mobile device shall continue to collect information until the User changes the device"s privacy settings and vice versa.
9.8. The Service Administrator uses the following types of cookies:
- Session cookies are temporary cookies stored on the User"s device for a certain period of time until the User leaves the website or closes the software (web browser). Session cookies help the Service to remember the actions taken by the User on the previous page, thus eliminating the need to re-enter information;
- Persistent cookies - the User"s device stores them for the time period specified in the file settings or until the User deletes them manually. Cookies help the Administrator to identify the User as a unique visitor;
- External device cookies (such as third-party cookies, for example, Google)/Advertising cookies - files, for example, from the servers of companies or service providers working with the site owner. These files allow customization of ads according to the User"s wishes and habits. They also allow to evaluate the effectiveness of ad (for example, how many people clicked on an ad or opened a site). Information obtained by third-party advertisers may include data such as geographic location (as a result of the IP address obtained).
- The Administrator also uses social media cookies. Some of our Service pages allow sharing content on social networks such as Facebook and Instagram. Sometimes we publish videos from sites like YouTube. These sites set their own cookies which are beyond our control. To opt out of such cookies, follow the instructions on the respective sites. Furthermore, such sites apply their own privacy policies which Users may find on these sites.
10. User Requests
10.1. The Users may send their requests to the Administrator, including requests regarding the use of their personal data, as provided for in Clause 6.3 of this Policy, by sending a request to an e-mail address [email protected]
10.2. The request sent by the User must contain the following information:
- The number of the main identification document of the User or his/her representative;
- Information on the date of issue of the specified document and the issuing authority;
- Information confirming the User"s relationship with the Administrator (in particular, the e-mail address used by the User as his/her login information to access the Service);
- Signature of the User or his/her representative.
10.3. The Administrator shall be obliged to review and send a response to the received User request within 30 days after receipt thereof.
10.5. All correspondence received by the Administrator from the User shall be considered restricted information and shall not be disclosed without the written consent of the User. Personal data and other information about the User sending the request may not be used without the explicit consent of the User, except to provide a response to the received request or in cases provided by law.