HAT Brewery SIA Personal Data Protection Policy

Purpose: The purpose of this Policy is to ensure the rights of individuals (data subjects) for the secure processing of personal data, by acquiring and processing adequate personal data of individuals, and providing these individuals with information about the purpose, scope, protection, rights of individuals, and the duration of data processing.

1. Controller and Contact Information

Data processing controller:

HAT Brewery SIA, Registration No. 40203288881 Legal address: "Lāmiņas", Katlakalns, Ķekavas pag., Ķekavas nov., LV-2111, Latvia.

Contact information regarding personal data processing: Email address: [email protected]

2. How Your Data May Reach HAT Brewery SIA and How This Policy Applies?

2.1. In this Policy, as well as under the Regulation of the European Parliament and of the Council 2016/679 (hereinafter – Regulation), the term "Personal data" refers to any information related to an identified or identifiable natural person ("data subject").

2.2. This Policy applies to ensuring privacy and personal data protection concerning:

  • Natural persons – employees, consumers, participants in stocks and lotteries (potential, former, and current), and third parties who receive or transmit any information about a natural person (Personal data subject) in connection with the sale of goods or provision of services to a natural person (employee, consumer, participant in stocks and lotteries);
  • Natural persons – service providers, including appointed agents, buyers of HAT Brewery SIA goods (wholesalers, retailers), suppliers of various raw materials and materials, contact persons of service providers;
  • Visitors to HAT Brewery SIA's production facilities, offices and other premises, including those subject to video surveillance; voice line (telephone line) service users (voice recordings);
  • Natural persons – mobile application users who have agreed to receive commercial information, allowing the use of geolocation (GPS, Wi-Fi, Bluetooth) features;
  • Online services – visitors to internet websites and mobile applications maintained by HAT Brewery SIA (hereafter – Clients).

2.3. The Policy is applicable to data processing regardless of how the Client provides personal data (by concluding a contract, on HAT Brewery SIA's website, in mobile applications, on paper, or by telephone) or how HAT Brewery SIA obtains them (contact persons of business partners, lottery and stock winners, participants, surveillance cameras) and in which company's electronic systems or on paper they are processed.

2.4. HAT Brewery SIA cares about Client privacy and personal data protection, respecting Clients' rights to lawful processing of personal data in accordance with applicable laws.

2.5. Regarding specific types of data processing (e.g., cookie processing, etc.), environments, and purposes, additional, specific rules may be set, about which the Client is informed when they provide relevant data to HAT Brewery SIA.

2.6. Our websites and products, as well as our accounts on social networks (e.g., Facebook), may contain links to third-party websites. These third-party websites have their own Privacy Policy. If you visit these websites, you will be subject to these policies.

3. Purposes and Basis of Personal Data Processing

3.1. As far as permitted by law, HAT Brewery SIA may process personal data for possible purposes including:

  • Identifying the Client;
  • Preparing and concluding contracts;
  • Establishing employment relationships;
  • Delivering goods, placing orders, receiving goods, organizing logistics, other communications (contractual obligations);
  • Serving customers;
  • Reviewing and processing recommendations and objections;
  • Building customer relationships, fostering loyalty, measuring satisfaction;
  • Administering settlements;
  • Maintaining and improving websites and mobile applications.

3.2. For fulfilling the information obligation prescribed by the Regulation (Article 13), HAT Brewery SIA prepares a Personal Data Processing Declaration for each Data Processing Purpose (register) or related group of processing activities, where the Client can access precise information about the processing activities.

3.3. Should the information provided to the Client at the start of Data collection change, HAT Brewery SIA does everything possible to notify the Client of such changes as soon as possible and, if necessary, renew the Client's consent according to the changes before further processing.

3.4. HAT Brewery SIA does not make automated decisions regarding Clients.

  1. Legal Basis for Processing Client Personal Data:

    • Contract conclusion and execution – to conclude a contract at the Client's request and ensure its performance;
    • Compliance with statutory regulations – to fulfill obligations prescribed by external statutory regulations binding on HAT Brewery SIA;
    • Client – data subject's consent;
    • Legitimate (lawful) interest – to realize the legitimate (lawful) interests of HAT Brewery SIA or third parties arising from relationships existing between HAT Brewery SIA and the Client, from a concluded contract, or from law.

  2. Personal Data Protection

5.1. HAT Brewery SIA protects Client data using modern technology possibilities, considering existing privacy risks and HAT Brewery SIA's reasonably available organizational, financial, and technical resources.

5.2. HAT Brewery SIA has implemented internal rules for ensuring security, preventing incidents, and reporting.

5.3. Unfortunately, no data transmission is 100% secure. If you have concerns or suggestions for improvements, please inform us immediately.

  1. Categories of Personal Data Recipients

6.1. HAT Brewery SIA does not disclose Client personal data or any information obtained during service provision and contract operation to third parties, except for individual data transfers that may occur to the following entities:

  • If the respective third party needs to receive data within the scope of a concluded contract to perform a function necessary for contract execution or mandated by law (e.g., a bank for settlements);
  • According to the Client's clear and unambiguous consent;
  • Those who provide services on behalf of/instruction from HAT Brewery SIA;
  • Those who assist in our commercial activities, such as website hosting and development, debt collection, and customer service, help in marketing activities;
  • Analysts and search engine operators who help optimize and improve the website;
  • Statutory entities upon their justified request;
  • In cases prescribed by law for the protection of HAT Brewery SIA's lawful interests, e.g., resorting to court or other state institutions.

6.2. When transferring data, HAT Brewery SIA commits to ensuring that the data recipient adheres to the same or stricter security measures for personal data processing as those applied by HAT Brewery SIA.

6.3. Your personal data may be processed, stored, and transferred to third parties in the manner and scope specified in this Policy, in the contract(s) between you and us, and in the consents you periodically give us.

  1. Duration of Personal Data Storage – No Longer Than Necessary

7.1. HAT Brewery SIA stores and processes Client personal data as long as at least one of these criteria exists:

  • Only as long as the contract with the Client is valid;
  • While under the external statutory regulations HAT Brewery SIA or the Client can realize their legitimate interests (e.g., submit objections or initiate or carry a lawsuit);
  • While either party has a legal obligation to store data;
  • While the Client's consent to the relevant personal data processing is valid, if there is no other legal basis for data processing.

7.2. When the conditions mentioned in point 7.1. end, Client personal data is deleted.

  1. Access to Personal Data and Other Client Rights

8.1. The Client has the right to receive information prescribed by statutory regulations related to their data processing.

8.2. The Client has the right to request from HAT Brewery SIA access to their personal data, as well as request their supplementation, correction, deletion, or limitation of processing concerning the Client, or the right to object to processing (including personal data processing based on the legitimate (lawful) interests of HAT Brewery SIA).

8.3. The Client can submit a request to exercise their rights:

  • In written form by mail to HAT Brewery SIA's legal address: "Lāmiņas", Katlakalns, Ķekavas pag., Ķekavas nov., LV-2111, Latvia;
  • Via email, signed with a secure electronic signature and sent to the address: [email protected];
  • Personally, by previously arranging a meeting time with the contact person.

8.4. Upon receiving a request, HAT Brewery SIA verifies the Client's identity, assesses, and fulfills the request according to statutory regulations.

8.5. HAT Brewery SIA may reject requests that jeopardize the privacy of others or are unreasonable or repetitive, or would require disproportionate effort.

8.6. HAT Brewery SIA sends its response to the Client by registered mail or email to their specified contact address.

8.7. HAT Brewery SIA ensures compliance with data processing and protection requirements according to statutory regulations, and in case of a Client objection, performs reasonable actions to resolve the objection. However, if it is unsuccessful, the Client has the right to turn to the supervisory authority – the Data State Inspectorate.

  1. Client Consent for Data Processing and Right to Withdraw

9.1. To process data for which there is no other legal basis but which is necessary to achieve a lawful purpose of HAT Brewery SIA (e.g., to subscribe to newsletters, the ability to submit a CV electronically, participate in a lottery, analyze product target audience usage habits, prepare and send commercial notifications, individual advertisements, etc.), the Client may give consent on HAT Brewery SIA's portals/apps, electronically or in person at HAT Brewery SIA's legal address.

9.2. The Client has the right to withdraw consent for data processing at any time in the same manner as it was given, and at the same place where it was given, that is – on the respective website or in person at HAT Brewery SIA's legal address, and thereafter further data processing based on the previously given consent for that purpose will no longer be carried out. In any case, the Client has the right to withdraw their consent by submitting a written application to HAT Brewery SIA.

9.3. Withdrawal of consent does not affect the processing of data carried out during the time when the Client's consent was valid.

9.4. Withdrawing consent does not stop data processing that has another legal basis.

  1. Changes to the Policy

10.1. HAT Brewery SIA has the right to make additions to the Personal Data Protection Policy, making its current version available on HAT Brewery SIA's website.

10.2. HAT Brewery SIA retains previous editions of the Personal Data Protection Policy, which are available on HAT Brewery SIA's website. Regarding Clients whose rights may be limited by such changes, violating the requirements of Article 13 of the Regulation, HAT Brewery SIA ensures an individual information procedure compliant with the Regulation's requirements.

Contact Information:

HAT Brewery SIA "Lāmiņas", Katlakalns, Ķekavas pag., Ķekavas nov., LV-2111, Latvia. [email protected]