1. About us
RB Rail AS, reg. No. 40103845025, legal address: Satekles iela 2B, Rīga, LV-1050, Latvia (hereafter – RB Rail or we/our) task and aim is to implement new railway infrastructure project, which would integrate Baltic countries into the European railway network (hereafter – Project). In order to provide the implementation of Project and regulate the process, RB Rail is required to process partner, independent expert, subcontractor and other party personal data. Meaning that RB Rail function implementation inevitably is associated with personal data collection, structurisation, storage etc personal data process types, for example, in order to provide implementation of the Project, public procurement procedures are being organised and, for RB Rail to adequately to assess submitted offers, we are required to process personal data which are related to offer submitters and identities of independent experts, qualification, contact information etc.
RB Rail informs that according to General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council), RB Rail is a controller in those cases when RB Rail has decided why and how Your personal data are to be processed.
2. Aim of RB Rail privacy policy
The aim of this privacy policy is to inform You about your rights and why RB Rail uses Your personal information, i.e., personal data as clear and understandable as possible.
RB Rail explains that personal data is any kind of information that can be used to identify private individual. RB Rail performs any required measure to ensure that Your personal data are safe and their processing is performed according to applicable personal data protection implementation legislation. RB Rail commits to protect Your personal information and ensure confidentiality in all processes supervised by RB Rail.
It is important for RB Rail to provide transparency and visibility while processing Your personal data, therefore RB Rail hereafter in this privacy policy indicates possible purposes and legal grounds for processing of Your personal data. This privacy policy allows you to learn what kind of Your personal data RB Rail may collect and how RB Rail will use them. Additionally, this privacy policy contains information regarding Your rights and how can you contact RB Rail in order to receive additional information about Your personal data processing and aspects of how You can exercise Your rights.
RB Rail might require updating the privacy policy, however RB Rail homepage https://www.railbaltica.org/lv/ will always publish latest privacy policy version, which will be available to everyone.
3. What kind of personal data RB Rail process?
In order to provide RB Rail function implementation, we may require processing Your personal data, for example, Your personal data processing may be conducted for these reasons:
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PURPOSE |
PERSONAL DATA CATEGORIES |
LEGAL GROUND |
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Communication provision: enquiry, suggestion, complaint and other information collection and processing in order to prepare answers and provide communication with addressee/submitter. Communication may be done through e-mail, mail, phone or in person (largely depends on the method of your communication with RB Rail). |
Name, surname, contact information, other personal information included in enquiry, suggestion or complaint. |
Data subject`s consent – person actively submits aforementioned information to RB Rail.
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Different document coordination: Mainly, according to laws and regulations, it is necessary to coordinate technical solutions and documents with private individuals during Project implementation. |
Name, surname, contact information, address, data regarding ownership, other personal information related to achievement of certain purpose. |
Mainly, Personal data processing is necessary in order for controller (us) to complete legal responsibilities, which are stipulated in laws and regulations related to construction. In certain cases, such processing may be justified also with RB Rail legitimate interest. |
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Sanction check: According to International and Republic of Latvia national sanction laws, RB Rail has a responsibility to conform and implement international and national sanctions. Additionally, it means, that RB Rail needs to conduct background check of its partners to ensure there are no international or national sanctions against certain person. |
Name, surname, birth data, personal identification number and other data which allows to identify certain person. |
Personal data processing is necessary in order for controller (us) to complete legal responsibilities, which are stipulated in laws and regulations related sanction implementation and supervision. |
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Record keeping organisation: documentation, inbox and outbox, contract etc. recording and storage. |
Documentation, correspondence, contracts which may include personal data, for example, contact information, birth data, name, surname etc. |
Depending on documentation type, it can be stored in order to implement its legitimate interests in court or to conform to laws and regulations. |
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Seminar, event, hackathon etc.: ensuring of different RB Rail organised or supported events. If the pictures or records are taken during the event, you will be additionally informed. |
Depending on event type, application can include certain personal data, for example, name, surname, birth data, contact information, information regarding represented organisation etc. It is possible, that during the event pictures or video recordings may be taken. |
Legitimate interest – informing the public regarding RB Rail operations and RB Rail recognition facilitation. |
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Posts about news: for marketing and public information purposes there may be posts regarding events, seminars and activities organised or sponsored by RB Rail. Posts are published on RB Rail homepage and/or social networks, for example, Facebook. |
Posts prepared by RB Rail may contain pictures, video records, names, surnames etc of event participants and/or visitors. |
Legitimate interest – informing the public regarding RB Rail operations and RB Rail recognition facilitation. |
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Contests: for marketing and public information purposes contests may be organised, results of which are published |
For example, contest participant and/or winner pictures, names, surnames, and other information according to contest regulation/rules |
Participant consent when participating in the said contest. |
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Commercial announcements in order to inform about our latest news, which are related to our operations. |
E-mail, name, surname, data regarding company You represent and Your current position. |
Consent. You may unsubscribe from our commercial news at any time, by clicking on the link in the e-mail or writing to us on [email protected] . |
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For staff management purposes: staff selection process organisation and provision, employment relationship establishment etc. See more: Personal data processing information to applicants |
Name, surname, experience, education, and other information included in CV or application letter. |
During selection process – data subject consent – person actively submits aforementioned information to RB Rail. During employment relationship – according to employment contract and laws and regulations. |
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Video surveillance: RB Rail conducts video surveillance by processing data subject personal data during their time on RB Rail supervised territory or premises in order to prevent, discover and retain evidence regarding criminal activity against property. In places, where the video surveillance is being conducted, RB Rail has set up warning signs regarding video surveillance. |
Video records. |
RB Rail legal interest of property protection and legal interest protection in court. |
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Procurements: in order to provide RB Rail operations, public procurement is of significant importance because it assists in selection of partners in open, transparent, adequate and indiscriminate way by avoiding conflict of interests, at the same time ensuring efficient use of assets. RB Rail cooperates with product, service, and construction work suppliers by conforming to free competition and fair treatment principles. More about our policy here. RB Rail provides electronic access to procurement plans and purchase documents by providing information exchange with suppliers and offer submittal in Electronic procurement system – https://www.eis.gov.lv/EIS/ |
Information about candidate’s employees (name, surname, work experience, relevant education etc), which proves candidate`s suitability to procurement requirements. |
Contract closing and implementation with data subject, as well as legal responsibility completion mentioned in Public procurement law and other laws and regulations related to public procurements. |
4. To whom Your personal data may be submitted?
Your personal data may be submitted to:
A. Service providers and partners
In order to complete our responsibilities and provide Project implementation and supervision, we may be required to provide information and Your personal data to our partners.
We carefully check all service providers, which process Your personal data on behalf of us. We assess whether partners (personal data processors) use suitable security measures in order to ensure that Your personal data processing would be conducted according to our aims, instructions and applicable laws and regulations. These companies do not have a right to use Your personal data for other purposes except for our defined tasks.
If you require information regarding our partners, please contact RB Rail.
B. Authorities, government, and municipal institutions
In order to abide the law, we may submit Your personal data to authorities (for example, police) as well as to government and municipal institutions by their request. We may also submit your Personal data to authorities (for example, courts) as well as government and municipal institutions in order to protect our legal interests by preparing, submitting and protecting our legal claims.
In addition to aforementioned, we would like to emphasise, that Your personal data are not processed in countries outside European Union or European Economic Area.
5. Which sources do RB Rail obtain personal data from?
There are several ways how RB Rail may obtain Your personal data. The most common are the following:
A. RB Rail may obtain Your personal data directly from You as data subject, for example:
- by receiving and revising Your enquiries, suggestions, applications and complaints;
- with Your consent we collect Your personal data during informative seminars, conferences, discussions, “hackathons” etc.
B. Personal data may be created during different processes, for example:
- personal data are created by performing actions necessary for Project implementation;
- personal data are created when you visit RB Rail premises (during video surveillance);
- personal data are created when you use cookies, when visiting RB Rail AS webpage.
C. Your personal data may be received from our partners, if there is a legitimate purpose and legal grounds, for example:
- in cases, when our partner has indicated You as a contact.
D. Personal data are obtained from public and private registries, for example:
- RB Rail in certain cases can obtain data from public registries or databases, for example, Land Register.
6. How long is Your personal data stored for?
Personal data is stored until:
- responsibilities stipulated by laws and regulations are resolved (for example, when completing accounting requirement stipulated by law);
- if the processing is conducted based on consent, personal data are processed while consent is applicable and not revoked;
- data processing purpose is fulfilled.
Longer personal data storage time is allowed to conform to legal stipulations regarding document or information storage minimal duration or to protect RB Rai legal interests, for example, during legal proceedings.
Video surveillance records are stored for no longer than 30 days. Records are instantly deleted chronologically from the moment of record. Certain records can be stored for a longer period of time, if it is necessary for certain purposes, for example, investigation of incidents or crimes.
When there is no more reason to store personal data, RB Rail will safely delete Your personal data or render them inaccessible (archiving) or unidentifiable so they could not be connected to You.
7. How will RB Rail protect Your personal data?
RB Rail ensures, regularly revises, and improves security measures in order to protect Your personal data from unsanctioned access, accidental loss, disclosure or destruction. In order to implement that, RB Rail uses latest technologies, technical and organisational regulations, including, firewalls, antivirus software and encryption.
However, RB Rail recommends for You to abide by general device and internet usage safety rules, as well as Your private data (especially identification document) protection and storage requirements. RB Rail is not responsible for unsanctioned access to Your personal data and/or data loss if it occurred because of Your fault or neglect.
In case of Your personal data security incident, if it will cause high risk to Your rights and freedoms, we will inform you immediately, if possible, or information will be published on our website or by any other possible means.
8. Your rights regarding personal data protection
Laws and regulations provide you with several rights on how you can affect processing of Your personal data. In order to implement these rights, please, submit to RB Rail written application: a) in person at RB Rail premises (passport or ID required); or b) sending application with secure electronic signature and time stamp to [email protected].
After receiving application, RB Rail will identify, that is, ensure, that You are the same person mentioned in application and will respond in 30 days.
As a data subject You are entitled to following rights:
A. Right to access Your personal data
You have a right to request confirmation that RB Rail processes Your personal data. In case of positive answer, You are entitled to request information regarding Your processed data.
B. Right to edit personal data
If you think that Your information, which is under RB Rail supervision, is incorrect or incomplete, You have a right to ask RB Rail to correct it.
C. Right to revoke consent
Since RB Rail processes Your personal data on basis of your consent, You have a right to revoke Your consent for personal data processing whenever You see fit. In such case RB Rail will cease to process Your personal data for the purpose you gave your consent. Take it into account please, that revocation of consent will not give you right to contest the legality of data processing, which RB Rail has conducted before said revocation.
D. Right to request deletion of personal data
In certain circumstances You are entitled to request RB Rail to delete Your personal data. However, be reminded, that data deletion is not possible in cases when data processing is stipulated by laws and regulations. When data is no longer necessary for certain purpose implementation, RB Rail deletes them, archives or make them inaccessible/unidentifiable by any other means.
E. Right to request personal data processing limitation or object against data processing
In certain circumstances You are entitled to request RB Rail to limit Your personal data processing. However, be reminded, that data processing limitation is not possible in cases when data processing is stipulated by laws and regulations.
F. Right to data portability
In certain circumstances You are entitled to receive or submit Your personal data to other data supervisor. These rights concern only data, which You have submitted to RB Rail based on Your consent or agreement.
G. Right to turn to Data State Inspectorate
We highly value Your privacy and implore you to contact RB Rail, if You have any questions or uncertainties, however, if You believe that Your personal data are processed in improper way, You are entitled to turn to Data State inspectorate. If you are not satisfied with received answer, You have a right to file a complaint to Data State inspectorate (http://www.dvi.gov.lv/lv/funkcijas/kontaktinformacija/)
9. Who to contact in case You have any questions?
If you have any questions regarding Your personal data processing conducted by RB Rail, please, contact us. When sending an e-mail, in the e-mail subject field indicate that enquiry is related to Your personal data processing.
RB Rail contact information:
RB Rail AS
Reg. No. 40103845025
Legal address: Satekles iela 2B, Riga, LV-1050, Latvia
e-mail: [email protected]
If you want to send information directly to RB Rail data protection specialist, please send this e-mail to this address, indicating, that this e-mail is addressed directly to RB Rail data protection specialist: [email protected]