Albatross Spa Privacy Policy

The purpose of this Privacy Policy is to provide the client of Albatross SPA complex with information about the purpose, legal basis, scope, possible recipients, principles of protection and terms of processing, rights of data subjects, as well as the identity and contact details of the controller, and the processing of personal data by Albatross SPA Ltd, registration number: 40203382678, address: Albatrosa iela 18, Ķesterciems, Engures pagasts, Tukuma novads, LV-3113, (hereinafter – Albatross SPA).

Albatross SPA cares about your privacy and personal data security, respects your right to the protection of personal data and the lawfulness of processing in accordance with the General Data Protection Regulation 2016/679 (hereinafter – the Regulation), the Personal Data Processing Act, other applicable privacy and data processing legislation, as well as this Privacy Policy.

The Privacy Policy applies to the processing of personal data regardless of the form and/or medium in which you provide personal data (self-service portal www.albatrossresort.lv, paper, electronic, telephone) and in which systems it is processed.

Albatross SPA takes the necessary technical and organisational measures to ensure adequate security of personal data to protect your personal data from accidental disclosure, alteration or other unlawful processing.

1. Responsibility for the processing of personal data

SIA “Albatross SPA”
Single registration number: 40203382678
Legal address: 18 Albatrosa Street, Ķesterciems,
Engures pagasts, Tukuma novads, LV-3113
E-mail: info@albatross-spa.lv

You can ask a question about the processing of personal data by using this contact information or by contacting the registered office of SIA “Albatross SPA” or by using electronic means of communication with a written application signed in manuscript or with a secure electronic signature.
We will provide you with a reply within 30 calendar days of receipt of the request, if we are able to identify you.

2. What is personal data and how we process it

According to the General Data Protection Regulation 2016/679 (the Regulation), personal data means any information relating to an identified or identifiable natural person (data subject).

An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as that person’s name, identification number, location data, online identifier or to one or more factors specific to that natural person, such as physical, physiological, genetic, mental, economic, cultural or social identity, which describe that person and allow that person to be identified, directly or indirectly.

With regard to your personal data, Albatross SPA is the data controller, which determines the purposes and means of the processing of personal data.
Albatross SPA’s intention is to provide you with as much information as possible about Albatross SPA’s processing of your personal data so that, when you provide Albatross SPA with your personal data, you are aware of how it will be used.

The Albatross SPA Privacy Policy applies, for the protection of privacy and personal data, to:

• • Natural persons – customers, guests and other recipients of the services of Albatross SPA, including prospective, former and existing customers, as well as third parties connected with the provision of the services
  • Albatross SPA hotel, restaurant or spa and receives or transmits to Albatross SPA information such as contacts, payers, etc;
  • Visitors to the Albatross SPA hotel, restaurant and spa, including those under video surveillance;
  • Visitors to the websites maintained by Albatross SPA.

3. Purpose of the processing of personal data

3.1 Service Delivery:

• • to identify the client;
  • for the preparation and conclusion of the contract
  • to fulfil their contractual obligations
  • for the operation and maintenance of services
  • improving services, developing new services
  • advertising and distribution of services, sales promotion or commercial purposes;
  • customer service
  • handling and processing objections and complaints
  • maintaining cooperation, increasing customer loyalty, satisfaction surveys;
  • for the administration of settlements, including the provision of disbursements;
  • internal grouping of customers for additional bonuses, including discounts.

3.2 Business planning and analytics:

• • for statistical analysis
  • for business analysis
  • to maintain and improve business processes
  • for planning and accounting
  • to measure and improve efficiency
  • for data quality assurance
  • market and public opinion research;
  • for reporting purposes;
  • customer surveys to develop customer service levels and improve the services provided.

3.3 For the security of Albatross SPA property and persons by video surveillance:

• • to protect the property of Albatross SPA and third parties located on the premises and in the area of the Hotel, Restaurant and SPA,
  • ensure the safety of persons, prevent possible offences, record the commission of a crime, and monitor the progress and quality of service.
  • Video surveillance stores data for up to 7 days.
    After this period, Albatross SPA ensures the complete automatic deletion of the data, if the data has not been previously requested or no criminal offences or other security breaches have been detected.
    If the data have been previously requested from the competent state or local authorities or security breaches have been detected, the data shall be stored as necessary.

3.4 For other purposes:

• • to meet the requirements of binding laws and regulations;
  • for audit, compliance and operational purposes
  • for the provision of information to public administration bodies and subjects of operational activity in the cases and to the extent specified in external regulatory enactments;
  • for specific purposes, which Albatross SPA will inform data subjects about at the time the data subject provides the relevant personal data to Albatross SPA.

4. Legal basis for processing personal data

Albatross SPA Customer personal data is processed on the following legal grounds:

• • for the conclusion and performance of a contract – to conclude a contract at the Client’s request and to ensure its performance;
  • to comply with laws and regulations – to comply with an obligation imposed by external laws and regulations binding on Albaross SPA;
  • in accordance with the consent of the Client – data subject;
  • legitimate interests – to pursue the legitimate interests of Albatross SPA arising from the obligations between Albatross SPA and the Client or from the concluded contract or the law.
    Except where the interests of the Client as a data subject or the fundamental rights and freedoms which require the protection of personal data override the interests of Albatross SPA, in particular where the data subject is a child.

Albatross SPA as a data controller does not process the data of special categories of its customers.
The only exception to this may be if the processing is necessary to protect the vital interests of the client (e.g. due to a sudden deterioration of the client’s health, it is necessary to call an ambulance, and similar emergency situations).

5. Protection of personal data

Albatross SPA knows that customers provide personal data in good faith and count on it being monitored.
Therefore, Albatross SPA takes the security of your personal data with a high sense of responsibility.
Albatross SPA uses a variety of personal data storage, security technologies and procedures to protect your personal data from unlawful access, use or disclosure.

Albatross SPA protects Customer Data using modern technological capabilities, taking into account existing privacy risks and reasonably available organisational, financial and technical resources, including the following security measures:

• • Pseudonymisation of data where possible;
  • Firewalls;
  • Intrusion protection and detection programmes;
  • Antivirus software;
  • Other protection measures in line with the state of the art.

Albatross SPA provides, continuously reviews and improves security measures to protect customers’ personal data from unauthorised access, accidental loss, disclosure or destruction.

However, Albatross SPA recommends that clients comply with the general security rules for computer and internet use, as well as the requirements for the protection and storage of clients’ private data (in particular identity documents), and Albatross SPA will not be liable for unauthorised access to your personal data and/or data loss if this is due to the fault or negligence of the client.

6. Recipients of personal data

Albatross SPA uses third-party services to assist in the conduct and administration of its business.
These third parties include:

• • credit institutions, in connection with the settlements to be made;
  • our information technology and database maintenance and administration service providers;
  • cloud computing providers
  • providers of legal services, accounting and auditing services
  • debt collection companies, third parties through whom we send commercial and other communications and information.

In each specific case, Albatross SPA will only provide the Data Processor with the amount of your data that is necessary for the purpose and task in question.
The data is processed only for that purpose and task and is protected in accordance with the requirements of the Regulation and other applicable laws and regulations.
Your data is permanently deleted after the purpose or task has been achieved.

In addition to the above, Albatross SPA transfers your data to the persons provided for by external regulatory enactments, in the manner and to the extent provided for by the relevant regulatory enactment (e.g. to the State Revenue Service, law enforcement authorities, courts, etc.).

Albatross SPA may transfer your data to third parties, in the cases provided for by laws and regulations, for the protection of its legitimate interests (e.g., in court proceedings against a customer for debt collection, etc.).

Albatross SPA shall not disclose to third parties the Client’s personal data or any information obtained during the provision of the services and the performance of the contract, except:

• • where the third party is required to transfer the data within the framework of a contract in order to perform a function necessary for the performance of the contract or delegated by law (e.g. to a bank for settlement purposes);
  • subject to the Client’s express and unambiguous consent;
  • to the persons provided for in external normative acts upon their justified request, in the manner and to the extent provided for in external normative acts;
  • in the cases provided for in external regulatory enactments, as well as to protect the legitimate interests of Albatross SPA, e.g. by taking legal action against a person who has infringed the legitimate interests of Albatross SPA in court or before other public authorities.

Albatross SPA personal data cannot be accessed by developers or service providers in third countries (i.e. countries outside the European Union and the European Economic Area) in their capacity as a data processor (operator) (within the meaning of the Regulation – transfers to third countries).

7. Duration of storage of personal data

Albatross SPA stores your data for no longer than is necessary for the purposes of processing.
The data is kept for as long as:

• • the agreement or contract between us is valid, and as long as either party to the agreement or contract can exercise its legitimate interests (e.g. to submit claims and applications, to bring legal proceedings, etc.);
  • the processing is necessary to enable us to comply with legal obligations to which we are subject;
  • your consent to the processing of your personal data is valid, unless there is another lawful basis for processing your personal data.

Once the above circumstances cease to apply, your personal data will be permanently deleted.

8. Client’s rights

The Client has the right to receive the information required by the regulatory enactments in relation to the processing of his/her data, to verify the accuracy of his/her data and to correct them.

In accordance with the regulatory enactments, the Customer also has the right to request Albatross SPA access to his/her personal data, as well as to request their supplementation, correction or deletion, or restriction of processing in relation to the Customer, or the right to object to the processing (including the processing of personal data based on the legitimate interests of Albatross SPA), as well as the right to data portability.
These rights shall be exercised insofar as the processing of data does not result from obligations imposed on Albatross SPA by applicable laws and regulations and which are carried out in the public interest.

You have the right to obtain confirmation from Albatross SPA as to whether or not your data is being processed and, if it is being processed, to access your data and receive the following information about it:

• • the purposes of the processing;
  • categories of personal data;
  • recipients of personal data;
  • the duration of the retention of the personal data or the criteria for determining the duration of the retention;
  • the right to have your data rectified if it is inaccurate;

The right to have your data erased, and Albatross SPA will comply with this request if at least one of the following conditions exists:

• • the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • You withdraw your consent to the processing and there is no other lawful basis for processing;
  • where the processing is based on our legitimate interests or those of a third party, but there is no overriding legitimate ground for the processing;
  • You object to the processing of your data for direct marketing purposes;
  • if the data have been processed unlawfully;
  • to ensure compliance with a legal obligation imposed on us by law or regulation;
  • if your data was collected in connection with the provision of information society services.

You have the right to request that Albatross SPA restricts the processing of your data.
This request will be fulfilled if at least one of the following circumstances exists:

• • if you contest the accuracy of the data, for a period during which we can verify the accuracy of your data;
  • if the processing is unlawful but you object to the erasure of the data and instead request the restriction of the use of the data;
  • we no longer need your data, but you need it to assert, exercise or defend legal claims;
  • You have objected to the processing of your data on the basis of our legitimate interests or the legitimate interests of a third party, pending verification that our legitimate grounds do not override your legitimate grounds.

You have the right to object at any time, on grounds relating to your particular situation, to processing of your personal data based on our legitimate interests or those of a third party.
In such a case, we will no longer process your data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

If you believe that your personal data is being processed unlawfully, unreasonably or in any other way in breach of the Regulation or other laws and regulations, or if you have any doubts or questions about the processing of your personal data, please do not hesitate to contact Albatross SPA with a relevant application, request or complaint.
We will answer any questions you may have and rectify any mistakes, if any.

The customer may submit a request for the exercise of their rights:

• • in writing in person at Albatross SPA, upon presentation of an identity document;
  • by email, signed with a secure electronic signature;
  • Upon receipt of a Client’s request to exercise its rights, Albatross SPA shall verify the identity of the Client, assess the request and execute it in accordance with the laws and regulations.
  • Albatross SPA shall send the reply to the Customer by post to the contact address provided by the Customer by registered mail or by electronic mail if the application is received electronically.

If you believe that your personal data is being processed unlawfully, unreasonably or otherwise in breach of the Regulation or other laws or regulations, you have the right to lodge a complaint with the personal data supervisory authority of your place of residence.

9. Communication with the customer

Albatross SPA shall communicate with the Client using the contact details provided by the Client:

• • phone number;
  • email address;
  • Postal address.

Albatross SPA communicates on the basis of the concluded contract in order to:

• • Agreed delivery times
  • to specify the service, food or other information related to the provision of the service;
  • to inform you about changes in service provision or changes to a specific service;
  • find out about sending invoices and the information they contain

10. Commercial notices

Albatross SPA communicates commercial communications about Albatross SPA and third party services and other communications not directly related to the provision of contracted services (e.g. customer surveys) to Albatross SPA in accordance with external laws and regulations or if the customer has given his/her consent.

The Customer may give consent to receive commercial communications from Abatross SPA and its business partners on Abatross SPA and other websites by confirming his/her consent by signing up to receive new communications or by providing consent in a separate document.

The consent given by the Customer to receive commercial communications is valid until revoked (including after termination of the contract).
The Customer may opt-out of receiving further commercial communications at any time in any of the following ways:

• by sending an email to: info@albatross-spa.lv
• in person at Albatross SPA, address: 18 Albatrosa Street, Ķesterciems, Engure Parish, Tukums novads, LV-3113.
• using the automated opt-out option provided in the commercial communication by clicking on the unsubscribe link at the end of the commercial communication (email).

Albatross SPA shall cease sending commercial communications as soon as the Client’s request to withdraw consent to commercial communications has been processed.

11. How to contact us

You can contact us:

• in writing, by sending correspondence to: SIA Albatross SPA , Albatrosa iela 18, Ķesterciems,
  Engures pagasts, Tukuma novads, LV-3113;
• electronically via email: info@albatross-spa.lv
• By phone: +371 25776644