Latviski PERSONAL DATA PROTECTION
Privacy Policy for Order & Collect
This privacy policy (the “Privacy Policy”) explains how AS "Riga Airport Commercial Development", Latvian registration number: 40103345497 (“Company”, “we”or “us”) uses your (the “User”,“you”, “your”) personal data within Order & Collect services (the “Services”) managed through https://atudutyfree.lv/website (the “Website”).
This Privacy Policy applies to all the Users of the Website and our Services.
By using or interacting with any of the Services provided by Company under the Website, you confirm that you have read and understood all of the provisions stated herein.
This Privacy Policy governs the processing of your personal data performed by Company starting from the moment where Company collects your personal data.
If you are the User of Services for the purposes and within the scope of this Privacy Policy, we are the controller of your personal data. You can contact us using the following information:
Name: AS "Riga Airport Commercial Development"
Address: Mārupes nov., Mārupes pag., Lidosta "Rīga", "Lidosta "Rīga" 10/1", LV-1053
E-mail address: ATURIXCustomerservice@atu.com.tr
Please refer to our TERMS AND CONDITIONS OF THE ONLINE PLATFORM to become acquainted with the terms of using our Website and Services.
Personal Data, Purposes and Basis for Processing of Data, Retention Term, and Recipients
Company as Controller
Personal data is information related to an identifiable or identified natural person. If you are a natural person, the following list shows the type of personal data that we collect about you, as well as the purposes and basis for processing of your personal data, the retention term and the recipients of your personal data:
|
Purposes for processing of data |
Personal data |
Basis for processing of data |
Retention term |
|
Ordering goods for using the Services |
In all of the cases: name, surname, e-mail address, phone number, IP, flight information, reservation note, ordered product list, ID or passport number, boarding pass data. If User has a membership profile, we also process information on the User’s age. |
A contract concluded with you and steps necessary to enter into such contract. |
Up to 10 years after the order has been paid. If the order has not been paid and collected, we retain the personal data for up to 5 years. |
|
User membership registration and authentication to use our Website membership profile. |
Name, surname, e-mail address, phone number, age. |
A contract concluded with you and steps necessary to enter into such contract. |
For the duration of the use of your membership account on our Website. If you choose to stop using our Website and/or Services, for example, by deactivating your account, then your personal data can be stored for the period of up to 10 years after the termination of our and your relationship. |
|
Online security |
IP, name, surname, e-mail address, phone number, age. |
The legitimate interest of Company in ensuring the security and protection of the information held by Company. |
For the duration of the use of your membership account on our Website. If you choose to stop using our Website and/or Services, for example, by deactivating your account, then your personal data can be stored for the period of up to 10 years after the termination of our and your relationship. |
|
Communicating and providing additional information that may be of interest to you about our Services and Website. Providing our advertisements and other our marketing materials to you through the Website, third-party websites and applications, e-mail messages, text messages, or other methods of communication. [1] |
Name, surname, e-mail address, browsing history, information shared to the Website and Services, phone number. |
For existing customers with regards to e-mail communication only: our legitimate interest to ensure direct marketing to our existing customer base, including e-mail and newsletter marketing. In all other cases: your consent expressed by checking a consent box. |
Until the legitimate interests and related purposes described in this Privacy Policy are present and are not overridden by your interests or fundamental rights and freedoms. Until you object to the processing of your personal data or revoke your consent. |
|
Operating and improving our Services and Website as well as performing analytics to improve Website’s functions. |
Name, surname, e-mail address, browsing history, uploads and information shared to the Website and Services, phone number, IP. |
Legitimate interests of Company - business development, development of the Services and Website as well as financial, legal and security interests. Your consent for using cookies. |
Until the legitimate interests and related purposes described in this Privacy Policy are present and are not overridden by your interests or fundamental rights and freedoms. Until you revoke your consent or object to the processing of your personal data. |
|
Fulfilling requests of the Users related to our Services and Website and providing customer support. Sending you reminders, technical notices, updates, security alerts and support and administrative messages. |
Name, surname, e-mail address, browsing history, uploads and information shared to the Website and Services, phone number, IP. |
Legitimate interests of Company to comply with the requests of the Users, ensure that Services and Website fulfil their functions and are used in accordance with the applicable laws and terms. |
Until the legitimate interests and related purposes described in this Privacy Policy are present and are not overridden by your interests or fundamental rights and freedoms. |
|
Complying with the statutory requirements, which may include keeping or otherwise processing of your personal data (for example, for accounting, tax, anti-money laundering, security, fraud prevention purposes). |
Name, surname, ID or passport number, boarding pass data, e-mail address, browsing history, picture, videorecords, payment details (if you visit our stores), uploads and information shared to the Website and Services, phone number, IP. |
Statutory requirements. Legitimate interests of Company to ensure proper business administration and keep records for compliance purposes. |
Within such time as is required to meet the requirements of the applicable law (generally during the use of personal data, as well as up to an additional 10 years thereafter depending on the type of accounting documentation and the corresponding legislation). |
|
Providing your personal data to corresponding authorities subject to specific statutory requirements which we are obliged to comply with (e.g. tax authorities, criminal investigation authorities). |
Any of the aforementioned personal data. |
Statutory requirements - a request from authorities based on the statutory requirement to provide personal data. Legitimate interest of Company to comply with statutory requirements and protect itself against potential legal and reputation-related risks (e.g. as penalties). |
Within such time as is required to meet the requirements of the applicable law depending on the type of personal data referred above. If your personal data is involved in any law-regulated process, we will keep the personal data as long as necessary for us to comply with the legal requirements or to keep evidence for our interest. |
|
For settling any conflict that may arise between Company, Users or clients. |
Any of the aforementioned personal data. |
Legitimate interest of Company to protect its position in the corresponding conflicts or litigation. |
Within such time as there is risk of conflict or litigation, while the conflict or litigation are in process and up to 10 years after their termination. |
[1] Please note that in certain cases depending on the applicable law we can send you marketing e-mails also without your consent.
Company may provide any of the aforementioned personal data to the following recipients:
- our services providers and partners who can access your personal data to help us fulfil the aforementioned personal data processing purposes such as data storage, communication, delivery, IT, marketing, security, legal, accounting and other relevant services providers;
- group companies – for managing the Services;
- airports – for complying with applicable security provisions;
- municipalities and/or state authorities if required under the applicable law.
Transfer of Personal Data Outside the European Union
Company may process your personal data outside the European Union only subject to the introduction of the appropriate guarantees provided in the applicable laws. For example, we may transfer your personal data based on the adequacy decision of the European Commission (as described in Article 45 of the EU GDPR), standard data protection clauses (as described in Article 46 of the EU GDPR) elaborated by the European Commission or supervisory authorities, or by using other possible safeguards and derogations (as described by Article 49 of the EU GDPR) where it is allowed by the applicable laws. You may receive the necessary copies of them by addressing us using the contact information indicated in this Privacy Policy.
Access to Personal Data and Your Other Rights
You have the right to:
- access your personal data;
- receive the information on the personal data processing carried out by Company as set forth in applicable laws;
- request a copy of your personal data that we process;
- request rectification of your personal data;
- request erasure of your personal data;
- request restriction of processing or object to processing of your personal data;
- lodge a complaint with a supervisory authority;
- withdraw your consent to processing of your personal data at any time by informing us by e-mail:ATURIXCustomerservice@atu.com.trif the personal data processing is based on your consent as indicated above;
- data portability - the right to receive your personal data in a structured, commonly used and machine-readable format and transmit those data to another Controller without hindrance from us.
Withdrawal of consent will not affect the lawfulness of processing done before the withdrawal, however, it may impact your further use of our Website and Services.
Please note that exercising data protection rights might be subject to certain exceptions.
Cookies and Related Technologies
When you use the Website and our Services, we collect certain information by automated or electronic means, including through cookies and similar tools.
The information from cookies and related technologies is stored in web server logs and also in web cookies kept on your computers or mobile devices, which are then transmitted back to our Website by your computer or mobile device.
In order to use some of cookies or similar technologies, we need your consent. If you do not provide your consent for using the cookies and related technologies, please note that we might not be able to provide you with certain Services and functionalities of the Website.
We use the following types of cookies:
- Necessary (or also required, technical) cookies – cookies without which a website or application will not be able to function technically, cookies related to ensuring security, cookies necessary for processing payments and ensuring authorization process, cookies used for animation, video and audio on the web page.
- Preferences (or also functional) cookies - cookies that store information about the user’s choices on the website such as the preferred language, region, username and password for automatic log-in.
- Analytical (or also statistics, performance) cookies - cookies that provide a website with data on how the user interacts with the website (how often the user visits the website, which pages the user visits, which links the user clicks on, etc.).
- Marketing (or also advertising) cookies - cookies stored for optimizing advertising and for targeted advertising purposes.
Your consent is not required for using necessary and preferences cookies.
Below you can find a more detailed list of the cookies used:
|
Name |
Purpose |
Provider |
Term |
|
Necessary |
|||
|
poi__user_cookie |
The cookie is used to enable cart functionality This cookie is used for basket transactions of the same user who visits at different times. |
ATU |
6 months |
|
poi__store_id |
This cookie is used to automatically select the last store the user opened. |
ATU |
6 months |
|
poi__cookie_prefs |
This cookie is used to store user cookie preferences. |
ATU |
6 months |
|
PHPSESSID |
The cookie is used to establish a user session and to pass state data via a temporary cookie across pages. |
ATU |
Session |
|
Analytical cookies |
|||
|
_ga, _ga_xxxxxx |
These cookies’ name is associated with Google Analytics. These cookies are used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. |
|
1 year |
If you want to decline analytical and/or marketing cookies or change your cookie preferences, please use the following link: [link].
Some of the cookies can lead to the transfer of your personal data outside of the European Union. This takes place only subject to the introduction of the appropriate guarantees provided in the applicable laws. For example, we may transfer your personal data based on the adequacy decision of the European Commission (as described in Article 45 of the EU GDPR), standard data protection clauses (as described in Article 46 of the EU GDPR) elaborated by the European Commission or supervisory authorities, or by using other possible safeguards and derogations (as described by Article 49 of the EU GDPR) where it is allowed by the applicable laws. You may receive the necessary copies of them by addressing us using the contact information indicated in this Privacy Policy.
Company may also use cookies for profiling purposes. For further information, please see the next section.
Automated Decision-Making, Profiling and Cookies
We may use automated decision-making with respect to your personal data for the development of our business activities, for marketing purposes, including for personalised marketing. We may analyse the data relating to your visit and use of the Website and Services in order to personalise advertisements in accordance with your habits and interests. This analysis can be generalised or carried out with the help of specific algorithms depending on the chosen marketing solution.
For profiling purposes, we may use web analytics services such as Google Analytics, which collect information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our Website (such as the pages you visit and what you click on). The information regarding our use of cookies and related technologies is available in our cookie policy as stated in this document. By automatically analysing and categorising the aforementioned information, we are able to gain a better understanding of our Users’ needs and desires (in terms of the content of our website and the offered Services), how to improve the Website and how to advertise and market our Services.
Modification of the Privacy Policy
Company may revise the terms and conditions of this Privacy Policy.
Company will notify the registered Users of the Website about substantial amendments to this Privacy Policy by communicating it using the contact information provided by such Users to Company through Company’s registration forms.
If you are a non-registered User of the Website or Services, we invite you to check the current version of the Privacy Policy each time you use the Website and/ or Services as Company to stay updated.
By using the Website and the Services, you are agreeing to be bound by the current version of this Privacy Policy.
Governing Law
This Privacy Policy is governed by the laws of Latvia. Any disputes arising from this Privacy Policy shall be governed by the laws of Latvia.
Version 1.0
Updated: 17.11.2023