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Terms & Conditions
Privacy Policy
Manager and contact details
Scope of the document
Purposes of personal data processing
Legal basis for the processing of personal data
Processing of personal data
Protection of personal data
Categories of recipients of personal data
Access by third country entities to personal data
Duration of storage of personal data
Access to personal data and other Customer rights
Customer's consent to data processing and right of withdrawal
Communication with the Customer
Commercial communications
Website visits and cookie processing
Different rules
The purpose of this Privacy Policy is to provide an individual - a customer of the Aeternum Libertarian Foundation SIA - with information about the purpose, extent, protection, processing time and rights of the data subject at the time of data collection and processing of the customer's personal data.
Manager and contact details
1. The controller of personal data processing is Company Name: Aeternum Libertarian Foundation SIA (hereinafter referred to as ALF), registration no. 40203100595, legal address Akadēmijas laukums 1-1, Rīga, Latvia, LV-1050 
2.ALF's contact information on personal data processing issues is:
Using this contact information or contacting ALF's legal address, you may ask about the processing of personal data. A claim for the exercise of one's rights may be made in accordance with paragraph 24.
Scope of the document
3. Personal data means any information relating to an identified or identifiable natural person. Definitions, explanations and categories of personal data are listed here.
4. The privacy policy applies to the protection of privacy and personal data regarding:
*natural persons - customers, subscribers and other users of the ALF service (including potential, past and present), as well as third parties who receive or transmit any information to ALF in connection with the provision of services to a natural person (subscriber, customer, user) including contacts, payers, etc.);
* ALF visitors to shops, offices and other premises, including those subject to video surveillance;
* Visitors of homepages and mobile applications maintained by ALF, and callers to the ALF Contact Center telephones (hereinafter - Customers).
5. ALF respects the privacy of its Customers and protects its personal data, respects the Customers' right to the lawfulness of personal data processing in accordance with applicable law - Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 the free movement of such data (the Regulation) and other applicable legislation on privacy and data processing.
6. The Privacy Policy applies to the processing of data, irrespective of the form and / or medium in which the Customer provides personal data (on ALF's website, mobile applications, self-service portal, paper or telephone) and in what corporate systems or paper form.
7. Additional specific terms may be set for specific types of data processing (such as cookie processing, etc.), environment, purposes, which the Customer is informed at the time of submitting the relevant data to ALF.
Purposes of personal data processing
8. ALF processes personal data for the following purposes:
* For the provision of services and goods:
- customer identification;
- preparing, concluding and proving the conclusion of the contract;
- the supply of goods and services (for the performance of contractual obligations);
- provision / maintenance of services;
- guarantees of compliance with obligations;
- improvement of goods and services, development of new goods and services;
- promoting, promoting and disseminating the service;
- customer service;
- processing and processing of applications and objections;
- customer retention, loyalty building, satisfaction measurement;
- administration of settlements;
- creditworthiness assessment, credit monitoring;
- debt recovery and recovery;
- maintaining and improving websites and mobile applications.
* Business planning and analytics:
- statistics and business analysis - planning and accounting - measuring efficiency - ensuring data quality - conducting market and public opinion research; - preparing reports - conducting customer surveys - within risk management activities.
* Information, information systems and enterprise security.
* Provision of information to public administration institutions and operational subjects in the cases and to the extent prescribed by external regulatory enactments.
* For other specific purposes as notified to the Customer at the time he or she provides the relevant data to ALF.
Legal basis for the processing of personal data
9. ALF processes the Customer's personal data on the following legal grounds:
* for the conclusion and performance of the contract - to enter into the contract upon the Client's application and ensure its execution;
* for regulatory purposes - to fulfill an obligation imposed by ALF binding external laws and regulations;
* with the consent of the Customer, the data subject;
* legitimate interests - to realize the legitimate interests of ALF arising from obligations existing between ALF and the Client or from the contract or law;
* for the vital interests of the data subject or other natural person - to ensure the physical and property security of ALF's employees, Customers and visitors.
10. ALF's legitimate interests are:
* to conduct business;
* provide electronic communications services;
* verify the Customer's identity before entering into the contract;
* ensure fulfillment of contractual obligations;
* Avoid unreasonable financial risks to your business (including credit risk assessment prior to the sale of goods and services and during the performance of the contract);
* to keep Customer's applications and applications for the purchase of goods and services, other applications and applications, notes thereon, including those made in writing or orally, by calling the call centers, on websites and through the self-service portal;
* to conduct negotiations with the Customer on the provision, maintenance and billing of the services in order to control the quality of customer service;
* negotiate with Customer Records to arrange for the fulfillment of contractual obligations to the Service;
* to negotiate with the Customer a record of oral agreement to prove the fact of the conclusion of the contract;
* analyze, develop and implement improvements to ALF websites, websites and mobile applications;
* administer the Customer's account on ALF's websites, web sites and mobile applications;
* to carry out actions for retaining Customers;
* segment the customer database for more efficient provision of services;
* design and develop goods and services;
* promote your goods and services;
* send other reports on the progress of the contract and any events relevant to the performance of the contract, as well as conduct customer surveys on the goods and services and their experience of using them (NPS);
* to ensure the maintenance and development of electronic communications networks;
* maintaining and developing the communication network;
* monitor the operation of the communication network for technical problems and to prevent and remedy illegal activities;
* prevent fraud;
* provide corporate governance, financial and business accounting and analytics;
* Ensure effective business management processes;
* Effectiveness of service delivery and sales and delivery of goods;
* ensuring and improving the quality of services;
* administer payments;
* administer outstanding payments;
* apply to public administration and investigative authorities and the courts to protect their legal interests;
* inform the public about their activities.
Processing of personal data
11. ALF processes Customer Data using state-of-the-art technology, taking into account existing privacy risks and ALF's reasonably available organizational, financial, and technical resources.
12. ALF may make automated decisions regarding the Customer. The Customer shall be notified separately of such ALF activities in accordance with the laws and regulations. The Customer may object to making automated decisions in accordance with the law, however, knowing that in some cases this may limit the Customer's right to use certain potential options available to him (for example, to receive commercial offers).
13. Automated decision making that has legal consequences for the Client (eg approval or rejection of the Client's application) may only be made during the conclusion or performance of a contract between ALF and the Client based on the Client's express consent or in cases specified by external law.
14. In order to ensure the quality and expediency of fulfilling its contractual obligations with the Customer, ALF may authorize ALF Group companies, their affiliates, to perform certain supplies or provision of services, such as commissioning services, invoicing and the like. If ALF Group companies or affiliates process Customer's personal data held by ALF in the performance of these tasks, the ALF group companies or affiliates concerned shall be considered ALF data processing operators (processors) and ALF shall have the right to assign ALF group companies and affiliates the Customer's required personal data to the extent necessary to perform these activities.
15. ALF Partners and ALF Group companies (as data controllers) will enforce personal data processing and protection requirements in accordance with ALF's requirements and laws, and will not use personal data for purposes other than to fulfill ALF's contractual obligations to the Customer.
Protection of personal data
16. ALF protects Customer Data using state-of-the-art technology, taking into account existing privacy risks and ALF's reasonably available organizational, financial, and technical resources, including the following security measures:
* encryption of data during transmission (SSL encryption);
* firewalls;
* Intrusion protection and detection programs;
* other protective measures according to the state of the art.
Categories of recipients of personal data
17. ALF will not disclose to third parties Customer's personal data or any information obtained during the provision of the Services and during the term of the Agreement, including information about electronic communications, content or other services received, except:
* if the third party in question must transfer the data within the framework of an existing contract in order to perform a function necessary for the performance of the contract or delegated by law (eg to a bank for settlement or provision of services such as electricity service ALF exchanges data with the distribution network operator is notified in the relevant service agreement);
* subject to the Customer's express and unambiguous consent;
* persons provided by external regulatory enactments upon their reasoned request, in the manner and to the extent prescribed by the external regulatory enactments;
* Protecting the legitimate interests of the ALF, for example in legal proceedings or other public authorities, against a person who has infringed the legitimate interests of the ALF, in cases specified by external law.
Access by third country entities to personal data
18. In individual cases, subject to regulatory requirements, ALF will have access to personal data by developers or service providers in third countries (ie countries outside the European Union and the European Economic Area) (transfer to third countries within the meaning of the Regulation) as data controllers.
19. In such cases, the Tet shall provide for statutory procedures to ensure a level of processing and protection of personal data equivalent to that provided by the Regulation.
Duration of storage of personal data
20. ALF shall store and process Customer's personal data as long as at least one of the following criteria is met:
* only for the duration of the contract with the Customer (including recordings of conversations leading to an oral contract / service request);
* the data are necessary for the purpose for which they were received;
* as long as the ALF or the Client can pursue their legitimate interests (for example, to lodge an objection or to sue or to sue) in accordance with the procedure prescribed by external regulatory enactments;
* As long as there is a legal obligation for one of the parties to keep the data (for example, according to the Accounting Law, company invoices must be kept for 5 years, etc.);
* as long as the Customer's consent to the relevant processing of personal data is in force, unless there is another legitimate basis for the processing.
After the circumstances referred to in this paragraph cease, the Customer's personal data shall be deleted. Audit records shall be kept for at least one year from the date of their completion in accordance with the provisions of regulatory enactments.
21. The record of the conversation with the Customer regarding the operation, maintenance and billing of the services based on the legitimate interests of ALF shall be kept for 6 (six) months after the date of recording the call and thereafter shall be deleted.
Access to personal data and other Customer rights
22. The Client has the right to receive information specified in regulatory enactments regarding the processing of his or her data. Most of the Customer's information is already posted on the self-service portal and on ALF web sites and applications used by the Customer to receive ALF Services and where the Customer can verify the accuracy of his / her data and, if necessary, manage it.
23. The Customer shall also have the right, in accordance with regulatory enactments, to request ALF's access to its personal data, as well as to require ALF to add, correct, or delete it, or to restrict processing with respect to Customer, or the right to object to the processing based on ALF's legitimate interests) as well as the right to data portability. This right shall be exercised insofar as the processing of data does not result from the obligations imposed on ALF by the applicable laws and regulations and in the public interest.
24. The Customer may submit a request for the exercise of his rights:
* by e-mail with a secure electronic signature;
* by logging in to the self-service portal
25. Upon receipt of the Customer's request for the exercise of its rights, ALF shall verify the Customer's identity, evaluate the request and execute it in accordance with regulatory enactments.
26. ALF shall send the reply to the Customer by e-mail to the contact address indicated by the Customer in a registered letter or self-service portal
27. ALF shall ensure compliance with data processing and protection requirements under applicable law and, in the event of Customer's objection, shall take all reasonable steps to resolve the objection. However, if this fails, the Customer shall have the right to approach the supervisory authority, the Data State Inspectorate.
Customer's consent to data processing and right of withdrawal
28. The Customer may consent to the processing of personal data based on consent (eg, analysis of data on the use of services, personalized advertising, etc.) by authorizing the self-service portal ALF service application forms, ALF service apps, ALF websites.
29. The Customer shall have the right at any time to revoke the consent to data processing in the same way as it is, ie by logging in to the self-service portal, ALF service apps, ALF websites.
30. The revocation of consent does not affect the processing of data during the period of the Client's consent.
31. Withdrawal of the consent may not interrupt the processing of data on other legal grounds.
Communication with the Customer
32. ALF shall communicate with the Customer using the contact information provided by the Customer (telephone number, e-mail address, mailing address, self-service portal  and other self-service accounts, as well as through application notifications).
33. ALF communicates on the performance of service obligations under the contract (eg reconciliation of service delivery or repair times, billing information, scheduled work, interruptions, changes in services, etc.).
Commercial communications
34. Communications regarding commercial communications for ALF and / or third party services and other communications not related to the provision of directly contracted services (such as customer surveys) shall be made by ALF in accordance with external regulations or with Customer's consent.
35. The ALF may also communicate using automated calling machines, including for commercial communications.
36. The Customer may give consent to receive commercial communications from ALF and / or its affiliates by logging in to the self-service portal, ALF service application forms, ALF service portals / apps, ALF and other websites (eg newsletter sign-up forms).
37. The Customer's consent to receive commercial communications is effective until revoked (even after the termination of the Service Agreement). The Customer may at any time opt out of receiving further commercial communications in any of the following ways:
* ticking the appropriate user profile on ALF's self-service portal;
* sending an email to ;
* Calling the  Contact Center 20272453;
* Changing notification settings for devices.
* using the automated option in the commercial communication to opt-out of receiving further notices by clicking on the opt-out link at the end of the relevant commercial notification (email).
38. ALF will stop sending commercial communications as soon as Customer's request is processed. Request processing depends on technological capabilities, which can take up to seven days.
39. By expressing their opinion in the surveys and leaving their contact information (email, phone), the Customer agrees that ALF may contact him regarding the Customer's rating using the contact information left by the Customer.
Website visits and cookie processing
40. ALF websites may use cookies. Cookies processing terms are available here.
41. ALF websites may include links to third party websites that have their own terms of use and personal data protection for which ALF is not responsible.
Different rules
42. ALF has the right to make additions to the Privacy Policy by making available to the Client an up-to-date version of it on his / her user profile at ALF self-service portal , as well as by placing it on the ALF homepage.
43. ALF maintains previous versions of the Privacy Policy and is available on the ALF website.
44. This Privacy Policy comes into force on 15 november 2019 and supersedes the previously approved Privacy Policy.