Privacy Policy
1. General provisions
1.1. SIA Code is Poetry, Reg. No. 40103499607, registered address: Kapseļu iela 7-1, Rīga, LV-1046 (hereinafter – “Ezuro”), collects, processes, and stores personal data obtained from its customers and individuals who visit the mobile application or website (hereinafter – the “User”).
1.2. Personal data means any information relating to an identified or identifiable natural person, i.e., the User. Processing means any operation performed on personal data, such as collection, recording, modification, use, access, erasure, or destruction.
1.3. Ezuro complies with the data processing principles provided for in applicable legislation and ensures that personal data are processed lawfully, fairly, securely, and in accordance with the requirements of the law.
2. Collection, Processing, and Storage of Personal Data
2.1. Ezuro primarily collects, processes, and stores personally identifiable information through its website and mobile application.
2.2. By visiting and using the website or the services provided therein, the User agrees that any information provided may be used and managed for the purposes defined in this Privacy Policy.
2.3. The User is responsible for ensuring that the personal data submitted are accurate, correct, and complete. The intentional submission of false information constitutes a violation of this Privacy Policy. The User is obliged to notify Ezuro without undue delay of any changes in the submitted personal data.
2.4. Ezuro is not responsible for any losses incurred by the User or third parties as a result of inaccurate or false data submitted by the User.
3. Processing of Customer Personal Data
3.1. Ezuro may process the following categories of personal data:
3.1.1. Name and surname;
3.1.2. Date of birth;
3.1.3. Contact information (e-mail and/or phone number);
3.1.4. Any other information provided while purchasing and/or using our provided services.
3.2. In addition, Ezuro is entitled to verify the accuracy of submitted data using publicly available registers.
3.3. The legal basis for personal data processing is Article 6(1) (a), (b), (c), and (f) of the General Data Protection Regulation:
(a) the User has given consent to the processing of their personal data for one or more specific purposes;
(b) processing is necessary for the performance of a contract to which Ezuro is a party or in order to take steps at the User’s request prior to entering into a contract;
(c) processing is necessary for compliance with a legal obligation to which Ezuro is subject;
(f) processing is necessary for the purposes of the legitimate interests pursued by Ezuro or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the User that require personal data protection, in particular where the User is a child.
3.4. Ezuro stores and processes User personal data as long as at least one of the following conditions applies:
3.4.1. The personal data are necessary for the purposes for which they were collected;
3.4.2. While Ezuro and/or the User may pursue their legitimate interests in accordance with the procedures laid down in regulatory enactments, for example, to submit objections or bring claims in court;
3.4.3. While there is a legal obligation to retain the data, for example, under the Accounting Act;
3.4.4. While the User’s consent to the relevant data processing is valid, unless another lawful basis for processing exists.
3.4.5. When the above conditions cease to apply, the User’s personal data retention period also ends, and all relevant personal data are permanently deleted from Ezuro’s systems and electronic and/or paper documents containing such data, or the data are anonymized.
3.5. To fulfill its obligations towards the User, Ezuro has the right to transfer the User’s personal data to cooperation partners and processors who carry out necessary data processing on behalf of Ezuro, such as accountants, courier services, etc. Ezuro acts as the controller of personal data. Upon request, User data may also be transferred to state authorities and law enforcement bodies where necessary to protect Ezuro’s legal interests in preparing, submitting, and defending legal claims.
3.6. In processing and storing personal data, Ezuro implements appropriate organizational and technical measures to protect personal data against accidental or unlawful destruction, alteration, disclosure, or any other unlawful processing.
4. User Rights
4.1. In accordance with the General Data Protection Regulation and the laws of the Republic of Latvia, the User has the following rights:
4.1.1. To access their personal data, receive information on its processing, obtain a copy of their personal data in electronic format, and request the transfer of such data to another controller (data portability);
4.1.2. To request the rectification of inaccurate, incorrect, or incomplete personal data;
4.1.3. To request the erasure of personal data (“the right to be forgotten”), except where the law requires retention;
4.1.4. To withdraw previously given consent to the processing of personal data;
4.1.5. To request restriction of processing, i.e., to require Ezuro to temporarily suspend processing of all User personal data;
4.1.6. To lodge a complaint with the Data State Inspectorate.
4.1.7. Requests regarding the exercise of User rights can be submitted by filling out a form in person or by sending an electronic request to Ezuro at [email protected].
5. Final Provisions
5.1. This Privacy Policy has been drafted in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation), as well as the applicable laws of the Republic of Latvia and the European Union.
5.2. Ezuro reserves the right to amend or supplement this Privacy Policy at any time without prior notice. Amendments take effect upon their publication on Ezuro.com.