Complete Payement Systems
Privacy and Cookies Policies

Privacy Policy

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This privacy policy ("Privacy Policy") describes how cps.lv ("CPS", "we", "us") processes personal data in connection with the use of the website and the provision of services, and sets out the rights available to data subjects. CPS, as the Controller, will process the personal data received only for the purposes and in the ways set out in this Privacy Policy.

Below you can find detailed information about the types of personal data we collect about individuals and for what purposes, what we do with this data and how we process it. By accessing or using our website, you agree to the terms set out in our Privacy Policy and Cookie Policy. If you do not agree to the Privacy Policy, you must leave this website and stop using our services.

1. Introduction

1.1 The purpose of this Privacy Policy is to provide you with information about the processing of natural persons' data by CPS. The Privacy Policy applies to the processing of personal data of recipients of CPS services, as well as potential recipients of services, visitors to the website and business partners.

1.2 CPS processes personal data 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 and repealing Directive 95/46/EC ("General Data Protection Regulation"), as well as other regulatory provisions in the field of personal data protection.

1.3 In the Privacy Policy, the term CPS means the Limited Liability Company "Sofius", registered in the Republic of Latvia, registration No. 40103714293, registered office at 3-11 Nometņu Street, Riga, LV-1048, Latvia.

1.4 The terms "Personal Data", "Data Subject", "Processing", "Controller" and "Supervisory Authority" used in the Privacy Policy shall have the same meaning as set out in the General Data Protection Regulation.

2. What personal data do we process?

2.1 In the course of conducting its business, CPS receives various types of information from prospective and existing customers, website visitors and other persons who communicate with us. Some of this information is personal data in respect of which CPS is the Controller.

Personal data provided to CPS

2.2 Our existing and potential customers provide us with the following personal data:
- Name;
- email address;
- telephone number;
- payment details;
- social network account information (if you register on our website with your social network account and/or choose to join a closed group on Facebook);
- any other personal data that may be included in the content you provide to us, such as the password you choose for your user account, in an email message, etc.

This data is necessary for CPS to enter into and perform contracts with you and to communicate with you.

2.3 When you sign up for newsletters and CPS services using the form available on the website, you provide us with details of your email address. This data is necessary for CPS to communicate with you.

2.4 When you communicate with us using the contact form available on the Website, you provide us with details of your email address and/or telephone number and/or your residential or mailing address and any other information that you choose to disclose to us. This information is necessary for CPS to communicate with you and respond to your questions, requests, complaints, etc.

Personal data collected automatically

2.5 When you visit the CPS website, we automatically collect and process the following information, which may include your personal data: your device and browser, the pages you access, device identifiers, the operating system you use, your location, mobile network information, standard web log data and other information collected from cookies and similar technologies we use on our website. Find out more about how we use cookies on our website by reading our Cookies Policy.

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3. Purposes and legal basis for processing

3.1 CPS processes your personal data in order to offer and provide services to you, to improve the services provided, to resolve any problems you may have with the service and to provide you with the best possible experience as a customer.

3.2 CPS collects and processes your personal data for purposes including, but not limited to:
- for the conclusion and performance of contracts;
- for the creation of your user account on our website;
- for the provision of services;
- for issuing a certificate;
- communicating with you about our services and other matters;
- analysing the use of our website and services so that we can make improvements;
- informing you about our services;
- to protect our legitimate interests and for legal reasons such as enforcing contracts, complying with applicable laws and regulations, and cooperating with law enforcement authorities.

We will ask for your consent before using your personal data for a purpose not covered by this Privacy Policy.

3.3 CPS collects and processes your personal data only when it has a lawful basis to do so, which may vary depending on the specific category of data and the purposes of the processing. Please note that we may process the same Personal Data for multiple purposes at the same time and on multiple legal bases respectively.

3.4 Conclusion and performance of a contract. The legal basis for most processing of your Personal Data is the contractual relationship between you and CPS, given that we need the data to enter into and perform a contract with you.

3.5 Legal obligation. In some cases, CPS processes personal data on the basis of legal obligations imposed on us by applicable laws and regulations, such as in the area of taxation, or where we are required to respond to a legal process.

3.6 Legitimate interests. The processing of your personal data is necessary for the pursuit of the legitimate interests of CPS or the legitimate interests of third parties, except where your interests or fundamental rights and freedoms which require the protection of personal data override such interests. For example, we may process your data for marketing purposes based on our legitimate interests in developing our business. Other legitimate interests include engaging in commercial activities, managing and providing services, informing potential customers about our services, promoting and developing services, detecting and preventing security and technical problems with the services, complying with legal requirements, and others.

3.7 Consent. Some of the personal data we process is based on your consent. This is data that we do not need for the performance of a contract, but you may voluntarily provide us with such data in order to receive information about our services to your email address (name, email address, telephone number). Please note that you have the right to delete this information and withdraw your consent at any time.

4. Storage period

4.1 The CPS retains personal data until the purpose for which the data was collected has been fulfilled. For example, we retain customer data for as long as a contractual relationship exists between us.

4.2 After you terminate your relationship with us, complete training or otherwise end your contract with us, we may continue to retain certain data for as long as is reasonably necessary to comply with our legal obligations, to resolve disputes, if any, to enforce our agreements and/or to protect our legitimate interests.

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5. Transfer of personal data to third parties.

5.1 In order for CPS to provide you with the Services, we work with third parties who provide us with various services necessary for us to conduct our business ("Third Party Service Providers"). Accordingly, we transfer your personal data to Third Party Service Providers such as server service providers, email communication service providers, payment processing service providers, legal service providers.

5.2 Third party service providers receive a strictly limited amount of personal data necessary for the provision of their services. CPS only transfers personal data to Third Party Service Providers that are able to ensure that all personal data processing requirements are met in accordance with the General Data Protection Regulation and other applicable laws and regulations.

5.3 In certain circumstances, we may be legally obliged to transfer your personal data to national or local government authorities or other third parties.

5.4 CPS may transfer your personal data to third parties where it is in our legitimate interests to do so, such as in the case of mergers, asset disposals, business transitions and other restructuring of service provision.

5.5 Personal data processed by CPS may be transferred to third party service providers and other parties located outside the European Economic Area ("EEA"). CPS confirms that personal data is only transferred to Third Party Service Providers and other parties outside the EEA that are located in territories that have been recognised by the European Commission as providing an adequate level of protection for personal data or are otherwise able to provide adequate safeguards, and that effective legal remedies are available to data subjects.

6. Data subject rights.

6.1 Individuals located in certain countries, including the EEA, have certain rights under their laws and regulations in relation to their personal data. Subject to any exceptions provided for in the laws and regulations, you may have the right to request access to your personal data to update, erase or correct it, to restrict or object to the processing of your data, as well as the right to data portability.

6.2 You may exercise these rights by contacting the CPS using the contact details set out in the Privacy Policy below.

6.3 If you believe that we have unlawfully processed your personal data, you have the right to complain to us using the contact details set out in the Privacy Policy below or to lodge a complaint with the data protection supervisory authority in your country.

7. Security of personal data.

7.1 Taking into account the potential risks and the nature of the processing, CPS uses reasonable and appropriate organisational, technical and administrative measures to protect the confidentiality, integrity and availability of personal data.

7.2 Unfortunately, no data transmission or storage system is guaranteed to be 100% secure, so we cannot guarantee complete data security. We therefore urge you to take care of your personal data, set a secure password for your CPS account, restrict access to your device and browser when logging out at the end of a session, and avoid as far as possible providing any sensitive data to the CPS, the disclosure of which could cause significant harm to the data subject.

7.3 All CPS staff involved in processing personal data provided to us are committed to confidentiality obligations and must not access personal data without permission or when it is not necessary for the purposes for which the data was collected.

7.4 In the event of a personal data breach, we will notify you in accordance with our obligations under applicable laws and regulations and provide reasonable assistance in connection with the investigation of the personal data breach and notification to supervisory authorities.

8. Changes to the Privacy Policy.

8.1 CPS may amend the Privacy Policy, for example, by introducing new services. Amendments to the Privacy Policy will take effect and apply from the time they are posted on our website.

8.2 Accordingly, we encourage you to visit the CPS website from time to time. By continuing to use our services, website or otherwise providing us with personal data after the Privacy Policy has been amended, you agree to the new Privacy Policy.

9. Applicable Law.

The CPS Privacy Policy is subject to the laws and regulations in force in the Republic of Latvia. Any disagreements will be resolved by negotiation. If no mutual agreement is reached, disputes will be litigated in the courts of the Republic of Latvia in accordance with the laws and regulations in force in the Republic of Latvia.

10.    Contact.

If you have any questions about the Privacy Policy and the processing of your data, or if you wish to exercise your data subject rights, please contact us by email at ask@cps.lv or by using the following contact details:
   
Complete Payment Systems SIA
Registered office: Brīvības gatve 226/2, Rīga, LV-1039

The Privacy Policy is effective from 1 January 2024.