1. General rules

1.1. This Privacy Policy describes how SIA Excly, Bišuiela 8, Cēsis, Cēsu nov. LV-4101, Registration number: 40203368481 (hereinafter referred to as the “Data Controller”) obtains, processes, and stores personal data obtained from its clients and individuals who visit the website www.excly.com (hereinafter referred to as the “Data Subject” or “You”).

1.2. Personal data is any information regarding an identified or identifiable natural person, i.e., the Data Subject. Processing includes any operation related to personal data, such as collection, recording, organization, use, viewing, deletion, or destruction.

1.3. The Data Controller adheres to the legal principles of data processing and can confirm that personal data is processed in accordance with applicable legislation.

2. Acquisition, processing, and storage of personal data

2.1. The Data Controller obtains, processes, and stores personally identifiable information primarily through the use of the website and email.

2.2. By visiting and using the services provided on the website, you agree that any information provided is used and managed in accordance with the purposes outlined in the Privacy Policy.

2.3. The Data Subject is responsible for ensuring that the submitted personal data is accurate, precise, and complete. Knowingly providing false information is considered a violation of our Privacy Policy. The Data Subject has an obligation to immediately inform the Data Controller of any changes to the submitted personal data.

2.4. The Data Controller is not responsible for losses incurred by the Data Subject or third parties if they arise due to falsely submitted personal data.

3. Processing of Customer Personal Data

3.1. The Data Controller may process the following personal data:

3.1.1. Name, surname

3.1.2. Contact information (email address and/or phone number)

3.1.3. Any other information submitted to us during the use of website services, purchase of goods, or when contacting us.

3.2. In addition to the above, the Data Controller has the right to verify the accuracy of the submitted data using publicly available registers.

3.3. The legal basis for the processing of personal data is Article 6(1)(a), (b), (c), and (d) of the General Data Protection Regulation:

1. a) the data subject has given consent to the processing of their personal data for one or more specific purposes;
2. b) processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;
3. c) processing is necessary for compliance with a legal obligation to which the controller is subject;
4. d) processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

3.4. The Data Controller stores and processes the personal data of the Data Subject as long as at least one of the following criteria is met:

3.4.1. The personal data is necessary for the purposes for which it was obtained;

3.4.2. Until the Data Controller and/or the Data Subject can exercise their legitimate interests in accordance with external regulations, such as submitting objections or bringing or defending legal claims;

3.4.3. As long as there is a legal obligation to retain the data, such as under the Accounting Law;

3.4.4. Until the Data Subject’s consent for the specific processing of personal data is no longer valid, unless there is another lawful basis for processing.

Upon the expiration of the conditions mentioned in this section, the storage period of the Data Subject’s personal data ends, and all relevant personal data is irrevocably deleted from computer systems and electronic and/or paper documents containing such personal data are either deleted or anonymized.

3.5. To fulfill its obligations to you, the Data Controller has the right to transfer your personal data to business partners, data processors performing necessary data processing on our behalf, such as accountants, courier services, etc. A data processor is a data controller. Upon request, we may disclose your personal data to state and law enforcement authorities to defend our legal interests, compiling, submitting, and defending legal claims when necessary.

3.6. In processing and storing personal data, the Data Controller implements organizational and technical measures to ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.

4. Data Subject Rights

4.1. In accordance with the General Data Protection Regulation and the laws of the Republic of Latvia, you have the following rights:

4.1.1. Access to your personal data, information about its processing, the right to request a copy of your personal data in electronic format, and the right to transfer this data to another controller (data portability).

4.1.2. Request correction of incorrect, inaccurate, or incomplete personal data.

4.1.3. Erasure of your personal data (“right to be forgotten”), except in cases where the law requires data retention.

4.1.4. Withdrawal of your previously given consent for the processing of personal data.

4.1.5. Restriction of data processing – the right to request the temporary suspension of the processing of all your personal data. You can exercise your rights by submitting a request electronically or by writing to the customer support service at contact@excly.com.

5. Closing Provisions

5.1. This Privacy Policy is developed 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 the current laws of the Republic of Latvia and the European Union.

5.2. The Data Controller has the right to make changes or additions to the Privacy Policy at any time and without prior notice. Amendments come into effect upon their publication on the website www.excly.com.