Privacy Policy

This privacy policy (Privacy Policy) explains how and to what extent SPICE, which is owned by the limited liability company Tirdzniecības centrs Pleskodāle, registration number: 40003523495, registered address: 29 Lielirbes Street, Riga, LV-1046 (“SPICE”, “we”, “our” and “us”), collects, for what purpose processes, and for how long stores and uses the information from your contact with the SPICE products. This Privacy Policy applies to both personal data we collect directly from you and personal data we collect from third parties. This Privacy Policy applies to all Users (“Users”, “you” and “your”) who use the SPICE website.

Please read the terms and conditions of this Privacy Policy carefully and contact us if necessary.

1. User’s consent

By using the SPICE websites and agreeing to the application of this Privacy Policy to the protection of personal data, the User confirms that he/she is informed about the processing of his/her personal data to the extent and under the procedure outlined in this Privacy Policy. We have the right to use personal data for the purposes described in this Privacy Policy as well as for other purposes that we informed you about at the time of collecting personal data.

2. Personal data we collect

Personal data means the information related to an identifiable or identified natural person. The following information about the User is being compiled:

(a) Language you use on the SPICE websites;

(b) Name;

(c) Age;

(d) ID number of your device;

(e) The type of operating system of your device;

(f) Information about preferred stores;

(g) Information about categories marked as “liked”.

3. How personal data are collected

We can:

(a) request personal information when you register, subscribe for newsletters, create an account or otherwise use the SPICE websites;

(b) receive additional personal information from third parties (Google Analytics);

(c) collect information about your location, history of visits, search history and uploads to the SPICE websites when you use offers on the SPICE websites through a mobile phone or a different device used to visit the SPICE websites;

(d) receive information about the person’s e-mail address, with the consent of the person, if the person has applied for receiving newsletters;

(e) request personal information (name, surname and ID number, phone number and/or e-mail address if you apply for or participate in the lotteries and/or contests organized by us. Please note that neither your ID number, nor your phone number, nor your e-mail address will be published within the lotteries and/or contests;

(f) request personal information (given name, surname, phone number and/or e-mail address if you leave your suggestions, feedback and complaints on our website, in order to contact you.

Please be informed that when using other services of third parties in order to use the SPICE websites, such platforms, applications or services may have their own special privacy policies which govern the use of personal data.

4. For what purposes we use your personal data

SPICE uses personal data only if we have a legal basis to do so and only for the following purposes:

(a) to procure operations and improve the SPICE websites, and to introduce new features and technologies based on our legitimate interest in improving the quality of our services. We are interested in providing you with the widest and most personalized range of services possible;

(e) to provide User support, based on your consent when you approach us seeking support, as well as our legitimate interest to improve the quality of our services;

(f) to check and verify the information in the Users’ profiles based on our legitimate interest to identify the particular User. In certain cases, we have the right to protect our legitimate interests if you have filed a claim about our activities;

(g) for communication (using notifications on mobile devices) and to provide additional information about SPICE, its offers, planned changes, improvements, questionnaires, administrative or other notifications that might be of interest to you based on your consent to receive such communications;

(h) to keep statistics about the Users as well as to transfer such statistics to service providers based on our legitimate interest to ensure further development and maintenance of the SPICE websites;

(i) to ensure our day-to-day activities, for example, to administer, maintain and analyze the SPICE websites, to prevent fraud or to ensure compliance with provisions of the effective laws based on the duty imposed on us to comply with requirements of the provisions of law and necessity to ensure operation and development of the SPICE websites;

(j) to use your personal data that you provide in lotteries and/or contests organized by us in order to identify you as a participant in the lottery and/or contest and to contact you if you win;

(k) to use your personal data that you provide in connection with your suggestions, feedback and complaints in order to be able to contact you and respond to your suggestions, feedback and complaints.

5. How long SPICE stores your data

We process and store your personal data until you erase your information from the SPICE websites. Your personal data submitted for receiving the newsletter are stored until you withdraw your consent. However, some types of personal data may be retained: for example, statistical data may be stored in an aggregate form so that we can improve the functionality of the SPICE websites. In order to protect the legal interests of SPICE when conducting a legitimate interest assessment to determine whether the interests of SPICE are more important than the interests and fundamental rights of individuals, personal data may be stored for 5 (five) years after the termination of processing. We process your personal data only as long as we have a legal basis for this. The following circumstances may affect the storage period of your personal data:

• the periods laid down in laws, within which we can pursue our legitimate interests (for example, bring a claim to court or file an objection to a claim you have filed);
• an obligation laid down in laws to store personal data for a specified period (for example, in relation to tax payments and accounting documents);
• as long as your consent to the appropriate processing of personal data is valid, unless there are other legal grounds for the processing of your personal data.

If the aforementioned conditions for the processing of your personal data cease to exist, your personal data will be irrevocably erased/destroyed and/or anonymized.

6. When and why SPICE transfers personal data

We may transfer your personal data in individual cases and only to the extent that is necessary for other companies – personal data controllers with which we have a contractual relationship and with which we have ensured that the relevant security requirements for sending and receiving personal data are met in order to ensure the rformance of services in line with the following:

(a) to partners of SPICE or advertisers, event and advertising agencies, public relations and digital service agencies, including companies representing Facebook, Google Analytics and other brands, as well as mobile and e-mail marketing service providers. Information is transmitted only to the extent necessary to ensure the functionality of the SPICE websites;

(b) to carry out mergers of companies, acquisitions of companies or other activity related to the operations of SPICE.

By using the SPICE websites, you confirm that you are informed that your personal data may be transferred to aforementioned third parties and processed (inter alia, stored, analyzed, registered, modified, used or erased) in line with the purposes described in the Privacy Policy. However, the use of your personal data may be subject to privacy policies of such persons, which are beyond our control. We can disclose your information, if it cannot be identified with you or in the event that it is necessary in accordance with the effective laws and regulations and/or at a request of government or municipal authorities (for example, law enforcement agencies, tax administration or supervisory bodies).

Personal data are processed only in the EU/EEA and are not transferred outside the EU/EEA.

7. Amendments to the Privacy Policy

We may update or supplement this Privacy Policy if new services are added to the SPICE websites. These supplements or amendments to the Privacy Policy shall come into effect at the time when posted on the SPICE website and mobile application and communicated to the Users. The currently valid Privacy Policy is available on the website and mobile application of SPICE.

8. Your rights and safety of personal data

To ensure the proper processing of your personal data, you have the following rights, which you can exercise in relation to your personal data. To exercise your rights, please contact us using the contact information provided in Paragraph 11 of the Privacy Policy.

You have the right:

• to access your personal data from your mobile application account as well as to request information about the personal data processed by us that are of direct relevance to you
• to request the rectification of your personal data if you believe that the personal data processed by us are incorrect, incomplete or inappropriate. You have the right to request the updating or rectification of your personal data;
• to withdraw your consent. If we process your personal data on the basis of your consent, you can withdraw your consent at any time;
• to object to the processing of your personal data or to restrict it. If we process your personal data based on our legitimate interests, you have the right to object to our processing of such data. After receiving your objections to the processing of personal data by us on the basis of our legitimate interests, we will no longer process your personal data or restrict their processing unless we can justify the processing of your personal data in accordance with our legitimate interests or our right to protect our legitimate interests;
• to request the erasure of your personal data if you believe that we no longer need your personal data for the purposes for which they were obtained, or if you withdraw your consent or in other cases when we are not bound by an obligation to store your personal data for certain purposes established by laws.
• to make rectifications in your personal data, to update or erase them as well as to receive information and bring claims and objections in accordance with the provisions of effective laws. To exercise your rights, please contact us using the contact information provided in Paragraph 11 of the Privacy Policy.

You have the right to file complaints if you believe that our processing of data violates your legitimate interests and rights, using the contact information provided in Paragraph 11 of the Privacy Policy.

You also have the right to approach the national data supervisory authority: Data State Inspectorate, 17 Elijas Street, Riga, LV-1050, phone: +371 67223131, e-mail: [email protected].

In order to guarantee the integrity and safety of the processed personal data as well as in order to prevent loss, modification and/or unauthorized access by third parties, SPICE has introduced necessary legal and technical measures so that your personal data are always kept safe.

To ensure access to personal data by authorized persons only as well as to prevent unauthorized disclosure or use of personal data, we use various security technologies and have implemented appropriate procedures.

9. Processing personal data for marketing purposes of SPICE

We process your personal data for various marketing activities of SPICE, administering your participation and awarding prizes in various lotteries and contests we organize. The marketing events we organize are public events that may be photographed or filmed. You must understand that by participating in such events, you can be seen by others. If you come to a marketing event organized by us with a minor under the age of 18, you must understand that the child may also be photographed and/or filmed during the marketing event organized by us.

When photographing and filming events that are held in SPICE, the following personal data about you are obtained:

• your image;
• date and time of the photo/video recording;
• your location.

Photos and videos of events held in SPICE are taken for the purpose of reporting about the course of the events in mass media and social media, on the basis of legitimate interests of SPICE to report and promote the organized events and the SPICE brand.

We store the photos and videos of events organized in SPICE for 5 (five) years after the specific event was held in order to report about and promote the events organized by SPICE, thus contributing to recognizability of the SPICE brand.

Some images, such as images depicting the hosts of the events, invited persons and crowd shots, may be stored on permanent basis for the purposes described above.

Our employees and photography and filming service providers have access to photos and video recordings of the events organized by SPICE. Certain photos or videos may be posted in mass media or social media, or placed in SPICE, where they are available to an unlimited number of people.

Upon request, having assessed the substantiation, or in accordance with provisions of the law, the photos and videos may be handed over to the state or municipal authorities.

During the event, you may ask photographers not to take pictures of you and/or not to film you, and after the event, you may ask them to erase your photo and/or video, indicating the time and place where you were when the photo and/or video was taken.

If you do not wish to be photographed and/or filmed, certain areas at the venue of the event are designated where no photos and videos are taken.

Please keep in mind that in order to exercise the right granted to you in the area of the personal data protection, you have to submit a signed application in person to the SPICE administration office or send an application signed electronically to the e-mail address specified in Paragraph 11 of the Privacy Policy.

10. Processing personal data for security purposes of SPICE

We conduct continuous video surveillance with recording in the common areas of the shopping centre SPICE, along the perimeter of the building and in its area. As part of the video surveillance organized by us, we monitor all people who are in the area of SPICE and come into the field of view of surveillance cameras, including children (persons under 18 years old).

When conducting video surveillance, the following personal data about you are obtained:

• your image;
• date and time of the video recording;
• your location.

Video surveillance in SPICE is conducted for the following purposes:

• preventing and detecting criminal offenses on the basis of the legitimate interests of SPICE to protect its property and your vital interests, including health and life, and obtaining evidence for insurance purposes;
• collecting statistical data on the number of SPICE visitors on the basis of the legitimate interests of SPICE to forecast human traffic as well as to comply with epidemiological safety requirements in place in the country.

In order to collect statistics, information on the number and traffic of SPICE visitors is collected and processed only in an aggregate form.

We process and store the video surveillance materials for no longer than for 25 (twenty-five) to 30 (thirty) days, taking into account the location where the specific CCTV camera is placed. If the video surveillance material is necessary for further investigation or as proof of a criminal offense, it can be stored throughout the period of investigation and, in relevant cases, stored in an archive along with the materials of the investigation file for no longer than 10 (ten) years.

The access to the video surveillance materials is strictly limited and provided only to those persons who require it to protect their legitimate interests. We ensure that only administration staff of SPICE and employees of the security services provider have access to the video surveillance materials. Your personal data may be transferred to the data controllers of the following categories:

• providers of physical security services;
• providers of security and safety systems maintenance services;
• providers of insurance services;
• state authorities (for example, investigative bodies, intelligence operations bodies, state security bodies, prosecutors, courts and other law enforcement bodies, and the State Revenue Service and its divisions).

You may access the video surveillance materials upon request, specifying the particular time when you were in “SPICE and the particular place where you were.

Upon request, having assessed the substantiation, or in accordance with provisions of the law, the video surveillance materials may be handed over to the state or municipal authorities.

11. For more information

Limited Liability Company Tirdzniecības centrs Pleskodāle

To read more about this Privacy Policy or if you have questions about our processing of personal data or want to exercise your rights, you can contact us by writing to the e-mail address: [email protected] or by sending a letter by post to our registered address: 29 Lielirbes Street, Riga, Latvia, LV-1046.

This Privacy Policy is approved and comes into effect on 1 July 2018.

Amendments to this Privacy Policy are approved and come into effect on 11 February 2021.

Cookie Use Policy

When you use the SPICE websites, we collect, automatically or by electronic means, certain information by using such tools as cookies, web browser analytics and web server logs. When you use the SPICE websites and applications, your web browser and devices contact our servers and the servers operated by our partners and service providers in order to coordinate and keep record of activities and satisfy your request for services and information.

Information from cookies and related technologies is stored on web server logs, as well as in cookies stored on your computer or mobile devices, and then transmitted back to the SPICE websites using your computer or mobile devices. These servers and cookies are administered by us, our partners or Service Providers.

Cookies are small text files that websites store on your computer or mobile device when you visit a website. Cookies are commonly used to improve the performance of websites and also to provide certain information to website owners.

There are several categories of cookies:

• necessary cookies enable our websites to function correctly and in a way that is convenient for you. If you do not agree with the use of such cookies, you will not be able to use our websites or you will face serious difficulties when using them. Necessary cookies do not collect your personal data;
• performance cookies collect information about how you use our website, for example, by recording the web pages you visit, which allows us to improve the performance and functionality of the website. Performance cookies do not collect your personal data;
• functional cookies allow the website to remember all preferences you choose, such as text size or language, so that we can provide you with a better website experience. Functional cookies collect your personal data;
• third-party cookies allow us to improve the functionality of our website and tailor it to your interests and needs, for example by allowing you to watch videos on YouTube or Vimeo. Third party cookies may collect your personal information depending on their type.

All cookies can be divided into the following types depending on how long the cookies are stored on your computer or mobile device:

• session cookies are stored on your computer or mobile device only during the corresponding web browser session, that is until you leave our website;
• persistent cookies are stored in your web browser for a certain time after the end of the session unless you delete them.

The cookies we use allow us to authenticate you and to process statistics about the use of our website and visits to specific pages. Activated cookies allow us to recognize your web browser and provide you with certain additional functions.

We use cookies:

• to create/maintain your session on our website;
• to provide statistics on website visits;
• to remember your screen settings (preferences), such as the selected language;
• to remember whether you gave your consent to the use of our cookies on this website or not;
• to compile information about the use of the website, which allows us to analyze how well our website suits your needs and to make any necessary improvements.

You can reject all cookies or instruct the web browser to report when a cookie is being sent. However, if you reject the use of cookies, you may not be able to use some of the SPICE services.

You can reject the use of Google Analytics cookies by downloading and installing the Google Analytics Opt-out Browser Add-on.

For additional information of general nature regarding cookies and to learn how to manage them please read the information on www.aboutcookies.org.

For more information about the personal data collected and your right of access please contact us by writing to the following address: [email protected] or you can read this information on www.spice.lv/privacy-policy

We use cookies for certain functions and analytical purposes. By using our website, you agree to our Cookie Use Policy.

For more information:

Limited Liability Company Tirdzniecības centrs Pleskodāle

Registered address: 29 Lielirbes Street, Riga, Latvia, LV-1046

E-mail: [email protected]

Phone: +371 67807279

You have the right to approach the national data supervisory authority: Data State Inspectorate, 17 Elijas Street, Riga, LV-1050, phone: +371 67223131, e-mail:[email protected].

This Policy is approved and comes into effect on 1 July 2018.

Amendments to this Policy are approved and come into effect on 11 February 2021.

The amendments to the Privacy Policy have been approved and come into effect on 20 September 2021.