4.1. Administrator processes personal data with the main objectives to develop professional development and interest educational programmes for teenagers and adults. Administrator, in collaboration with one or several partner organizations and upon prior agreement (stating the respective responsibilities of the involved parties), may process the personal data on a cooperative basis;

4.2. Administrator processes personal data with the following objectives:

4.2.1. In accordance with the legal agreement that has been concluded with Data Subject, Administrator processes personal data that are necessary for the purpose of conducting agreement with Data Subject, i.e., to identify the agreement partner, to mutually implement the terms of the agreement or the supplementary obligations of the agreement, to communicate with governmental authorities (i.a., e.g., the Ministry of Education and Science of the Republic of Latvia), to uphold the terms of the legal commitments as well as to resolve legal disputes and legal disagreements. In accordance with the aforestated objectives, the following data are prioritized and processed: name and last name of the student and student’s representative, personal ID, address, phone number, email address, information regarding the services listed within the binding agreement as well as the respective liabilities. Processing is executed in accordance with the Article 6, Paragraph 1, Subparagraph b) of Regulation; 

4.2.2. Student data register maintenance and organization of the educational process. In accordance with the objective, the following data are prioritized and processed: name and last name of the student and student’s representative, personal ID, address, phone number, email address, former education notice. Processing is executed in accordance with the Article 6, Paragraph 1, Subparagraph f) of Regulation as well as in accordance with the requirements of the Education Law and the General Education Law;

4.2.3. Education process analysis in order to upgrade the educational programme offer and to improve the educational programme quality as well as in order to develop better service range for the students. In accordance with the objective, the following data are prioritized and processed: gender, age, language level assessment. Processing is executed in accordance with the Article 6, Paragraph 1, Subparagraph a) of Regulation;

4.2.4. Providing Student Satisfaction Survey data for the respective research company. In accordance with the objective, the following data are prioritized and processed: gender, age, educational programme and its duration, language level assessment results. Processing is executed in accordance with the Article 6, Paragraph 1, Subparagraph a) of Regulation;

4.2.5. Delivering of Administrator’s advertising and informational materials via postal services or via email (direct marketing). In accordance with the objective, the following data are prioritized and processed: name and last name of the student and student’s representative, personal ID, address, phone number, email address, notice of the relevant educational programmes. Processing is executed in accordance with the Article 6, Paragraph 1, Subparagraph a) of Regulation;

4.2.6. Publicity of events organized by Administrator with the objective to promote Educational Establishment. Upon participating in events organized by Administrator or its partners, the visitors of the event may be photographed, filmed as well as invited to provide short interviews or to present their impressions of the event. On such occasions, the name and the last name of the participant as well as additional information that has been explicitly disclosed by the participant may be registered. The respective materials may be used to build Administrator’s archive as well as to promote Administrator’s brand by publishing the video materials and photographs on Administrator’s social media or any mass information media. Additionally, especially on occasion the participant has received an official invitation to an event organized by Administrator, in order to ensure safety and security measures during the event, additional information may be requested to identify the participant by their name, last name etc. Processing is executed in accordance with the Article 6, Paragraph 1, Subparagraphs a) and f) of Regulation;

4.2.7. Prevention or detection of unlawful acts respective to the security of persons or property. Video surveillance is operated with the objective of the protection of the legal interest of Administrator or third parties as well as the protection of person interest of crucial importance, i.a., protection of life and health interests on Administrator’s premises and on the territories adjacent to the premises. Upon Data Subject’s entering/locating themselves on Administrator’s premises or on Administrator’s territory where video surveillance is operative, Data Subject’s image as well as the time of entering the premises may be processed. Video surveillance is not operated in areas of increased privacy concern to Data Subject such as but not limited to lounges, dressing rooms etc. Video surveillance camera recording scope is focused on hallways, entrances/exits, cars and traffic flow on Administrator’s territory. Video surveillance is operated in accordance with the Article 6, Paragraph 1, Subparagraphs d) and f) of Regulation;

4.2.8. Audio recording of phone conversations with the purpose to ensure and to improve the quality of the services provided by Administrator as well as to ensure Administrator’s legal interest. Upon conducting calls to the phone contact numbers provided by Administrator, the communication content may be recorded and the caller’s phone number may be registered unless the caller has taken measures to prevent detectability. Phone conversations are recorded (if they are recorded) in audio format in accordance with the Article 6, Paragraph 1, Subparagraph f) of Regulation. The phone communication is recorded with the additional purpose of performing investigations on occasion complaints have been received regarding customer service quality as well as to accumulate evidence against such potential claims;

4.2.9. Storing and registering the incoming and outgoing communication (email messages, postal letters etc.) with the purpose of ensuring Administrator’s legal interest. Upon entering into written communication with Administrator, the contents as well as the time of the communication exchange may be stored in addition to the information concerning the selected communication channel. Processing is executed in accordance with the Article 6, Paragraph 1, Subparagraphs c) and f) of Regulation. Processing is justified with the obligation by Administrator to deliver the services listed within the legal enactments, i.e. to register correspondence relevant to Administrator’s nomenclature and relevant to requirements stated within the Archives Law. Processing is also implemented with the purpose of providing evidence on occasion a complaint has been raised;

4.2.10. Analysis of the history of website visitation statistics may be processed with the purpose of performing marketing analysis and Data Subject opinion analysis as well as to use the statistics tool and other website features. Additionally, processing is implemented in order to personalize the content in accordance with the user’s preferences. Administrator performs visitation history analysis with the use of online identifiers as well as the information deliberately submitted by Data Subject (e.g., service evaluations, website browsing experience, traffic, information regarding the user’s willingness to attend an event organized by Administrator etc.) in order to perform marketing analysis and opinion analysis. Processing is executed in accordance with the Article 6, Paragraph 1, Subparagraph f) of Regulation. Processing is also implemented with the purpose of analyzing the brand recognition of Educational Establishment;

4.2.11. Protection of the information systems managed by Administrator against threat is ensured through registering user’s device identifier, TCP/IP address, data and time as well as file manipulations. Processing is executed in accordance with the Article 6, Paragraph 1, Subparagraph f) of Regulation. Processing is implemented with the purpose of investigating deliberate attacks against Administrator’s information systems;

4.3. Special category data (race or ethnic origin, political views, religious or philosophical convictions, trade union membership, health status or data related to sexual orientation) processing is forbidden with the exception of the conditions listed in the Article 9, Paragraph 2, Subparagraphs b) and h) of Regulation that authorize the processing of special category data with respect to:

4.3.1. Health status of Administrator’s employees (mandatory health examination card, sick-leave certificates);

4.3.2. Trade union membership of Administrator’s employees before terminating the contract of employment upon prior notice;

4.3.3. Environmental and educational accessibility provision for students with special needs;

4.4. In order to improve the quality of the educational services provided for Data Subject as well as the quality of the experience, Administrator has the right to process personal data additional to the data categories and conditions stated within these terms. Similarly, Administrator may need to process data for purposes other than those listed in these terms. On occasion a necessity to perform the processing activities has arisen in accordance with the terms stated in this subparagraph, Administrator evaluates the legal terms of the respective processing conditions as well as informs Data Subject on the respective processing incident and the respective rights in accordance with the legislative acts;

4.5. Upon processing personal data for purposes other than those stated within this Policy, Administrator is obliged to separately inform Data Subject on the specific conditions of the respective processing in accordance with the requirements stated in the Paragraph 13 of Regulation.