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VIRŠI APP PRIVACY STATEMENT
1. General Terms and Condions
1.1. By implemenng the condions of Arcle 13 of Regulaon of the European Parliament and of
the Council (EU) 2016/679 of 27 April 2016 on the protecon of natural persons with regard to the
processing of personal data and on the free movement of such data, and repealing Direcve 95/46/EC
(General Data Protecon Regulaon), hereinaer – the Regulaon, please be informed about the
processing of personal data, when downloading and using the mobile app (hereinaer – App) of AS “VIRŠI-
A” (hereinaer – VIRŠI or the Controller).
1.2. In the privacy statement of the VIRŠI App (hereinaer – Statement) you will nd informaon
about what personal data VIRŠI collects and processes about you, for what purposes it is used, for how
long it will be stored, etc. Informaon relang to the App which is of importance to you.
1.3. Informaon about the processing of personal data of the VIRŠI loyalty programme (hereinaer
– Loyalty Programme) is available in the VIRŠI Loyalty Programme Privacy Statement, available here
hps://www.virsi.lv/documents/download/lojalitates-programmas-privatuma-pazinojums
2. Contact informaon of the Controller
2.1.The Controller of personal data processing is AS “VIRŠI-A” (reg. No. 40003242737, registered
address: Kalna iela 17, Aizkraukle, Aizkraukle Rural Territory, Aizkraukle Municipality), with the following
contact informaon for communicaon:
– postal address: Kalna iela 17, Aizkraukle, Aizkraukle Rural Territory, Aizkraukle Municipality, LV-
5101, Latvia;
– e-mail address: birojs@virsi.lv;
– telephone +371 80 700 070.
Riga. The date of the document is the date of the me stamp of its last electronic signature.
This document is signed with a secure electronic signature and contains a me stamp.
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2.2.You can contact VIRŠI regarding all personal data processing and protecon issues in the
following ways:
– electronically by wring to the e-mail address: datuaizsardziba@virsi.lv
– address for postal correspondence: Kalna iela 17, Aizkraukle, Aizkraukle Rural Territory, Aizkraukle
Municipality, LV-5101, Latvia.
Please address your leer to: “VIRŠI” Data Protecon Ocer.
3. What personal data about you is processed by VIRŠI and for what purpose (aim); what is the
legal basis for data processing and the period of storage of data?
3.1. For the administraon of the VIRŠI-hosted mobile App (developed to enable the parcipant
of the VIRŠI Loyalty Programme to keep track of the oers of the VIRŠI Loyalty Programme that are
available to them).
3.1.1. Personal data that are being processed.
For the parcipant of the VIRŠI Loyalty Programme (hereinaer – Parcipant or you) to be able to
keep track of the oers of the VIRŠI Loyalty Programme that are available to them, the Parcipant needs
to register on the App, by specifying their telephone number (which will be used as an idener and will
be linked to the prole of the Parcipant), name, surname, date of birth, gender, place of residence (city,
district), e-mail address, VIRŠI loyalty card number/bank card number and other informaon related to
parcipaon in the VIRŠI Loyalty Programme.
The preferences made by the Parcipant, such as whether the Parcipant wishes to receive
personalised newsleers (by SMS, e-mail, Push nocaons on the phone or social networks), and
whether the Parcipant has expressed a wish to parcipate in loeries of goods and services.
In order to use the informaon available on the App about the fuel staons near the Parcipant’s
locaon and other oers, VIRŠI may ask the Parcipant to provide addional locaon data (geolocaon).
In this case, VIRŠI will know the informaon about the locaon of the Parcipant.
In order to ensure secure and smooth operaon of the App, VIRŠI will record your App version, the
language selected on the App, user ID, informaon about when registraon has been performed, the
vericaon SMS has been sent, the App has been opened and about the last updates of the User
informaon, informaon about the sengs on the App, for example, whether the Parcipant has given
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permission for nocaons to be sent to them from the App, whether the Parcipant has permied the
use of locaon data, full fuel tank volume, default payment card idener.
3.1.2. Legal basis for data processing.
When using the funconality provided by the App, VIRŠI shall perform personal data processing
based on Arcle 6(1)(b) of the Regulaon, i.e., a contract has been concluded between the pares when
the Parcipant downloads the App and expresses the wish to use the funconality of the App.
In order to ensure that the Parcipant does not face risks to their rights and freedoms when using
the App, VIRŠI shall, on the basis of Arcle 6(1)(f) of the Regulaon, carry out regular upgrading of the
funconality and security soluons of the App. VIRŠI shall independently monitor whether any signs are
observed of unauthorised persons accessing the App, including the smart device of the Parcipant. Upon
detecng any suspicious conduct, VIRŠI may use all available informaon at the disposal of VIRŠI to
invesgate such security incident, including informaon reecng the history of use of the App. When
providing upgrades of the funconality and security soluons of the App, VIRŠI may use your personal data
reected on the App to ensure that the performed upgrades are not erroneous and do not contain any
other risks that may cause damage to the lawful interests of both VIRŠI and the Parcipant.
3.1.3. How long does VIRŠI store your data for?
Informaon about your use of the App will be stored for as long as you use the App.
If your personal data have been involved in a potenal personal data protecon breach or
informaon system security incident, the relevant informaon will be retained for at least ve years.
If a complaint is received or the lawful interests of VIRŠI are infringed, for example, there is a
dispute about the acons performed when using the App, the relevant informaon may be retained unl
resoluon of the issue is complete, for example, unl the moment of coming into force/enforcement of
the court judgment.
3.2.To enable you to sele payments for your purchases with the App.
3.2.1. Personal data that are being processed.
In order for you to be able to sele payments with the App for your purchases made at VIRŠI fuel
staons, you should specify your bank payment card number when registering on the App, which will be
used as an idener and will be linked to the Programme Parcipant prole you have created. Secon
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“Transacon History” of the App will display the purchases made via the App, which will reect informaon
about the goods purchased at fuel pumps and payments made through the App for fuel and/or windscreen
uid or other goods available at the pumps. An electronic receipt for the purchase will be sent to the e-
mail address provided on the App.
3.2.2. Legal basis for data processing.
When using the funconality provided by the App, VIRŠI shall perform personal data processing
based on Arcle 6(1)(b) of the Regulaon, i.e., a contract has been concluded between the pares when
the Parcipant downloads the App and expresses the wish to use the funconality of the App, and based
on Arcle 6(1)(c) of the Regulaon – processing is necessary for compliance with a legal obligaon to which
the Controller is subject, namely, the Accounng Law prescribes entering the payments of purchase
transacons into accounts and the details to be included in the source documents.
VIRŠI shall apply Arcle 6(1)(f) of the Regulaon – processing is necessary for the purposes of the
legimate interests pursued by the Controller or by a third party, except for where such interests are
overridden by the interests or fundamental rights and freedoms of the data subject which require the
protecon of personal data), to be secured with evidence that the payment and accounng provisions of
the mutual purchase transacons are complied with during the fullment of the contractual relaonship.
3.2.3. How long does VIRŠI store your data for?
Informaon about your bank card number will be stored for as long as you use the App. You can
make changes at any me by deleng your bank card number or by specifying a dierent bank card
number.
Informaon about the purchases made will be available on your smart device from the beginning
of the previous year unl the moment of deleon of the App from your smart device. Deleng the App
shall not mean that the data collected up to the me of deleon thereof will be deleted. VIRŠI will connue
to process them within the framework of the Loyalty Programme in order to achieve its purposes.
If your personal data have been involved in a potenal personal data protecon breach or
informaon system security incident, the relevant informaon may be retained for at least ve years.
If a complaint is received or the lawful interests of VIRŠI are infringed, for example, there is a
dispute about the acons performed when using the App for payments, the relevant informaon may be
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retained unl the resoluon of the issue is complete, for example, unl the moment of coming into
force/enforcement of the court judgment.
4. To whom does VIRŠI transfer your personal data?
4.1. The processing of your personal data will be carried out by the authorised employees of VIRŠI
according to the scope specied in their job dues, observing the requirements of personal data protecon
and other regulatory enactments, as well as the requirements of personal data processing set out in the
VIRŠI internal regulatory enactments.
4.2. Personal data may be transferred to:
- VIRŠI outsourced service providers (processors) who may be authorised to carry out certain data
processing acvies on behalf and under the supervision of VIRŠI, i.e., persons who assist VIRŠI in
implemenng and maintaining the Loyalty Programme and administering the App (e.g., the App host);
- under certain circumstances (e.g., if a complaint is received about the acons performed when
using the funconality of the App), data may be transferred to law enforcement or supervisory authories,
court, as well as processors – legal service providers, etc.
4.3.It is not intended to transfer personal data to recipients outside the Member States of the
European Union or the European Economic Area.
5. From what sources does VIRŠI obtain and collect your personal data?
VIRŠI shall collect almost all of your personal data from only you or the equipment you use. When
downloading the App and registering, you are subming data to VIRŠI. When purchasing goods through
the App, using the App and using an idener (loyalty/bank card), using the benets oered by the Loyalty
Programme with the App, VIRŠI receives your data.
6. What are your rights and how can you exercise them?
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You can freely exercise your rights as a data subject, by performing the relevant acons on the App
or by addressing VIRŠI. Informaon on your specic rights and how to exercise them is provided by VIRŠI
in this Statement and VIRŠI asks you to read it carefully:
6.1.Right to access your personal data processed by VIRŠI.
You have the right to receive informaon about whether VIRŠI processes your personal data. You
have the right to review your personal data processed by VIRŠI and informaon about the purposes of
data processing, categories of data to be processed, categories of data recipients, period of data
processing, sources of obtaining data, as well as their meaning and consequences. The majority of this
informaon is provided by VIRŠI in this Statement.
In addion, VIRŠI draws your aenon to the fact that your personal data are available on the App
you are using and you can consult your personal data processed by VIRŠI at any me (for example, check
the personal data you have submied, update the informaon, the consents you have given, withdraw
the consents you have already given or provide new consents, etc.).
If the informaon provided in this Statement or on the App in your prole is not sucient for you
(or you wish to receive addional informaon), you can contact VIRŠI in the ways specied in this
Statement.
6.2.Right to request the reccaon of personal data.
If the personal data specied by you at the me of your registraon have changed or you detect
that the informaon processed by VIRŠI about you is inaccurate or incorrect, you have the right to request
that this informaon be claried or reced.
In order to exercise this right, you can independently recfy your personal data in your prole of the
App or by contacng VIRŠI via the ways of contact informaon specied in this Statement, in order for
VIRŠI to recfy or clarify them.
6.3.Right to withdraw consent.
If VIRŠI processes your data on the basis of consent provided by you, you have the right to withdraw
your consent at any me. In such a case, the data processing based on your consent will be terminated.
The withdrawal of consent shall not aect the lawfulness of processing based on consent before its
withdrawal.
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For example, you may withdraw your consent to receive the news of the Loyalty Programme at any
me. The withdrawal of consent will not restrict your parcipaon in the Loyalty Programme and the use
of the App, but VIRŠI will not be able to provide you with current news through the specied
communicaon channel. The withdrawal of such consent shall not aect the fact that you will be able to
receive up-to-date informaon in your user prole on the App in the form of nocaons.
You may modify your consents (withdraw or give them anew), by changing the terms of your consent
on the App or by contacng VIRŠI in the ways specied in this Statement.
If you withdraw your consent, VIRŠI will delete the data, unless there is another legal basis for
processing them, and in the cases specied in the Statement – VIRŠI shall permanently anonymise the
data.
6.4.Right to lodge a complaint.
You have the right to lodge a complaint with the Data State Inspectorate if you believe that VIRŠI
has processed your personal data unlawfully. VIRŠI invites you to contact VIRŠI by wring to the e-mail
address: datuaizsardziba@virsi.lv, in order to promptly nd a soluon to the situaon if the Data Subject’s
right to personal data protecon has been violated.
6.5.The right to object to the processing of data carried out on the basis of our legimate interests.
You have the right to object to the processing of personal data, if the personal data is processed on
the basis of the legimate interests of VIRŠI. Taking the objecves of VIRŠI Loyalty Programme and the
balance of legimate interests of both pares into account, in such case, VIRŠI will not be able to provide
you with the opportunity to connue parcipang in the Loyalty Programme and the validity of the
concluded contract will be terminated. VIRŠI has the right to connue processing your personal data
where VIRŠI demonstrates compelling legimate grounds for processing which override your interests,
rights and freedoms, or for the establishment, exercise or defence of legal claims.
If you wish to exercise the rights set out in this secon, you must submit a wrien request to VIRŠI
in the ways specied in this Statement.
6.6.Right to request to erase data (right to be forgoen).
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In certain circumstances referred to in the regulatory enactments (for example, if personal data are
processed unlawfully, if the legal basis of the data processing expires, if personal data are no longer
necessary in relaon to the purposes for which they were collected or otherwise processed, etc.), you have
the right to request VIRŠI to erase your personal data. If you wish to exercise this right, please submit a
wrien request in the ways specied in this Statement.
Please note that the deleon of the App shall not mean that the data collected up to the me of
deleon thereof will be deleted. VIRŠI will connue processing them within the framework of the Loyalty
Programme in order to achieve its purposes.
You have the right to stop using the App at any me by logging out or deleng the App from your
smart device. You can also erase your personal data yourself at any me on the App, by logging in to your
user prole. You have the right to delete your prole in the “Manage Prole” Secon of the App. VIRŠI
draws your aenon to the fact that by deleng your data and/or by deleng the App, you will also be
excluded from parcipaon in the Loyalty Programme and all the benets you have accumulated will be
cancelled.
Please note that the right to erasure does not apply to cases where in accordance with the
regulatory enactments, VIRŠI has an obligaon to process personal data or data processing is necessary
for archiving purposes, implementaon of the interests of VIRŠI, as well as for the establishment, exercise
or defence of a legal claim.
6.7.Right to request the restricon of data processing.
In certain circumstances menoned in the regulatory enactments (for example, if personal data are
processed illegally, you dispute the accuracy of the data, you le objecons to data processing on the basis
of the protecon of legimate interests of VIRŠI, etc.), you have the right to restrict your data processing.
Due to such restricon of data processing, it may not be possible for VIRŠI to provide you with all the
benets of the VIRŠI Loyalty Programme.
If you wish to exercise the rights set out in this secon, you must submit a wrien request in the
ways specied in this Statement.
7. How does VIRŠI handle and process your requests?
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To protect the customer data of VIRŠI from unauthorised disclosure, VIRŠI will need to verify your
identy upon receiving your request to provide you with your data or the exercise of your other rights.
During this inspecon, VIRŠI has the right to send a control noce to you to your contact informaon
available at the disposal of VIRŠI (in the form of a text message or e-mail), requesng to perform
authorisaon. If the vericaon procedure fails, VIRŠI may reject your request.
Upon the receipt of your request for the exercise of any of your rights and the successful compleon
of the review procedure, VIRŠI shall provide the informaon requested by you as soon as possible, but no
later than within one month from the date of receipt of your request. If your request is complicated, VIRŠI
has the right to extend the above-menoned period for another two months, informing you of such and
stang the reasons for the extension.
If your request is submied by electronic communicaon means, VIRŠI will also provide a reply in
the same way, unless this is impossible (for example, due to the large amount of informaon) or if you ask
to provide a reply in any other way. VIRŠI will not full your request if any obstacles to the execuon of
such request are idened (for example, due to circumstances specied in the regulatory enactments).
8. Validity and changes in the Statement
This Statement shall be in force as of 4 August 2023.
This Statement may be changed (supplemented, updated) and the updated version of the Statement will
be placed on the App and at www.virsi.lv. You will always nd the latest version of the Statement in the
above-menoned places. By means of the contact informaon specied by you, you will be informed of
any changes and invited to become acquainted with them.
