Privacy Policy

1. Introduction

1.1. This Privacy Policy explains how SIA "Nuvilo" ("we", "our", the "Platform Operator") processes and protects your personal data when you use our platform Uznometni.lv (the "Platform").

1.2. In addition, this Policy also applies to the processing of personal data that we carry out on behalf of camp organisers who use our Platform to manage camp applications and agreements.

2. Data Controller and Data Processor

2.1. With regard to the personal data of camp organisers, the data controller is:

SIA "Nuvilo" Registration No.: 40203707349 Legal Address: "Zvaigznes Dārzs" - 10, Ķesterciems, Engures pag., Tukuma nov., LV-3113 Email: [email protected] Phone: +371 29250342

2.2. With regard to the personal data of camp participants and their legal or authorised representatives, SIA "Nuvilo" acts as a data processor, processing such data on behalf of camp organisers and in accordance with the camp organisers' instructions.

2.3. For each specific camp, the data controller is the relevant camp organiser.

2.4. As a data processor, SIA "Nuvilo" enters into a written agreement with each camp organiser (Data Processing Terms) governing the scope, purpose and security measures of data processing.

2.5. For personal data protection matters, please contact us at: [email protected]

3. Data We Process

We may process the following personal data:

• name, surname, contact details (email, phone number);
• information provided in registration forms and questionnaires (e.g., camp application details);
• website usage data (e.g., IP address, browser information, cookies);
• data submitted by end users to camp organisers through the Platform (e.g., child's name, age, health information, parents'/legal representatives' contacts, etc.).

4. Purposes of Processing

4.1. Data are processed in order to:

• respond to your inquiries;

• process camp applications or registrations;

• send updates and information about our services (with consent);

• improve website functionality and user experience;

• ensure the Platform's technical operation for camp organisers who process their clients' (end users') data via the website.

  4.2. In addition, health data (e.g., information about allergies, chronic conditions, medicines used and physical load limitations) are processed only with the prior explicit consent of the child's legal or authorised representative and only for ensuring the child's safety and health during the camp.

  4.3. Such data are generally stored for no longer than 3 years after the end of the relevant camp or until consent is withdrawn, unless the relevant camp organiser as data controller sets a different retention period. However, such data may be stored longer where required by a legal obligation or where necessary to defend legal interests (e.g., investigation of an accident or legal proceedings).

5. Legal Basis

5.1. Personal data are processed on the basis of:

• your consent;

• performance of a contract;

• legal obligations;

• our legitimate interests;

• where we act as a data processor – on the basis of a contract with the relevant camp organiser (data controller).

  5.2. Processing of personal data is carried out in accordance with Article 6(1)(a), (b) and (c) of Regulation (EU) 2016/679 (the GDPR).

  5.3. Where we act as a data processor, the legal basis for processing derives from the contract between the data controller (the camp organiser) and the data subject (e.g., the child's legal representative).

6. Processing of Children's Personal Data

6.1. Children's personal data submitted via the Platform are processed on behalf of and under the responsibility of camp organisers, based on the processing purposes determined by the camp organiser as data controller and the concluded data processing agreement. In such case, SIA "Nuvilo" acts as a data processor, while the relevant camp organiser is the data controller.

6.2. Children's personal data are processed based on the application and consent submitted by the child's legal or authorised representative, as well as for the performance of the contract with the relevant camp organiser.

6.3. Children cannot independently register or use the Platform services – all applications are submitted and approved through applications by legal or other authorised representatives.

6.4. Processing of special categories of data (e.g., health information) is carried out in accordance with Article 9(2)(a) of the GDPR – based on the data subject's explicit consent.

7. Data Disclosure

7.1. We do not disclose your data to third parties for sale. Data may be disclosed to:

• service providers (website maintenance, IT support, etc.);

• public authorities, where required by law;

• camp organisers acting as data controllers and receiving end users' applications and information within their camp;

• sub-processors (e.g., email service providers, data hosting) used to ensure the Platform's operation.

  7.2. Disclosure of data to camp organisers and their designated persons (e.g., camp leaders, medical staff, teachers or instructors) takes place only to the extent necessary to ensure the safe conduct of the camp.

  7.3. In certain cases, personal data may be processed outside the European Economic Area (e.g., when using email service providers), applying the Standard Contractual Clauses approved by the European Commission.

8. Data Retention

8.1. Personal data are stored only for as long as necessary for the specific purpose or for the period required by law.

8.2. Where we act as a data processor for a camp organiser, data retention periods are determined by the relevant data controller (the organiser), and we store data only within the scope and term defined by the data controller.

9. Security of Personal Data

9.1. We implement technical and organisational security measures to protect personal data against accidental or unlawful destruction, loss, unauthorised access, disclosure or other unlawful forms of processing.

9.2. Data are stored in secure IT systems with restricted access, regular backups, and safeguards against unauthorised data leakage or alteration.

10. Your Rights

10.1. Under the GDPR, you have the right to:

• request access to your data;

• request rectification or erasure of your data;

• object to processing;

• withdraw consent at any time;

• lodge a complaint with the Data State Inspectorate.

  10.2. If your data were submitted in relation to a specific camp, please contact the relevant camp organiser, who is the data controller.

11. Cookies

11.1. We use cookies to improve website performance and analyse user behaviour. You can manage cookie settings in your browser.

11.2. Non-essential (marketing and analytics) cookies are loaded only after the user's consent is obtained via the cookie banner.

12. Automated Decision-Making

The Platform does not carry out automated decision-making or profiling within the meaning of Article 22 of the GDPR that would produce legal effects or similarly significantly affect data subjects.

13. Changes to This Policy

13.1. We may update this Privacy Policy from time to time to reflect changes in the Platform's operation or applicable laws.

13.2. If changes are material, the Platform Operator may notify users using the email address provided in the Platform or other communication channels.

14. Contact

If you have questions about this Privacy Policy or data processing, please contact us:

• General Platform inquiries: [email protected]
• Data protection matters: [email protected]