PRIVACY POLICY

Definitions:

Website – the website managed by ALI MARKETING at www.dodok.eu;

User – any person who uses or has used the Website;

Controller, ALI MARKETING – SIA ALI MARKETING, unified registration number: 40203478175, legal address: Zemzaru iela 3, Marupe, Marupe municipality, LV-2167, email address: support@dodok.eu

Data Subject – User or person whose data is submitted to the Controller through the Website

Regulation - 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

Privacy Policy – this ALI MARKETING privacy policy.

1. General Information

ALI MARKETING is the owner of this website, responsible for its maintenance and management, facilitating the exchange of information between service recipients and providers.

The objective of the Privacy Policy is to provide information to the Data Subject regarding the processing of personal data carried out by ALI MARKETING, including the purpose, legal basis, scope, protection, and the options for exercising the rights of the Data Subject.

ALI MARKETING processes the personal data of individuals in accordance with the requirements of the Regulation, the laws of the European Union and the Republic of Latvia, and best practice guidelines, adhering to confidentiality requirements and ensuring the security of the personal data in its possession.

In its operations, ALI MARKETING:

• implements proportionate and appropriate physical, technical, and administrative procedures, security measures, and tools to protect the personal data collected and processed by ALI MARKETING;
• conducts regular training and informs its employees about data protection issues to reduce the likelihood of potential incidents;
• implements internal control procedures to reduce the likelihood of security incidents and mitigate their consequences;
• Carries out data transfers to third parties in compliance with applicable regulatory requirements.

ALI MARKETING is committed to ensuring the accuracy of personal data and relies on Users to provide complete and accurate data.

To keep Users informed about the processing of their personal data, ALI MARKETING regularly reviews and updates the Privacy Policy in accordance with regulatory requirements. Therefore, we encourage you to periodically review the current version of the Privacy Policy on the website.

ALI MARKETING reserves the right to make changes to its data processing policy by publishing the updated policy on the website.

For specific data processing purposes, the data processing policy may be published separately for transparency purposes.

2. Controller of Personal Data Processing

SIA ALI MARKETING,

Registration Number: 40203478175,

Legal Address: Zemzaru iela 3, Marupe, Marupe municipality, LV-2167

Email address for communication regarding personal data processing: support@dodok.eu.

3. Scope of Application of the Privacy Policy

The Privacy Policy applies to the protection of privacy and personal data for data subjects, including:

• Individuals who have used, are using, or have expressed a desire to use the website;
• Website visitors;
• Third parties whose personal data is submitted by the User.

 

4. Purposes of Personal Data Processing, Legal Basis, Categories of Processed Data

Purposes of Processing	Legal Basis	Categories of Processed Data
For the maintenance and improvement of the website	Please familiarize yourself with the Cookie Policy to learn how we use cookies and how it impacts your browsing experience on our website (https://dodok.eu/en/cookies)	Please familiarize yourself with the Cookie Policy to learn how we use cookies and how it impacts your browsing experience on our website (https://dodok.eu/en/cookies)
Receiving updates about ALI MARKETING information Participating in user surveys	Data subject consent (Article 6(1)(a) of the Regulation).	User contact information: phone number and/or email address.
Initiation of contractual relations, provision of services, fulfillment of other obligations, and ensuring compliance	·   Conclusion and execution of a contract with the data subject (Article 6(1)(b) of the Regulation); ·   Fulfillment of a legal obligation (Article 6(1)(c) of the Regulation); ·   Controller's legitimate interests (Article 6(1)(f) of the Regulation), such as providing communication with the User.	User identification information, personal identification document information, and contact information Watercraft registration data, parameters, location Identification data of third parties, personal identification document information, and contact information Data on watercraft insurance (yes/no) Payment card details, selected payment method/tool Reserved and used services Location, history of used services, and payment Customs declaration data Information on applications to Border Guard, Police, Emergency Medical Assistance, port assistant
User identification	Data subject consent (Article 6(1)(a) of the Regulation).	Phone number

 

5. Methods of Data Acquisition, Obligation to Provide Data

ALI MARKETING obtains data in various ways:

• Directly and indirectly from the Data Subject;
• From third parties (e.g., the User provides data of watercraft crew members for receiving services or communicating with ALI MARKETING).

The User is not obligated to provide personal data to ALI MARKETING. However, if the User chooses not to provide the necessary personal data, ALI MARKETING may not be able to provide the selected services to the User.

6. Storage Duration of Personal Data

ALI MARKETING stores and processes personal data as long as at least one of the following criteria exists:

• There is a legal obligation to retain data for a specific period according to regulatory acts;
• It is necessary to pursue ALI MARKETING's legitimate interests;
• It is necessary to fulfill contractual obligations;
• The User has given consent for specific data processing, and there is no other legal basis for further data processing (the User has the right to withdraw consent at any time by sending a notice to ALI MARKETING's email address);
• Until the conditions specified in the current regulatory acts allow ALI MARKETING or the Data Subject to pursue their legitimate interests (e.g., submit objections or bring a claim to court);
• For a period specified in ALI MARKETING's internal regulatory acts (including the time indicated in the Privacy Policy and Cookie Policy).

When the conditions determining that there is no longer a legal basis for further storage of personal data are met, the personal data of the Data Subject is deleted or destroyed.

7. Updating of Personal Data

ALI MARKETING relies on the User to provide accurate information and precise personal data, including the expectation that, after personal data has been provided to ALI MARKETING, these data will be kept up-to-date. If changes occur in the submitted personal data that are relevant to the purpose of processing and comply with regulatory requirements, the personal data will be updated.

8. Transfer of Personal Data

ALI MARKETING transfers personal data to:

• Collaborative partners (processors or separate controllers) associated with the provision of services. In cases of necessity, ALI MARKETING may involve a natural or legal person, a public institution, agency, or other structure processing personal data on behalf of ALI MARKETING (hereinafter - Processor) and having the necessary knowledge and skills required for the provision of specific services. The mutual legal relations between ALI MARKETING as the controller and the Processor are always regulated by a written agreement. In accordance with regulatory requirements and the cooperation agreement concluded with ALI MARKETING, the Processor is assigned a set of measures to ensure adequate privacy and personal data protection for Data Subjects. ALI MARKETING's collaborators process personal data only in accordance with ALI MARKETING's instructions and may not use them for other purposes.
• External entities specified in regulatory acts (border guard, customs, law enforcement agencies, court, or other state and municipal authorities) to fulfill a legal obligation. The transfer of personal data is carried out if a written request is received or if a legal situation specified in regulatory acts has arisen, and the legal basis for such data processing is established. The transfer of personal data is performed in the manner and scope provided by the relevant regulatory act.
• Third parties in cases specified in regulatory acts to protect ALI MARKETING's legitimate interests (e.g., in court).

In its daily work, ALI MARKETING takes measures to minimize the scope of personal data processing in relation to its employees, stipulating that employees have access only to the data of Data Subjects necessary for the performance of work duties.

ALI MARKETING ensures that the personal data it possesses is issued only to the Data Subject. The issuance of data to third parties, including those related to the Data Subject, is carried out only in cases where clear written consent from the Data Subject has been received or when there is a case specified in regulatory acts allowing such data transfer.

ALI MARKETING does not transfer data in cases where it cannot verify the identity of the Data Subject or if there are suspicions that the identity presented by the Data Subject does not match their true identity.

In cases where data transmission is carried out using email communication options, ALI MARKETING ensures that such action is carried out only after receiving the Data Subject's consent, either in writing or orally (documented by an employee), specifying the email address to which the Data Subject wishes to receive the correspondence. When transmitting data using email communication options or other online data exchange solutions, such as self-service platforms, ALI MARKETING takes measures for the protection of the relevant data by applying data access protection or encryption methods.

ALI MARKETING transfers the Data Subject's data outside the European Union and the European Economic Area (EU/EEA) if the place of service provision is outside the EU/EEA.

In cases where personal data is sent outside the EU/EEA, ALI MARKETING implements additional security measures to ensure that the processing of personal data in third countries will comply with an equivalent level of protection of the rights of data subjects—data processing will be legal and proportional, data will be secure, and the rights of the data subject to control their data, etc., will be respected.

If ALI MARKETING's collaboration partners—Processors who process Data Subject data—perform this processing outside the EU/EEA, ALI MARKETING ensures that, with regard to data security and technical requirements, the respective service providers comply with the requirements specified in the Regulation and other regulatory acts of the European Union and the Republic of Latvia, as well as good practice guidelines.

9. Automated Decision-Making

ALI MARKETING utilizes an automated decision-making system. Automated decision-making ensures a lower probability of errors and is more efficient and secure compared to decisions made personally by ALI MARKETING employees.

By agreeing to this Privacy Policy, the Data Subject simultaneously consents to the automated decision-making concerning them.

When evaluating the need to suspend the provision of services, information is taken into account regarding whether the Data Subject has made a payment for the received and/or reserved services.

An automated decision to suspend a service is made if: (i) no payment has been made for the previously received service, or (ii) there are insufficient funds in the attached payment instrument to cover the reserved services.

We encourage you to always exercise your right to contact ALI MARKETING using the email address support@dodok.eu and dispute the decision if you disagree with it. You can also request a reconsideration of the decision, express your opinion, and receive clarification.

10. Data Subject's Rights Regarding ALI MARKETING's Processing of Personal Data

In compliance with the regulatory requirements governing privacy and the protection of personal data, ALI MARKETING ensures that the Data Subject has the following rights based on their written request:

• Access to Personal Data: The Data Subject has the right to receive confirmation from ALI MARKETING regarding whether their data is being processed or not. If their data is being processed, the Data Subject has the right to access their data and receive the following information: the purposes of data processing, categories of personal data, recipients of personal data, the duration of data storage, or the criteria used to determine the storage period.
• Correction of Personal Data: The Data Subject has the right to request the correction of their data if they find that the information about them held by ALI MARKETING is incorrect or incomplete.
• Deletion of Personal Data: The Data Subject has the right to request the deletion of their data if at least one of the following conditions exists:
  • The data are no longer necessary for the purposes for which they were collected or otherwise processed;
  • The Data Subject withdraws their consent for data processing, and there is no other lawful basis for the processing;
  • If data processing is based on ALI MARKETING's or a third party's legitimate interests, but there is no compelling legitimate reason for the processing;
  • The Data Subject objects to the processing of their data for direct marketing purposes;
  • The data have been processed unlawfully.
  • To ensure compliance with a legal obligation imposed on ALI MARKETING by applicable regulations.
• Restriction of the processing of personal data: The Data Subject has the right to request the limitation of the processing of their personal data held by ALI MARKETING.
• Objection to the processing of personal data: The Data Subject has the right to object to the processing of their personal data based on ALI MARKETING's legitimate interests.
• Data portability: The Data Subject has the right to receive or transfer their personal data to another data controller ("data portability"). This right applies only to the data provided by the Data Subject based on their consent or a contract and when the processing is carried out by automated means.

The Data Subject's request must be in writing, signed with a personal signature, or in the form of an electronic document signed with a secure electronic signature.

ALI MARKETING will respond to the request without undue delay and within one month of receiving the request, or may extend the response time by two months, taking into account the complexity and number of requests. The Data Subject will be informed of any extension and the reasons for it. The response will be provided in the preferred format indicated by the Data Subject, to the extent possible.

Requests can be submitted in person, by post, or courier to ALI MARKETING's legal address, or electronically with a secure electronic signature to the email address: support@dodok.eu.

If the Data Subject faces difficulties in submitting a written request, they have the right to express the request verbally in person by contacting ALI MARKETING at the legal address, by prior appointment over the phone. In such cases, the responsible employee of ALI MARKETING will formalize the request in writing, and the Data Subject, after identification and verification, will sign it.

11. Protection of Personal Data

ALI MARKETING ensures the non-disclosure and security of Data Subject's personal data by utilizing modern technological capabilities, considering existing privacy risks, and reasonably available organizational, financial, and technical resources. This includes ensuring the physical and environmental security of Data Subject's personal data, restricting access rights to authorized ALI MARKETING employees who need it for their job duties, sending Data Subject's personal data in encrypted form, ensuring network and device protection, data backup, implementing internal control procedures to reduce the likelihood of security incidents, providing employee training and information on aspects of personal data processing, and implementing other protective measures to safeguard Data Subject's personal data against unauthorized access, use, or disclosure.

Processors to whom ALI MARKETING entrusts the processing of Data Subject's personal data are evaluated and informed of the set of measures they need to take to ensure the processing, confidentiality, and protection of Data Subject's personal data in accordance with regulatory requirements and the cooperation agreement concluded with ALI MARKETING.

ALI MARKETING continuously improves and supplements its existing technical solutions, taking into account current industry trends and available opportunities, based on identified risks.

12. Receipt of Additional Information and Submission of Complaints about Data Processing

For questions related to the processing of Data Subject's personal data (including providing feedback, expressing objections to the personal data processing processes, making requests), and if you believe that your rights to the protection of personal data have been violated by ALI MARKETING when processing your personal data, please contact ALI MARKETING via email: support@dodok.eu.

If you are not satisfied with the received response, you have the right to submit a complaint to the Data State Inspectorate Republic of Latvia (address: Elijas iela 17, Riga, LV-1050; email: pasts@dvi.gov.lv; phone Nr.: +371 67223131.