PRIVACY POLICY

Last updated: 03.06.2026

1. General information

This Privacy Policy sets out how SIA "Jurmala Invest" processes personal data through the internet platform Komercregistrs.lv (hereinafter – the Platform).

The Platform processes personal data in accordance with:

• Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR);
• the Personal Data Processing Law;
• other applicable regulations of the Republic of Latvia and the European Union.

2. Legal basis for processing personal data

The Platform may process personal data on the basis of:

• the user consent;
• the performance of a contract or provision of a service;
• compliance with a legal obligation;
• the legitimate interests of the Platform;
• other bases provided for by law.

3. What data is processed

Depending on the services used, the Platform may process:

• name and surname;
• email address;
• phone number;
• user account information;
• IP address;
• browser and device technical information;
• data entered for document generation;
• listing information;
• licence information;
• security and system log information.

The Platform does not process the content of user invoices or the content of customer databases in the KomercRēķini local application.

4. Document generation

The Platform provides automated document preparation based on information entered by the user.

The Platform does not perform:

• the provision of legal consultations;
• individual legal assessment;
• legal or factual verification of user data.

The user is fully responsible for:

• the accuracy of entered data;
• checking generated documents;
• submitting documents to the relevant institutions.

5. Document storage

Generated documents are stored for up to 48 hours from the time of creation to allow repeated downloading.

After this period, documents are deleted from the active system, except where their temporary retention is necessary for the operation of backups or security mechanisms.

6. Registered users and listings

Certain Platform functions are available only to registered users.

Listings are published for 30 days from the time of publication.

After the period expires, the listing is deactivated or removed from public access.

The Platform may retain limited technical information about a listing for the purposes of security, dispute resolution, or compliance with regulatory requirements.

The Platform has the right to:

• restrict access;
• delete content;
• suspend a user account.

7. Partner services and third parties

The Platform may display information about:

• financial services;
• fintech solutions;
• payment services;
• business support solutions.

Some links may be partner or referral links.

The Platform may receive a commission for certain registrations or service usage.

8. KomercRēķini application

KomercRēķini runs locally on the user device.

The Platform does not access:

• invoice content;
• customer lists;
• financial documents;
• user business data.

For licensing purposes, the following may be processed:

• licence identifier;
• device identification hash;
• application version;
• licence status.

9. Recipients of personal data

If necessary, data may be transferred to:

• hosting service providers;
• IT system maintainers;
• accounting service providers;
• state authorities in cases provided for by law;
• other cooperation partners, if necessary for the provision of the service.

10. Data transfer outside the European Economic Area

In principle, the Platform does not transfer personal data outside the European Economic Area.

If such a transfer is necessary, it will take place only in accordance with the requirements of the GDPR.

11. Personal data retention periods

• Contact form data – up to 2 years;
• User account data – while the account is active;
• Listings – 30 days of public availability;
• Generated documents – up to 48 hours;
• Security logs – up to 12 months;
• Licensing data – during the term of the licence and the period set by law.

12. Data security

The Platform uses:

• HTTPS encryption;
• access control;
• audit logs;
• security monitoring;
• the data minimisation principle.

13. User rights

The user has the right to:

• request access to their data;
• request rectification of data;
• request erasure of data;
• restrict data processing;
• withdraw consent;
• receive a copy of the data;
• submit a complaint to the Data State Inspectorate.

14. Automated decision-making

The Platform does not carry out automated decision-making or profiling within the meaning of Article 22 of the GDPR.

15. Minors

The Platform is not intended for persons under 18 years of age.

If it is found that personal data has been obtained without an appropriate legal basis, the Platform may delete such data.

16. Cookies

The Platform may use technical and analytical cookies.

More information is available in the Cookie Policy.

17. Changes to the policy

The Platform reserves the right to make changes to this Privacy Policy.

The current version is always published on the Platform.