Last update: [15.08.2017]
1. General Provisions
We, TSC Authorised Service Centre, tel. +371 67 808 808,,, (hereinafter – We) always provide our customers with new Services, corresponding with modern standards. Not only is the convenience and possibilities provided by the Services We offer important to us, but also the Privacy protection of the Customers. We invest resources, in order for our Customers to feel safe, and during our daily activities We take care to ensure Customer data is protected.
The purpose of this Privacy Policy is to inform you about the protection of Customers’ privacy provided by us, to provide an explanation on how We protect personal data of Customers, and help Customers to understand how the personal data of Customers are processed and what the rights and obligations of us and the Customers are.
When processing personal data, We comply with the regulatory enactments being in force in the state and binding instructions and regulations issued by the responsible authorities, as well as regulatory enactments of the European Union, including, but not limited to, requirements determined in the area of data processing, fair commercial practice and protection of consumer rights.
This Privacy policy shall be applicable to the mutual relations between us and the Customer, including that it shall refer to every current Customer, buyer or any other person who uses or has shown an intention to use any of our services, or who turns to us with any kind of request or claim, submits any kind of document, visits our webpage or Customer Service centres and outlets, or other objects or events organised by us, or communicates with us by using distance communication means, including mail, e-mail or telephone (hereinafter all collectively referred to as - Customer).
This Privacy policy shall not be applied to data processing measures performed by other merchants, including if the Customer visits a webpage of another merchant or uses the services of another merchant and reaches the webpage or service through our communication channels, including the webpage. In such cases, please, become acquainted with the personal data processing guarantees provided by the relevant merchant.
We have created this Privacy policy as simple as possible, however if you are not familiar with terms such as “anonymised data”, “personal data” etc., please, first become acquainted with the terms below, used in this Privacy policy:

  • Personal data - any information, referring to the identified or identifiable natural person (data subject), such as the first name, surname etc.
  • Anonymised data - information, which is not Personal data and is not to be referred to a natural person anymore, because all elements identifying the person are excluded from the set of information.
  • Services - all types of services We offer in person or remotely.

2. How do We acquire Personal data and what is the basis for data processing?
We offer a broad range of Services to our Customers. Information that We acquire on the person depends on the Service, which the Customer uses or for which the Customer has applied. Besides, We acquire the information that the Customer has provided to us within the framework of any kind of cooperation.
We may receive the Personal data in several ways, including as follows:

  • The Customer has provided his/her Personal data to us, i.e., when the Customer or authorised person of the Customer contacts or cooperates with us or our authorised persons, for example, using our Services, or requests any information or submits an application regarding a review of the specific issue or request, visits our Customer service centres, or contacts us on the specified informative channels.
  • Data are created by using our Service, such as by making a call or visiting or using our webpage.
  • We can receive data from other sources, for example, if the Customer makes contact with us at other service providers or cooperation partners, for example, regarding the acquisition of devices or accessories thereof, delivery of shipments or settlement of the issues of repair of devices. In order to fulfil the requirements of regulatory enactments and ensure long-term cooperation possibilities, the need may arise for us to also request data from publicly available registers, within the framework of regulatory enactments.

The Customer shall be entitled to refuse to provide us with his/her Personal data, however in such a case it is possible that We will not be able to provide the Services requested by the Customer and the provision of the transaction will be refused.
We perform Data processing in accordance with the specific basis of data processing only, including, on the basis of the request of the Customer and provision of the transaction related to it; scope of the consent provided by the Customer; fulfilment of requirements stipulated by regulatory enactments, as well as the protection of legitimate interests of us and third persons that We perform, considering the balance between the rights and interests of the Customer.

3. What Personal data do We acquire?
Types of Personal data may differ, depending on the used Service or cooperation. General Personal data may be distributed into the following categories of Personal data:

  • Basic information, including the first name, surname, contact phone, e-mail address;
  • Data related to the relationship with the Customer, for example, information on the Service provided to the Customer and data arising from the provision of the Service, such as, acquisition of devices or accessories and documents confirming the transaction in relation to this; data of shipment delivery service; data on repair of devices and in relation to this, including the producer of the device, model, IMEI code, complete set, description of defects, visual image - assessment, security code, if any; or data available within the framework of the data storage service for devices; documents related to payments and data thereof; communication data of the Customer that we receive during the contact in the presence of or remotely with the Customer, such as e-mail messages addressed to us, applications or information provided during the phone call conversation and agreements concluded with the Customer; requests of the Customer or prohibitions to process specific data for the relevant purpose;
  • Data acquired on the basis of the consent of the Customer and defined at the moment when the consent is given. The Customer shall be entitled to revoke the consent given to us at any time in the manner which is as simple as it was given, including by using our channels of communication. The consent shall be effective until the fulfilment thereof or revocation accordingly, if it is earlier. Revocation shall not affect the lawfulness of processing, which is based on the relevant consent before revocation.

We shall not deliberately collect and process personally identifiable information from persons, who are below the age set by regulatory enactments, giving the right to act independently. We respect the rights of such persons and in the case of need for the Services We recommend the parents or guardians of such persons to contact us.
4. How do We use Personal data?
We process the Personal data in order to provide Services, effective Customer service, cooperation and other activities significant for our activity and Customers.
In order to protect the Personal data of our Customers, We prefer Anonymised data processing to prevent identification of the person. However, We quite often have the need to process identifiable Personal data, considering the essence of the provided Service or cooperation, as well as the requirements of binding regulatory enactments. In such a case We process the data, taking into account the applicable basic principles for data processing, in particular the minimisation principle for data processing and other requirements provided by regulatory enactments.
We only process the Personal data for particular necessary purposes, such as:

  • Service provision quality control. The quality of provided services and implementation of the Customer’s rights provided by regulatory enactments for the receipt of Services appropriate for the transaction is important for us, therefore in certain cases the Personal data may be processed for the purposes of quality control.
  • Settlement of the issues applied, including review and settlement of various applied issues or complaints.
  • Provision of services and fulfilment of the transaction. We process the data in order to provide the Services. For example, We process the data, in order for it to be possible to perform the applied repair of the device or the applied order delivery. We process Personal data during the communication with the Customer, for example, send service notifications related to the Service, in order to provide information on the result of the fulfilment of the service or provide other important information to the Customer. Besides, the need may appear for us to contact the Customer in relation to the Service provision, in order to specify, for example, the information of the applied order, description of the submitted application for repair or establish any other additional information, facilitating the course of processing of the transaction. In order to ensure traceable fulfilment of the transaction, our meetings and negotiations with the Customer regarding settlement of the particular issue may be recorded in writing. Within the framework of transactions, in order to fulfil the provisions of accounting We have to perform the administering of payments, as well as recording of provided Services. In cases when the Customer has not paid for the provided Services in full, We need to implement processes for the receipt of the remaining payments, in accordance with the procedure provided by regulatory enactments.
  • Making proposals. We consider the rights of every Customer to give, revoke or change the possibilities for the receipt of information. In cases when the Customer has shown an intention to receive information or provide an opinion regarding the particular products or Services, the Personal data may be processed, in order for it to be possible to provide the Customer with the necessary information. In such cases the consent of the Customer is always important. If the consent of the Customer refers to the receipt of information from the cooperation partner, for example, in order for the producer to contact the Customer and establish the satisfaction of the Customer with the products of the trademark of the particular producer and in the case of repair for it to be possible to assess the quality of the repair of the device, the Customer data, such as the first name, surname, contact phone and e-mail in the consent given by the Customer, may be provided to the specific producer.
  • Fulfilment of the binding regulatory enactments. We process Personal data in order to fulfil the obligations set by regulatory enactments, for example in order to ensure data availability to competent authorities, including in order to provide replies to the requests from authorities and courts received within the framework of regulatory enactments, as well as implement the rights provided for the Customers within the framework of the regulatory enactments and liabilities imposed upon us as a merchant.
  • Security of persons and objects. We can process Personal data in order to ensure the security, elimination of an unlawful or other threat, facilitation of the detection of criminal offences in our objects and territory adjacent to them, in order to ensure the security of our employees, Customers, including our objects and visitors of events organised by us.
  • Other purposes, including the purposes for which the Customer has given his/her consent. Data processing may also be performed within the framework of legitimate interests, for example, when the Customer participates in the events organised by us, for example, visits the presentations organised by us or participates in product launch events. In order to provide and improve our Services and develop principal activities, We can process data for statistical purposes and a summary of business information and analysis, in order to enable us to make informed decisions regarding the improvement of activity and protection, as well as to prepare reports on the results of our commercial activity.

In all cases We only process Personal data to the extent it is necessary for the purpose, considering the Privacy of every person.
5. How do We protect Personal data?
We ensure confidentiality of Personal data, performing the appropriate safety measures and following the requirements of regulatory enactments and obligations provided therein.
For the purpose of the protection of Customer’s interests We constantly develop our security processes and measures. Such security measures include the protection of personnel, information and technical resources, IT infrastructure as well as the building, where We operate. We provide the appropriate information protection level within the framework of such measures, in order not to permit unauthorised access of third persons.
6. To whom may We provide Personal data?
Personal data exchange may be necessary in certain cases, when it has the particular provided purpose, for example, We could have the need to provide Personal data to the following categories of data recipients:

  • Companies of our Group for information processing within the framework of regulatory enactments, including in order to ensure the appropriate management of Group companies.
  • Cooperation partners, including cooperation partners for the provision of Services, quality control and development, as well as the partner, providing certain delivery services, services of protection of persons, objects and information protection and security and other Services. For example, We cooperate with producers who process Personal data, in order to provide the repair guarantees provided in the service instructions of the device in accordance with regulatory enactments. In such cases, the personal data of the Customer (first name, surname, contact phone and e-mail, if any is provided), necessary for fulfilment of the transaction, data of the device necessary for the provision of repair and copies of documents certifying the purchase (transaction) of the device, may be delivered to the producer of the Customer’s device or the persons specified by him/her as a manager, in order to implement the purpose of processing - provision of the repair transaction. In case of need We cooperate with our partners, providing the delivery of orders to Customers. Grounds for such data processing shall be Customer’s applications - provision of transaction and fulfilment of regulatory enactments. Such cooperation partners may only use Personal data for the purposes, regarding which We have agreed with the cooperation partner. We follow the appropriate care, in order to ensure that such cooperation partners operate in accordance with the present Privacy policy and security requirements provided for the Customers by regulatory enactments.
  • Law enforcement authorities. In order to fulfil the requirements of regulatory enactments, the need may arise for us to provide Personal data to different state and/or local authorities, or court authorities, in accordance with the provisions of regulatory enactments.
  • Other persons. Data may be processed in accordance with the consent or request made by the Customer, including, in the case if the Customer has agreed on further use of data for the purpose defined by the third person. For example, in the case if the Customer uses the device of any specific producer and the Customer has agreed that the producer contacts with the Customer in order to establish satisfaction of the Customer with the products of its trademark and for assessment of the quality of performance of repair. In such a case the Customer’s data shall be received and processed by the particular producer, in order to contact the Customer.

In addition to the above mentioned, there may be cases, when We can deliver the Personal data to another person in relation to the transfer of companies, any merger, acquisition, selling of our assets or delivery of the provision of Services to other merchant.
We can also process Anonymised data. Such data that do not provide an opportunity to identify the person, may be used for other purposes and delivered to other persons.
7. How long do We store data?
We only store the Personal data for the time period, which is necessary in order to achieve the purposes set in this Privacy policy, unless the longer storage thereof is determined or permitted by the applicable regulatory enactments. In order to determine the time period for data storage We use criteria, corresponding with the liabilities set by regulatory enactments, including We also consider the rights provided for the Customers, for example, determining of data storage for the time period during which the claims related to the transaction, if any appear, may be applied.
Restrictions shall not be applicable for the storage of anonymised data.
Our purpose is to ensure that the information on the Customer is correct and updated. Therefore We invite the Customer to inform us of any changes in the information provided by the Customer.
8. What are the rights of the Customer and what do We expect from the Customer?
Rights of the Customer:

  • to submit an application and receive information on the data that We acquire and store about the Customer, unless the applicable regulatory enactments provide otherwise. the Customer may acquire the information him/herself by contacting us in writing or visiting our Customer service centres;
  • to claim access to his/her data, the correction or deletion thereof, or restriction of processing, as well as to implement the rights to object against the processing, including to object against data processing, which is performed within the framework of legitimate interests to the extent it is provided by regulatory enactments, as well as to use the rights on data portability;
  • to revoke the consent provided to us by the Customer, at any time. Giving of consent or revocation shall be the free choice of the Customer and it shall not impose any mandatory additional obligations. However, if the Customer decides to revoke any consent, it should be taken into account that data processing related to the consent will not be provided anymore and the possibilities may not be available to the Customer in the previous amount. For example, revocation of the receipt of current news will mean that new or other current events will no longer be delivered.
  • to contact the supervisory authorities, including to submit the review of the issue to authorities supervising the requirements for data processing.
  • to contact us regarding all issues topical for the Customer, including on the Privacy policy and applicable data protection. We will provide a reply as soon as possible, but not later than within one month from the receipt of the application, unless the scope of the issue will cause the need for additional time.

Responsibility of the Customer:

  • to inform us on changes in the provided information and data. It is important for us that true and topical information on the Customer is available at our disposal;
  • to provide necessary information in order for us to identify the Customer in relation to the request of the Customer and be sure that communication or cooperation is performed correctly with the particular Customer. It is necessary for the protection of personal data of the Customer and other persons, in order for us to ensure that the right Customer is the subject of Personal data and that the information disclosed within the framework of communication and/or cooperation on the Customer is provided only to the Customer, without violating the rights of other persons. For example, in the case if the Customer wants to establish information about him or herself by sending a request to us. In such a case it is important for us to make sure that the Customer is the one who has submitted and signed the request. Accordingly, We may ask you to provide additional identifiable information. However, if the Customer fails to provide additional information and/or if We have doubts about the person requesting information, for the purpose of protection of the Customers’ data (in order for the data not to be disclosed to third persons) We can refuse to disclose data until the day when We are sure of the fact that the right Customer has requested the above mentioned information.
  • Before the commencement of cooperation with us, to become acquainted with the present Privacy policy, as well as introduce every person who is related with the Customer and whose interests may thus be affected during the Customer data processing processes, with it. This Privacy policy shall become as an integral part of the Services provided by us. We expect the Customer to use the data provided to us in good faith and not affect the legal interests of other persons. In cases when in accordance with the relevant provisions the Customer has a possibility to provide access or enable another person to jointly use his/her Services and/or devices, the Customer shall be responsible for ensuring that such persons are informed of the data processing performed within the framework of particular processes and the liabilities arising therefrom. In cases when the data refer to another person in a direct way (in the case of change of data subjects), the Customer shall be responsible to inform us of this without delay. Until full identification of persons the data shall refer to the Customer as a data subject.

9. How to find out the information about changes in this Privacy policy
We constantly improve and develop our operation by amending and supplementing this Privacy policy from time to time. Therefore We recommend Customers to regularly become acquainted with the updated version of the Privacy policy on our webpage and our other communication channels. We will provide information with a notification on our webpage when We make changes to the present Privacy policy.
10. How to contact us
In the case of any questions regarding this Privacy policy or the implemented Personal data processing, please, contact us or our data protection specialist by using the contact information specified in this Privacy policy.

Privacy Policy PDF file