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Privacy Policy
10/10/2023 revision

    The purpose of this Privacy Policy is to provide information regarding the processing of personal data by Balticom. This Privacy Policy applies to the processing of personal data of Balticom’s customers, website visitors, and cooperation partners.

    Data Controller and Its Contact Information

  1. The data controller for personal data is AS Balticom (hereinafter – Balticom), with registration number 40003443452, and its registered address in Riga at Straupes iela 5/k-3.
  2. Balticom’s contact information for matters related to personal data processing is: klients@balticom.info By using this contact information or by writing to Balticom’s registered address, you can obtain information regarding the processing of personal data by Balticom. A request to exercise your data subject rights may be submitted in accordance with these terms.
  3. Scope of the Document

  4. Personal data means any information about an identified or identifiable natural person. Definitions of personal data, explanations, and the categories of data processed by Balticom are specified in the appendix.
  5. This Privacy Policy applies to the protection of privacy and personal data in relation to:
    1. natural persons – customers, subscribers and other users of Balticom services (including potential, former, and current ones) and related third parties (contacts, payers, etc.);
    2. visitors of Balticom offices and other premises;
    3. visitors of Balticom maintained websites and social network profiles, users of mobile applications, and callers to Balticom contact center phones (hereinafter – Customers);
    4. participants in Balticom marketing campaigns;
    5. owners of real estate that hosts Balticom’s electronic communication network and engineering communications.
  6. The Privacy Policy applies to data processing regardless of the form and/or medium in which Balticom processes personal data: in IT systems, on websites, in mobile applications, on the Balticom self-service portal, in paper form, by telephone, via videoconference, or using automated dialing and communication methods (robots and chatbots).
  7. For certain specific types of data processing (for example, the use of cookies), additional specific terms may be established, about which the Customer will be informed at the time when Balticom obtains the respective data.
  8. Purposes of Personal Data Processing

  9. Balticom processes personal data for the following purposes:
    1. For the provision of services and sale of goods:
      1. to identify the customer;
      2. to prepare, conclude, and prove the fact of concluding a contract;
      3. for the delivery of goods and installation and provision of services (performance of contractual obligations);
      4. to ensure/maintain the operation of the service;
      5. to fulfill warranty obligations;
      6. to improve goods and services, and to develop new goods and services;
      7. to promote, advertise, and distribute the service;
      8. for customer service;
      9. to review and process applications and objections;
      10. for customer retention, building loyalty, and measuring satisfaction;
      11. to administer settlements;
      12. to maintain and improve websites and mobile applications.
    2. To ensure the fulfillment of obligations:
      1. for credit assessment and credit monitoring;
      2. for debt recovery and collection.
    3. For business planning and analytics:
      1. for statistics and business analysis;
      2. for planning and accounting;
      3. for measuring efficiency;
      4. to ensure data quality;
      5. to conduct market and public opinion research;
      6. to prepare reports;
      7. to carry out customer surveys;
      8. within the framework of risk management activities.
    4. For compliance with legal requirements:
      1. to ensure the preservation of data;
      2. to provide information to state authorities and operational bodies;
    5. To ensure the security of information, information systems, and the company.
    6. For the maintenance and installation of the engineering communication network (coordinating network maintenance/installation/improvement works with land or building owners – with or without survey, in any manner).
    7. For other specific purposes, about which the Customer will be informed at the time he/she provides the respective data to Balticom.
  10. Legal Basis for Personal Data Processing

  11. Balticom processes the Customer’s personal data based on the following legal bases:
    1. for the conclusion and execution of a contract – to prepare and conclude a contract based on the Customer’s application and to ensure its execution;
    2. for compliance with regulatory requirements – to fulfill obligations imposed on Balticom by applicable external legal acts;
    3. based on the explicit consent of the Customer – data subject consent;
    4. for ensuring Balticom’s legitimate interests – to implement legitimate interests arising from legal acts or concluded contracts;
    5. for the protection of the vital interests of the data subject or another natural person – to ensure the physical and property security of Balticom’s employees, Customers, and visitors.
  12. Balticom processes the Customer’s personal data on the following legal bases:
    1. to conduct commercial activities;
    2. to provide electronic communication and other services, and to sell goods;
    3. to verify the Customer’s identity prior to concluding a contract;
    4. to ensure the performance of contractual obligations;
    5. to prevent unwarranted financial risks to its business (including conducting a credit risk assessment before selling goods and services and during contract execution);
    6. to retain Customer applications and submissions for the purchase of goods and provision of services, other applications and submissions, and related notes – whether made in writing or verbally, by calling call centers, on websites, or in self-service environments;
    7. to perform quality control of customer service, including by recording conversations with the Customer regarding the provision, maintenance, and settlements of services, and storing these records;
    8. to organize the performance of service contractual obligations, including by recording conversations with the Customer and storing such records;
    9. to provide evidence of the fact and content of verbally concluded contracts, the Customer’s expressed requests, and consents, including by recording and storing conversations with the Customer;
    10. to send commercial offers via email to registered prepaid service customers about similar services that the Customer uses or has purchased in the previous two years, provided that the Customer has not opted out of receiving such messages;
    11. to analyze the operation of Balticom’s website, websites, and mobile applications, and to develop and implement improvements;
    12. to administer the Customer’s account on Balticom websites, internet sites, and mobile applications;
    13. to perform activities for customer retention;
    14. to segment the customer database for more efficient service provision;
    15. to develop and improve goods and services;
    16. to advertise its goods and services;
    17. to send other notifications regarding the progress of contract execution and essential contractual conditions, as well as to conduct customer surveys about goods, services, and their usage experience (NPS);
    18. to ensure the maintenance and development of the electronic communication network;
    19. to maintain and develop the communication network;
    20. to monitor the operation of the communication network to detect technical problems as well as unlawful activities and to remedy them;
    21. to prevent fraud;
    22. to ensure corporate governance, financial and business accounting, and analytics;
    23. to ensure effective business management processes;
    24. to enhance the efficiency of service provision, sale of goods, and delivery;
    25. to ensure and improve service quality;
    26. to manage payments;
    27. to manage failed payments;
    28. to approach state authorities, operational bodies, or courts for the protection of its legal interests;
    29. to inform the public about its operations.
  13. Personal Data Processing

  14. Balticom cares about the privacy and protection of the Customer’s personal data and respects the Customer’s rights to lawful processing of personal data in accordance with applicable laws – the European Parliament and Council Regulation (EU) 2016/679 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 (the Regulation), the Law on Processing of Personal Data, and other applicable legal acts in the field of privacy and data processing.
  15. Balticom processes the Customer’s data taking into account the appropriate legal basis and in accordance with the principles of data minimization and transparency.
  16. In certain cases, Balticom may make automated decisions regarding the Customer.
  17. Automated decision-making that causes legal effects for the Customer (for example, approval or rejection of the Customer’s application) may only be carried out during the conclusion or performance of the contract between Balticom and the Customer, based on the Customer’s unequivocal consent or in cases provided by external legal acts.
  18. In certain cases, if the Customer refuses to give consent for automated decision-making, the Customer will not be able to use all the benefits (for example, to receive individualized commercial offers).
  19. For qualitative and operational performance of the contractual obligations with the Customer, Balticom may authorize Balticom group companies or its cooperation partners to carry out certain activities such as goods delivery or provision of services, for example, installation work, invoice dispatch, etc. If, in performing these tasks, Balticom group companies or cooperation partners process the Customer’s personal data that is in Balticom’s possession, the respective Balticom group companies or cooperation partners are deemed to be Balticom data processors, and Balticom has the right to provide such Customer personal data to Balticom group companies and cooperation partners to the extent necessary for the performance of these activities.
  20. Balticom’s engaged data processors ensure compliance with the requirements for personal data processing and protection in accordance with Balticom’s requirements and applicable legislation, and will not use the personal data for any purposes other than the performance of contractual obligations assigned by Balticom.
  21. Personal Data Protection

  22. Balticom protects the Customer’s data by using modern technological capabilities, taking into account the existing privacy risks and the reasonably available organizational, financial, and technical resources, including by applying the following security measures:
    1. encryption of data during transmission (SSL encryption);
    2. firewalls;
    3. intrusion detection and prevention programs;
    4. other protective measures in accordance with current technological developments.
  23. Sources of Personal Data

  24. Balticom obtains personal data from the following sources:
    1. directly from the Customer;
    2. from Balticom’s information systems;
    3. from intrusion detection and prevention programs;
    4. from credit history databases;
    5. from Balticom’s cooperation partners;
    6. from publicly available databases (www.zemesgramata.lv; www.kadastrs.lv; www.lursoft.lv, etc.).
  25. Categories of Data Recipients

  26. Balticom does not disclose the Customer’s personal data or any information obtained during the provision of services and contractual activities to third parties, except:
    1. if the data must be transferred to a third party under a concluded contract in order to perform a function necessary for contract execution or a legally delegated function (for example, to a bank within the framework of settlements or to a distribution network operator within the framework of electricity services), the Customer will be informed about this in the respective service contract;
    2. with the explicit and unequivocal consent of the Customer;
    3. to persons provided for by other applicable legal acts upon their justified request;
    4. for the protection of Balticom’s legitimate interests in the manner provided by law, for example, when approaching a court or other state institutions regarding a person who has infringed upon Balticom’s legitimate interests.
  27. Access by Third-Country Entities to Personal Data

  28. In certain cases, in compliance with regulatory requirements, personal data of individuals processed by Balticom may be accessed by cooperation partners located in third countries (i.e. countries outside the European Union and the European Economic Area) – for example, developers or service providers acting as data processors.
  29. In the cases mentioned in point 20, the cooperation partners engaged by Balticom in third countries ensure a level of data protection equivalent to that provided by Balticom.
  30. Duration of Personal Data Storage

  31. Balticom stores and processes the Customer’s personal data as long as at least one of the following criteria exists:
    1. the contract concluded with the Customer is in force;
    2. as long as, in the manner provided by external legal acts, Balticom or the Customer can exercise their legitimate interests;
    3. as long as one of the parties has a legal obligation to store the data (for example, according to the Accounting Law, invoices issued by the company must be stored for at least 5 years, etc.);
    4. as long as the Customer’s consent for data storage is in effect (this applies only in cases where there is no other legal basis for storing personal data (for example, in cases where the potential customer’s data have been obtained during a marketing activity)).

    After none of the legal bases for data processing exists, the Customer’s personal data will be deleted.

  32. Audit logs are stored for at least one year from the date of their creation in accordance with applicable legal acts. Audit logs from high-security information systems are stored for at least 18 (eighteen) months.
  33. Audio recordings of conversations with the Customer or correspondence regarding service provision, maintenance, and settlements, based on Balticom’s legitimate interests, are stored for 6 months after the recording or correspondence date, and are then deleted.
  34. Data of prepaid service customers are stored for 2 years after the end of service usage.
  35. Access to Personal Data and Other Rights of the Customer

  36. Balticom provides the Customer with all information provided by applicable legal acts regarding the processing of his/her data, as well as ensuring the exercise of all data subject rights as provided by law.
  37. Most of the information about the Customer’s data is available in the Balticom self-service portal “Mans Balticom”, on Balticom websites and applications used by the Customer to receive Balticom services, where the Customer can access his/her personal data, verify its accuracy, and, if necessary, manage or modify it.
  38. The Customer has the right to request access to his/her personal data from Balticom, as well as to request supplementation, correction or deletion of the data, to obtain a copy of the data, to object to data processing, or to request the restriction of data processing and ensure data portability.
  39. Balticom will process the data subject’s requests provided that they do not conflict with Balticom’s obligations imposed by applicable legal acts or the terms of the contract concluded between Balticom and the Customer.
  40. The Customer may submit a request to exercise his/her rights:
    1. in writing, in person at Balticom’s registered address, by presenting an identity document;
    2. via email, signed with a secure electronic signature;
    3. by logging into the self-service portal “Mans Balticom”.
  41. Upon receiving the Customer’s request to exercise his/her rights, Balticom will verify the Customer’s identity, assess the request, and fulfill it in accordance with applicable legal acts.
  42. If the Customer wishes to receive information containing his/her personal data, Balticom will send the response by mail to the contact address provided by the Customer in a printed letter or hand it over in person, taking into account the Customer’s preferred method of receiving the response.
  43. In the event of any objection by the Customer, the Customer has the right to contact Balticom using the contact information provided in this Privacy Policy for Balticom and the data protection specialist. Upon receipt of a complaint or objection, Balticom will immediately ensure that it is examined and any shortcomings are remedied.
  44. If the Customer is not satisfied with the handling of the objection or the remedial actions taken by Balticom, the Customer has the right to contact the supervisory authority – the Data State Inspectorate.
  45. Customer Consent to Data Processing and the Right to Withdraw It

  46. In certain cases, Balticom processes personal data based on the Customer’s consent (for example, for analysis of service usage habits, to receive individually tailored advertisements, etc.).
  47. The Customer may provide consent for the processing of his/her personal data via the self-service portal “Mans Balticom”, in Balticom service application forms, in banners displayed by Balticom, in Balticom applications, by calling Balticom customer service at 29333333, via email at klients@balticom.info, or in person at Straupes iela 5/3, Riga, providing the information verbally during a meeting with a Balticom representative.
  48. The Customer has the right to withdraw his/her consent for data processing at any time in the same manner in which it was given, that is – via the self-service portal “Mans Balticom”, in Balticom service application forms, in banners displayed by Balticom, in Balticom applications, by calling Balticom customer service at 29333333, via email at klients@balticom.info, or in person at Straupes iela 5/3, Riga. In the event of consent withdrawal, further data processing based on the previously given consent for that specific purpose will no longer be carried out.
  49. Withdrawal of consent does not affect the lawfulness of data processing that was carried out while the Customer’s consent was in effect.
  50. After the Customer withdraws consent for data processing, Balticom retains the right to process those Customer data for which there is another legal basis for processing.
  51. Communication with the Customer

  52. Balticom communicates with the Customer using the contact information provided by the Customer (phone number, email address, postal address), via the self-service portal “Mans Balticom”, and also through automated dialing systems and chatbots.
  53. Communication within applications set up by the Customer is carried out in accordance with the application notifications (alerts) that are mandatory or selected by the Customer.
  54. Communication regarding the execution of service contracts is carried out by Balticom on the basis of the concluded contract (for example, coordinating service delivery or repair times, providing information about invoices, planned works, communication interruptions, changes in services, etc.).
  55. Commercial Notifications

  56. Balticom sends commercial notifications regarding Balticom and/or third-party services and other notifications not directly related to the provision of contracted services (for example, customer surveys) based on the Customer’s consent or, where permitted by applicable legal acts, based on its legitimate interests.
  57. Based on the regulation of the Electronic Communications Services Law, Balticom has the right to send commercial notifications via email to its customers about similar goods and services without obtaining the Customer’s consent, while providing an option for the Customer to opt out of receiving such notifications.
  58. The Customer may provide consent to receive commercial notifications from Balticom and/or its cooperation partners via the self-service portal “Mans Balticom”, in service application forms, during conversations with a Balticom call center operator, in banners located on the Balticom self-service portal “Mans Balticom”, and in Balticom stores.
  59. The Customer’s consent to receive commercial notifications remains in effect until it is withdrawn (even after the termination of the service contract).
  60. The Customer may opt out of receiving further commercial notifications at any time in one of the following ways:
    1. via the self-service portal “Mans Balticom”,
    2. in Balticom service application forms,
    3. in banners displayed by Balticom,
    4. in Balticom applications,
    5. by calling Balticom customer service at 29333333,
    6. via email at klients@balticom.info,
    7. in person at Straupes iela 5/3, Riga.

    Balticom will cease sending commercial notifications as soon as the Customer’s request is processed. The request will be processed online and fulfilled immediately. In some cases, request processing may take up to 2 days.

  61. Regarding the opinions expressed by the Customer in surveys, if the Customer leaves his/her contact information (email address, phone number), Balticom may contact the Customer regarding the evaluation of the services provided by Balticom.
  62. Website Visits and Cookie Processing

    The terms of use for cookies on Balticom websites are specified in the Cookie Usage Policy on Balticom websites: www.balticom.lv, https://mans.balticom.lv/, etc. (hereinafter – Balticom sites or websites), which indicate the purposes of cookie usage, as well as the rights of users to change and choose cookie usage according to their needs.

    Cookie usage terms on Balticom sites: cookie policy.

    What are cookies?
    Cookies are small text files that a web browser (for example, Internet Explorer, Mozilla Firefox, Safari, etc.) saves on the user's device (computer, mobile phone, tablet) when the user visits a website, in order to identify the browser or to save information or settings within the browser. Thus, cookies allow a website to store the user's individual settings, recognize the user, and respond accordingly to improve the website experience. The user may disable or restrict the use of cookies, but without cookies it will not be possible to fully utilize all website features. Depending on the functions performed and the intended purpose, Balticom uses mandatory, functional, statistical, and targeting (advertising) cookies.

    Technical / mandatory cookies:
    These cookies are necessary for the user to freely visit and browse the website and to use its offered functionalities, including obtaining information about services and purchasing them. These cookies identify the user's device but do not disclose the user's identity, and they do not collect or aggregate information. Without these cookies, the website would not be able to function fully, for example, to provide the user with the necessary information, to deliver requested services in an online store, to log into a profile, or to apply for a service.

    Functional cookies:
    With functional cookies, the website remembers the user’s chosen settings and selections (for example – language settings) so that the website can be used more conveniently by the user.

    Statistical cookies:
    Statistical cookies collect information about how the user uses the website, determine the most visited sections, including the content selected by the user while browsing the website. This information is used for analytical purposes, to understand what interests website users, and to improve the website's functionality, making it more user-friendly. Statistical cookies only identify the user's device but do not reveal the user's identity. In some cases, certain statistical cookies may be managed by a data processor on behalf of the website owner in accordance with the indicated purposes.

    Targeting (advertising) cookies:
    Targeting cookies are used to collect information about the websites visited by the user and to offer services or proposals of interest to that particular user, or to address offers corresponding to the user's expressed interest. Usually, these cookies are placed by third parties with the permission of the website owner and only for the purposes indicated.

  63. Balticom uses cookies on its website. (A cookie is a data array that a web server sends to a browser so that it can be stored on the user's hard drive. They are used to personalize the visitor’s activity on websites).
  64. Balticom.lv uses cookies to improve interaction with the visitor.
  65. A visitor may block the use of cookies. For Internet Explorer, search for Tools/Internet Options; for Netscape, Edit/Preferences; for Firefox, Tools/Options/Privacy 7.
  66. Balticom websites may contain links to third-party websites that have their own terms of use and personal data protection policies, for which Balticom is not responsible.
  67. Other Terms

  68. Balticom reserves the right to make amendments to the Privacy Policy, making the current version available to the Customer via the Balticom self-service portal “Mans Balticom”, as well as by posting it on the Balticom website.
  69. Balticom retains previous versions of the Privacy Policy, which are available on the Balticom website.
  70. This version of the Privacy Policy comes into force on 20 January 2023 and replaces the previously approved version of the Privacy Policy.

  71. Previous and current versions of the Privacy Policy (PDF):

    Effective from 25.05.2018


    Balticom Privacy Policy Appendix No. 1

    Data Categories

    No. Data Category Examples
    1. Personal Identification Data first name, last name, personal code/ID, date of birth, passport No./ID number, signature
    2. Personal Contact Information address, phone number, email address
    3. Special Category Data (Sensitive) resident/non-resident, death status, disability mark
    4. Personal Contact Person Data contact person’s first name, last name, email address, phone number
    5. Customer Data customer contract number, customer registration date, status
    6. Mans Balticom Data user number, actions performed on the Mans Balticom portal
    7. Customer Analytics Data category membership, segment, age group, age segment (youth, mass, senior), language, gender, etc.
    8. Service Data service number, service name, service address, price, discount, discount end date
    9. End Device Data end device name, type, serial number, MAC address, meter number
    10. Service Contract Data contract number, signing/approval date, type, appendix number, appendix date
    11. Transaction Data transaction number, date, transaction name, type, status, service installation information
    12. CRM1 Activity Data activity number, type, date, category, owner
    13. Communication Data incoming/outgoing communication type, number, date, registrar, content, channel, delivery status
    14. Purchase Data of Goods name of goods, product code, purchase date, waybill number, method of goods receipt, price, payment method, receipt information
    15. Purchase Data of Services prepaid terrestrial TV purchase information (activation date, type), Balticom+ film purchases (price, date, film name)
    16. Financing Purchase Data financing contract number, decision, payment schedule, leasing contract number
    17. Creditworthiness Check Data status regarding the existence of external debt, credit rating, creditworthiness status
    18. Settlement Data settlement system account number, bank account number, invoice number, date, amount, method of invoice receipt, payment date, debt amount, debt collection information, payment data (payment date, amount payable, amount paid, payer, days overdue, penalty amount)
    19. Service Usage Data stored data for voice services, stored data for internet access services, interactive TV usage data, Balticom usage data, Wi‑Fi usage data, Balticom electricity usage data, sensor data.
    20. Damage Data damage number, registration/resolution date, type, description
    21. Objection/Application Data objection/application number, registration/resolution date, type, description
    22. Customer Survey Data survey name, sending date, response date, survey questions and provided answers
    23. Actions on Balticom Websites IP address, names of actions performed, website section, date and time
    24. Photographs and Images photos from customer events, photo capture date
    25. Video Data videos from customer events, video surveillance on Balticom premises, recording date
    26. Call Recording Data Balticom customer service call recordings, date and time
    27. System Access Data usernames and passwords assigned to the customer
    28. Consent Information indication of consent given by the customer on specific topics, date and time of consent, source
    29. Location Data end device location address, access point address
    30. Network Information positions of network elements (crosses, cabinets, boxes, splitters), device ports, cable pair/fiber, device type, software version, connected devices
    31. Service Usage (Load) Data CDR, fact of IP address allocation, email data that must be stored
    32. TV Service Usage Data customer number, subscribed TV package, device ID, type, model, channel and transmission ID, TV viewings, Balticom Kino purchases, language used, use of TV broadcast archive


    1. CRM (Customer Relationship Management) – a customer relationship management system

    2. Stored Data – load data for voice telephony and internet access services (any information or data processed to transmit information over an electronic communication network or to prepare invoices and record payments, excluding the content of the transmitted information), location data and related information necessary to identify the subscriber or user.

    3. Consent – the freely, unequivocally expressed indication of the Customer’s will by which the Customer permits the processing of his/her personal data in accordance with the information provided by Balticom.

    4. Location Data – data processed in an electronic communication network or by means of an electronic communication service that indicates the location of the user’s device. In public mobile electronic communication networks, satellite networks and wireless networks used for the distribution of radio and television signals, it is the geographical location (address) of the electronic communication service user’s device, while in public fixed networks, cable television and cable radio networks, and electrical cable systems, as long as they are used to transmit electronic communication signals – the access point address.