Privacy policy
1. Terms used in the Privacy Policy
1.1. Processor – a natural or legal person who processes Personal Data on behalf of the Controller.
1.2. Data Subject – a natural person, directly or indirectly identified or identifiable.
1.3. Data Subject consent – any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes, by which the Data Subject, by means of a statement or an explicit affirmative action, gives consent to the processing of his or her
1.4. Special categories of Data – Personal Data relating to a person’s race, ethnic origin, religious, philosophical or political beliefs, trade union membership, genetic Data, biometric Data and Data revealing information about a person’s health, sex life or sexual orientation.
1.5. Client – a legal or natural person who uses the services offered by MMS COMMUNICATIONS LATVIA in person or remotely.
1.6. MMS COMMUNICATIONS LATVIA or We – limited liability company “MMS COMMUNICATIONS LATVIA”, unified registration No 40003330565, registered office at 12 – 7 Alberta Street, Riga, Latvia, LV-1010, telephone +371 67439875, e-mail address: info@publicisgroupe.lv.
1.7. Website – the website maintained by MMS COMMUNICATIONS LATVIA www.publicisgroupe.lv
1.8. Personal Data means any information relating to an identified or identifiable natural person; an identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier. For example, the name, identification number, location Data, online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.9. Processing of Personal Data – any operation or set of operations which is performed upon Personal Data or upon sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
1.10. Controller – a natural or legal person who, alone or jointly with others, determines the purposes and means of processing Personal Data. In this case, MMS COMMUNICATIONS LATVIA.
1.11. GDPR – Regulation 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 (General Data Protection Regulation).
2. Purpose of the privacy policy
2.1. The purpose of this Privacy Policy is to provide the natural person – the Data Subject – with information about the purposes, legal basis, scope, duration of data retention, security, rights of the Data Subject, and other information regarding the processing of Personal Data by MMS COMMUNICATIONS LATVIA following the requirements of the GDPR.
2.2. Our Clients are primarily legal entities. According to Recital 14 of the GDPR, the GDPR does not cover the processing of Personal Data which concerns legal persons and, in particular, undertakings established as legal persons, including the name and the form of the legal person and the contact details of the legal person. In addition, where the data of a self-employed person relate to a commercial activity, they may also be considered as data of a legal person in certain circumstances. Accordingly, this Privacy Policy does not apply to this MMS COMMUNICATIONS LATVIA Client circle to the extent that the requirements of the GDPR do not apply.
2.3. At the same time, in some instances, MMS COMMUNICATIONS LATVIA cooperates with natural persons, or the processing of Personal Data affects the Client’s or business partner’s employees. Accordingly, this Privacy Policy provides information about processing Personal Data in such cases.
2.4. Considering the scope of MMS COMMUNICATIONS LATVIA’s activities, additional conditions regarding processing Personal Data during the services provided by MMS COMMUNICATIONS LATVIA are available in the contract with the Client (if applicable). In case the provisions in this Privacy Notice contradict those in the contract with the Client, the provisions in the contract with the Client take precedent.
2.5. The Privacy Policy applies to the processing of Personal Data regardless of the form and/or medium in which the Data Subject provides Personal Data (in writing, by telephone, on the website, in paper format or by electronic mail, etc.) and in what systems or form MMS COMMUNICATIONS LATVIA processes it.
3. Information about Controller
3.1. The Controller is MMS COMMUNICATIONS LATVIA, unified registration No 40003330565, registered office at 12 – 7 Alberta Street, Riga, Latvia, LV-1010, telephone +371 67439875, e-mail address: info@publicisgroupe.lv.
3.2. If you have any questions about our collection and processing of your Personal Data, please get in touch with the Publicis Chief Data Privacy Officer at privacyofficer@publicisgroupe.com.
3.3. In this Privacy Policy, We provide information about our data processing activities; however, given that we are a creative, digital and media agency, We may also act as a Processor for our Clients in certain circumstances (for example, when developing marketing campaigns with individuals). In these cases, We will have entered into a data processing agreement following Article 28 of the GDPR. In such situations, you should contact our Client, the Controller, for more detailed information about processing your data.
4. Personal Data We process, purposes and legal bases
4.1. Personal Data means any information about an identified or identifiable natural person, including a visitor to the Website, a Client, a candidate applying for a job vacancy, etc.
4.2. To process Personal Data, MMS COMMUNICATIONS LATVIA must determine the purpose and legal basis for processing Personal Data.
4.3. MMS COMMUNICATIONS LATVIA may process Personal Data on one of the six legal bases set out in Article 6 of the GDPR. Still, in practice, the following legal bases are the most commonly used:
a) consent of the Data Subject (Article 6(1)(a) GDPR);
b) the conclusion and performance of a contract (Article 6(1)(b) GDPR);
c) compliance with legal obligations imposed by external laws and regulations (Article 6(1)(c) GDPR);
d) the pursuit of legitimate interests of MMS COMMUNICATIONS LATVIA (Article 6(1)(f) GDPR). In pursuing the legitimate interests of MMS COMMUNICATIONS LATVIA, the interests of the company are weighed against the rights of the Data Subject before the processing of Personal Data is carried out so that the legitimate interests of MMS COMMUNICATIONS LATVIA of a commercial nature do not conflict with the interests and freedoms of the Data Subject. This legal basis will be used, for example, to apply to public administration, law enforcement and judicial authorities to protect the company’s legitimate interests.
4.4. The following are the cases when MMS COMMUNICATIONS LATVIA needs to process your Personal Data:
| Purpose | Categories of Personal Data | Legal basis |
| Communication: We collect and process questions, suggestions, complaints, and other information to prepare replies and ensure communication with the addressee/submitter. Communication may be by e-mail, post, telephone or face-to-face (depending on how you contact MMS COMMUNICATIONS LATVIA). | Name, contact details, and other personal information contained in the question, suggestion or complaint. | The legitimate interest of the agency is to communicate with people and reply to their questions and requests. |
| Conclusion and administration of contractual relations: MMS COMMUNICATIONS LATVIA may need to contract with natural persons as part of its business activities. | It depends on the nature of the contract. For example, name, surname, personal identification number, address, and account no. | Contract. |
| Record-keeping: We need to ensure record-keeping and storage of documentation (including outgoing and incoming correspondence, contracts, etc.). | Documentation, correspondence, contracts containing Personal Data. | Depending on the type of documentation, we may keep it to pursue a legitimate interest, such as defending an interest in court or to comply with legal requirements. |
| Seminars etc.: We can organize or support various events. If events are photographed or recorded, you will be notified in addition. | Personal Data may vary, such as name, contact details, photos and video recordings of the event. | Legitimate interest – informing the public about the activities of MMS COMMUNICATIONS LATVIA and promoting the visibility of MMS COMMUNICATIONS LATVIA. |
| News items: for marketing and public information purposes, We may create records of events, seminars and activities organized or sponsored by MMS COMMUNICATIONS LATVIA. The recordings are published on the MMS COMMUNICATIONS LATVIA Website and/or on social networks such as Facebook. | The recordings produced by MMS COMMUNICATIONS LATVIA may include photographs, video recordings, names, etc., of participants and/or attendees of events. | Legitimate interest – informing the public about the activities of MMS COMMUNICATIONS LATVIA and promoting the visibility of MMS COMMUNICATIONS LATVIA. If you want us to delete a public image/recording of you, please get in touch with us. |
| Commercial communications: We may inform interested parties about our news and developments related to our activities. | E-mail and/or name | Consent. You may opt-out of receiving commercial communications at any time by clicking the relevant link in the e-mail or by e-mailing us at info@publicisgroupe.lv. |
| Recruitment: We process data for organizing and ensuring the recruitment process, establishing employment relationships etc. | Name, experience, education and other information in your CV and cover letter. | The legitimate interest of the agency is to organise recruitment and select suitable candidates. Feedback from former employers is collected based on consent. In an employment relationship – contract of employment and regulatory requirements (e.g. Employment law). |
| Website improvements: We process browsing data collected through cookies installed on our Website for the purpose of analysis of the Website usage, enhancement of Website navigation and marketing efforts. | To store and count page views, to calculate visitor, session and campaign data and track site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors. | We process your data related to browsing based on your consent to use cookies on our Website. For more information about the cookies we use please consult paragraph XI below. |
5. Sources of Personal Data
5.1. Personal Data may be collected in the following ways:
5.1.1. Some Personal Data We receive directly from you, such as questions that are sent to us.
5.1.2. some Personal Data is “produced” in the process.
5.1.3. in some cases, We also receive Personal Data from third parties, such as recruitment companies;
5.1.4. Personal Data is obtained from public Databases or social media profiles in some instances. For example, Lursoft or LinkedIn;
5.1.5. Personal data is obtained through the cookies installed on the Website.
6. Processing of Personal Data by MMS COMMUNICATIONS LATVIA
6.1. Personal Data shall be processed fairly, lawfully and in a manner that is transparent to the Data Subject, using the organizational, financial and technical resources reasonably available to MMS COMMUNICATIONS LATVIA.
6.2. Personal Data are collected for specified, explicit and legitimate purposes and are not further processed for purposes not originally intended or in a manner incompatible with those purposes.
6.3. Personal Data shall be stored so that the Data Subject can be identified from it for no longer than is necessary for the purposes for which the Data were collected or processed.
6.4. Personal Data is collected per the principle of data minimization, which means that data is adequate, relevant and includes only what is necessary for its processing.
6.5. MMS COMMUNICATIONS LATVIA ensures the accuracy of Personal Data and, where necessary, Personal Data is updated or deleted.
6.6. Personal Data shall be processed in such a way as to ensure adequate security of Personal Data, i.e. protection against unauthorized or unlawful processing, accidental loss, destruction or damage.
7. Recipients of Personal Data and place of processing
7.1. Your data is secure and is not inappropriately passed on to others. Personal Data may be further transferred to:
7.1.1. Public authorities in the cases provided for in the legislation. To comply with the obligations arising from the regulatory framework, We may transfer your data to state and local authorities upon their request;
7.1.2. Courts and other rights-protecting bodies. For example, to protect our legal interests by drafting, filing and defending legal claims in court;
7.1.3. Our business partners and our Processors. MMS COMMUNICATIONS LATVIA is entitled to engage and authorize external service providers to perform certain activities on behalf of MMS COMMUNICATIONS LATVIA. If, in the performance of these tasks, persons authorized by MMS COMMUNICATIONS LATVIA process Data Subject data held by us (e.g. IT service providers, security service providers, recruitment companies in respect of candidates), the persons performing the task shall be deemed to be Processors and MMS COMMUNICATIONS LATVIA shall be entitled to transfer the Data Subject Personal Data necessary for the performance of these activities to the Processors to the extent necessary for the performance of the activities. In cases where We authorize Processors to perform a particular task, MMS COMMUNICATIONS LATVIA and Processors shall ensure the protection of Personal Data processing following the GDPR. They shall not use Personal Data for purposes other than the performance of established obligations towards the Data Subject on behalf of MMS COMMUNICATIONS LATVIA.
7.2. We will provide you with more detailed information about the recipients of Personal Data upon your request.
7.3. MMS COMMUNICATIONS LATVIA processes Personal Data within the European Economic Area as far as possible. In the event of a transfer of Personal Data to countries outside the European Economic Area, MMS COMMUNICATIONS LATVIA shall ensure that the procedures set out in the GDPR are in place to ensure the processing of Personal Data and a level of protection equivalent to that set out in the GDPR.
8. Personal Data protection
8.1. MMS COMMUNICATIONS LATVIA shall protect the Personal Data of the Data Subject using modern technological means, taking into account the existing privacy risks and the organizational, financial and technical resources reasonably available to MMS COMMUNICATIONS LATVIA, including the following security measures:
8.1.1. Ensuring that persons handling Personal Data under the control of MMS COMMUNICATIONS LATVIA have received appropriate training and adequate and clear instructions on the Data processing to be carried out, including security instructions included in the Privacy Policy;
8.1.2. Access to information systems containing Personal Data is limited to those employees duly authorized to use them and through proper equipment. Unique authorization tools – username and password – are created for each employee;
8.1.3. Using a firewall and antivirus software;
8.1.4. Paper documents containing Personal Data shall be stored in designated areas, i.e. special rooms, lockers, etc., according to their value and classification.
8.1.5. We ensure that there is no accidental or unlawful erasure, corruption, loss, alteration, processing, disclosure to third parties, etc., of Personal Data.
9. Storage periods for Personal Data
9.1. Personal Data is stored as long as it is necessary:
9.1.1. For the fulfilment of the obligation established by the regulatory framework (for example, accounting requirements);
9.1.2. If the processing is based on consent, Personal Data is processed as long as the given consent is valid and has not been withdrawn;
9.1.3. To achieve the specified processing purpose. For example, as long as necessary to ensure the realization of the legitimate interests of MMS COMMUNICATIONS LATVIA, including for MMS COMMUNICATIONS LATVIA to be able to submit objections or file a lawsuit.
9.2. Candidates’ documents (including Personal Data) submitted for vacant posts will be kept on file for six months after the end of the competition. With consent, documents can be stored for up to one year.
9.3. Contracts and other related information are kept for ten years to ensure the legitimate interests of MMS COMMUNICATIONS LATVIA, such as the performance of contractual obligations, in the event of potential legal proceedings.
9.4. When the retention period of Personal Data has expired, MMS COMMUNICATIONS LATVIA will securely erase the Personal Data of Data Subjects or make it inaccessible (archiving) or non-identifiable so that it can no longer be linked to the Data Subject.
10. Data Subject’s Rights and Access to their Personal Data
10.1. The Data Subject has the right to obtain information about what Personal Data the company holds and to request access to, rectification, updating or erasure of their data, to restrict or object to processing, including the processing of Personal Data based on the company’s legitimate interests, as well as to exercise the right to data portability, insofar as this is in accordance with the GDPR.
10.2. In cases of data processing, where the legal basis is only the Data Subject’s consent, the Data Subject has the right to withdraw the consent given at any time, stopping further data processing, which was carried out based on the Data Subject’s consent.
10.3. Withdrawal of consent shall not affect processing activities carried out while the Data Subject’s consent was valid.
10.1. The Data Subject may withdraw consent in the same manner and form in which it was given (in writing, electronically, etc.) and, where necessary, provide all information about the consent, its nature, and the processing of Personal Data resulting from it.
10.2. The Data Subject’s rights shall be exercised to the extent that they do not conflict with the company’s obligations under external laws and regulations.
10.3. The Data Subject may submit a request to exercise their rights in the following ways: a) by sending a written application by post; b) by submitting it in person at the premises of MMS COMMUNICATIONS LATVIA; c) by sending an application signed with a secure electronic signature and a time stamp to info@publicisgroupe.lv.
10.4. Upon receipt of a request from a Data Subject, MMS COMMUNICATIONS LATVIA shall verify the identity of the Data Subject, assess the request and comply with it following the laws and regulations.
10.5. MMS COMMUNICATIONS LATVIA shall send the reply to the Data Subject’s e-mail address or by registered mail within one month from receipt of the Data Subject’s request. In some instances, the reply may take longer and, where necessary, this period may be extended by a further two months, considering the complexity and number of requests.
10.6. In cases where Personal Data are processed based on external laws, regulations, contractual basis, or to pursue the legitimate interests of the Company, the request for the erasure of Personal Data may not be implemented, which shall be notified to the Data Subject within one month from the moment when MMS COMMUNICATIONS LATVIA received the request for the erasure of data. The reply shall be provided with a clear, unambiguous justification as to why the erasure of Personal Data cannot be implemented. Conversely, in the event of a substantiated request for the erasure of Personal Data, an appropriate erasure of Personal Data shall be provided within one month of receipt of the Data Subject’s request.
10.7. MMS COMMUNICATIONS LATVIA values the privacy of Data Subjects and encourages them to contact MMS COMMUNICATIONS LATVIA with any questions or concerns; however, if the Data Subject believes that Personal Data is being processed inappropriately, the Data Subject has the right to apply to the courts or the Data Inspectorate. The contact details of the Data Inspectorate are as follows:
| pasts@dvi.gov.lv | |
| Phone | +371 67223131 |
| Address | 17 Elijas Street, Riga, LV-1050 |
11. Usage of cookies
11.1. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. If you choose to accept some or all cookies, the files are added to your browser, and the cookies help you to navigate our Website, help us in analysing web traffic or in our marketing activities.
11.2. You may manage your cookies setting options at any time later using the Cookie setting manager or within your browser settings. If you disable cookies, certain parts and functions of our Website may not be available.
11.3. Different retention periods apply to the different types of cookies according to whether they are session cookies (i.e. a cookie temporarily placed on your device that appears when you access the website and disappears when you close your browser window) or permanent cookies (that is a cookie that will remain on your device for a certain period to allow us to remember your preferences on your next visits).
{Cookies List}
11.4. When browsing the Website for the first time, you may click the button “Cookie Settings” on the Cookie banner in order to manage your Cookie preferences. At any time, you will be able to adjust your preferences in the Cookie settings manager available at the bottom of the Website.
12. Other provisions
12.1. MMS COMMUNICATIONS LATVIA has the right to update the Privacy Policy by publishing the current version on its Website. The Privacy Policy was last updated on 27 November 2023.
12.2. The current version of the Privacy Policy is always available on the Website. At the same time, the current and previous versions of the Privacy Policy are available by contacting MMS COMMUNICATIONS LATVIA.