Video Surveillance Policy
Personal Data Processing Principles for Video Surveillance
In Controller
In accordance with the European Parliament and Council Regulation (EU) 2016/679 of April 27, 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), we inform you about the processing of personal data when conducting video surveillance (hereinafter referred to as the Principles).
Controller
The limited liability company "Troja", registration number: 40003093873, legal address: Bauskas iela 143, Riga, LV-1004 (hereinafter referred to as Troja).
Controller's contact information
Legal address: Bauskas iela 143, Riga, LV-1004;
Email: troja@finieris.lv
Data Protection Officer's contact information
Address: Bauskas iela 143, Riga, LV-1004;
Email: troja@finieris.lv;
Phone: +371 67 609 321.
Purposes and Legal Basis for Processing Personal Data, Categories of Personal Data, and Processing Periods
1.
| Purposes of Data Processing | Legal basis for processing | Categories of personal data | Processing periods |
| For security within Troja premises, the territory, or at objects, for the protection of individuals and property. | The processing is necessary for the legitimate interests of Troja and third parties (Article 6(1)(f) of the General Data Protection Regulation): to prevent and detect security risks by conducting video surveillance in objects and their surrounding areas for the protection of individuals and property. | Personal image (appearance, behavior, actions performed), vehicle image, make, vehicle registration number, time of the personal and vehicle image recording, date, and location of the recording. | Video surveillance recordings are processed for no longer than 30 days. |
| For the protection of Troja's legitimate interests. | The processing is necessary for the legitimate interests of Troja and third parties (Article 6(1)(f) of the General Data Protection Regulation): to detect and investigate incidents and secure evidence (for example, to retain personal data for a certain period in case of a potential dispute for dispute resolution). | Personal image (appearance, behavior, actions performed), vehicle image, make, vehicle registration number, time of the personal and vehicle image recording, date, and location of the recording, personal image with voice recording during a conversation. | If the video surveillance recording reflects unlawful actions or actions that may help Troja or third parties protect their legal interests, the relevant video recording may be stored until the legal interests are secured (for example, until the day the final court decision comes into force). |
| For providing the electric transport charging service and ensuring quality control. | The processing is necessary for the legitimate interests of Troja and third parties (Article 6(1)(f) of the General Data Protection Regulation): to ensure and improve the quality of the electric transport charging service and/or to monitor the exceeding of the scheduled charging time for the data subject (customer) and the provision of the service. | Personal image (appearance, behavior, actions performed), vehicle image, make, vehicle registration number, time of the personal and vehicle image recording, date, and location of the recording. | Video surveillance recordings are processed for no longer than 30 days. |
2. Recipients of personal data
Troja, based on the legal basis and in compliance with personal data protection requirements, may disclose your personal data to the following recipients of personal data:
- Troja employees and authorized persons who have been granted access and are obligated to process your personal data to fulfill the aforementioned purposes of personal data processing;
- With the provision of Troja's services and business development, to affiliated parties in order to ensure the fulfillment of the aforementioned purposes of personal data processing, including, but not limited to: Information system service providers; security and safety service providerslegal service providers; Law enforcement agencies, courts, state public administration bodies, and other third parties, based on a written request and legal obligations as defined by applicable laws.
Personal data is not intended to be transferred to recipients outside the European Union or European Economic Area countries.
3. Your rights within the scope of personal data processing
You have the right to:
- You have the right to access your personal data and request information from Troja regarding the processing of your personal data by submitting a written request if the information provided in these Principles does not seem sufficient to you;
- By submitting a written request, you have the right to request the correction, deletion, or exercise of your right to data portability, restriction, or object to the processing of your personal data. In cases specified by the General Data Protection Regulation, the Controller may limit the exercise of your rights as a data subject, providing a justified decision based on a compelling legitimate reason for each specific case;
- You have the right to file a complaint with Troja, as well as with the Data State Inspectorate (Elijas iela 17, Riga, pasts@dvi.gov.lv), if you believe that Troja has violated your rights or has not adequately protected your personal data. However, before contacting the Data State Inspectorate, we encourage you to first reach out to Troja.
4. Procedure for submitting requests to exercise your rights
To exercise all the aforementioned rights, you can use the contact information for Troja provided in the Principles. In your request, please specify the following personal data: your first name, last name, personal identification number, postal address (if you wish to receive the response by registered mail) or email address (if you wish to receive the response by email), as well as any additional identifying information (e.g., the date, time, location, and descriptive information about the appearance from the video surveillance recording).
We encourage you to submit your request in one of the following ways::
- Send a free-form request electronically to the email address troja@finieris.lv, signing the email with a secure electronic signature;
- Send your signed free-form request by mail to the following address: Troja, Bauskas iela 143, Riga, LV-1004.
5. Other Terms
Troja has the right to make amendments to the Principles, making the most current version available to you on Troja's website.
The policy is effective from April 1, 2025.