1. Introduction 

SIA RIXMIND (its subsidiaries and affiliates, including each company operating under the brand name “RIXMIND” – together, “RIXMIND”) is committed to ensuring the protection of Personal Data of its Customers, Employees, Business Partners, and any other individual.

The Data Protection Policy (hereinafter, the “Policy”) outlines how RIXMIND processes the personal data of clients, suppliers, employees, and other categories of natural persons, namely, it describes the principles applicable to the processing of personal data within RIXMIND.

RIXMIND’s mission and objective are to uphold privacy and data protection legal obligations and maintain the highest standards in all data processing instances throughout the entire personal data life cycle.

The Policy is the document that provides high-level guidance on RIXMIND’s actions relating to personal privacy and data protection, and it is a statement by RIXMIND’s management of the standards that need to be met.

2. Definitions

Personal Data	Any information regarding an identified or identifiable natural person.
Data Subject	The natural person identified or identifiable through the personal data processing. An identifiable natural person is a person who can be identified, directly or indirectly, especially through referral to an identification element, such as a name, an identification number, localization data, an online identifier, or one or more specific elements characteristic of their physical, physiological, genetic, psychic, economic, cultural, or social identity.
Processing	Any operation or set of operations performed on personal data or personal data sets, with or without the use of automatic means, such as collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, usage, disclosure through transmittal, dissemination, or making available through any other means, alignment or combination, restriction, erasure or destruction.
Recipient	The natural person or legal entity, public authority, agency, or other organism to which (whom) the personal data is disclosed, regardless of whether it is a third party or not.
Data Protection Officer/Responsible	The person in RIXMIND responsible for meeting the demands regarding personal data protection, whether they were appointed as Data Protection Officer in the sense of the applicable data protection law or were only assigned certain tasks in this sense, if there is no a Data Protection Officer appointed.
Record of processing activities” or Personal Data Registry	Registry created by RIXMIND to keep the record of the processing activities performed by RIXMIND.
Processor/data importer	The natural person or legal entity, public authority, agency, or other organism that processes personal data on behalf of the controller/operator.
Controller/operator	The natural person or legal entity, public authority, agency, or other organism which, alone or together with others, establishes the purposes and means of the personal data processing.
Third party	A natural person or legal entity, public authority, agency or organism, other than: the data subject, the controller/operator, the processor and the people who, under the direct authority of the person mandated by the controller/operator, are authorized to process personal data.
RIXMIND group	All RIXMIND operating companies are partially or wholly owned unless specifically excluded and operating under the brand name “RIXMIND”.

 

3. Scope

RIXMIND processes personal data for several general purposes, which are listed in the record of personal data processing activities, in the form of a registry. This Policy applies to any Personal Data Processing that is done for or by RIXMIND.

This Policy shall be complied with by all employees, contractors, consultants, including all personnel affiliated with third parties who may have access to any RIXMIND resources.

 

4. Application of national law

The present Policy presents the principles applicable to personal data processing, which must be observed within RIXMIND, without replacing the legislation on data protection applicable in all countries where RIXMIND is established or does business in. The legislation prevails over this Policy if it contains divergent provisions or additional conditions. In particular, any conditions regarding reporting and authorization existing in the legislation concerning data processing based on the national legislation must be observed.

5. Principles of data processing

Each personal data processing must observe the rights and freedoms of the data subject, in accordance with the principles stated below. These must be observed even when new data processing is initiated or when the existing ones are extended or diversified.

Personal data processing is fair and lawful, meaning RIXMIND has a legitimate business purpose (and, where required, a legal basis) for processing personal data. Where RIXMIND acts as a processor, it will generally rely on the controller to establish this legal basis.  

Personal data processing is limited to the minimum necessary, meaning RIXMIND collects and retains the minimum amount of personal data necessary for the business purpose. Where RIXMIND acts as a processor, it must also process personal data only as directed by the controller. 

RIXMIND is transparent with data subjects about how and why their personal data will be processed. Where RIXMIND is a processor, this information is likely to be provided to the data subjects by the controller.  

Personal data is processed in accordance with the rights of data subjects (e.g., to access, erase, or correct personal data). Where RIXMIND acts as a controller, it must respect and observe any exercise of these rights, and where it is a processor, it will be required to assist the controller in responding. 

Personal data is accurate, up-to-date, and complete.  Where it acts as a processor, RIXMIND will assist the controller to ensure this.

Personal data is kept secure, meaning RIXMIND applies appropriate security safeguards to personal data, including where processed by third parties. Where RIXMIND acts as a processor, it will be required to implement its own appropriate safeguards and provide assistance to the controller in doing the same. 

Personal data is transferred internationally in accordance with applicable law.

RIXMIND is accountable and can demonstrate compliance with its obligations under applicable data privacy laws.

6. Rights of the data subject

Together with the principles mentioned above, RIXMIND keeps in mind and observes the rights of the data subject in all personal data processing according with the applicable law, which might include:

• Right to information and transparency – RIXMIND ensures that the data subject is informed with regard to the personal data processing.
• Right to access – RIXMIND observes the procedure in order to ensure the access of data subjects to information regarding their data processing.  
• Right to rectification – Regardless of the grounds for the processing, the data subjects have the right to request RIXMIND to rectify or complete their data, as the case may be, based on an additional statement.   
• Right to restrict the processing – The data subjects can request RIXMIND to restrict the processing of the personal data concerning them.  
• Right to erasure (“right to be forgotten”) – The data subjects have the right to request and obtain the erasure of personal data in some cases.
• Right to data portability – The data subjects have the right to request RIXMIND to provide a copy of their personal data to the data subject or a Third Party in some cases.
• Right to oppose the processing/ Right to oppose the processing in direct marketing purposes: RIXMIND shall not make decisions about data subjects based solely on automated processing.

7. Disclosure of personal data. Assignees. Transfer to Third-Party Countries

Type and purposes of personal data disclosures

Personal data shall only be disclosed if the party that receives it is personally liable for the data it has received or only if the party that receives it will use it in accordance with the instructions obtained from the party that discloses it.

Personal data can be disclosed for allowed purposes, mentioned in RIXMIND’s records, in view of the performance of RIXMIND’s activity, for observing legal obligations or if there is consent from the data subject.

Processors/Data importers

In situations in which the processing will be performed by another natural person or legal entity in the name of RIXMIND, they will be a processor/data importer in the sense of the applicable law and must offer enough guarantees for the application of adequate technical and organizational measures for personal data protection, which it will process in the name of RIXMIND and by observing the rights of the data subjects.

Transfer of data to a third-party country

There is a transfer to another country when the personal data is transmitted, visualized, or accessed by persons who are in another country.

If the personal data collected and stored by RIXMIND is transferred to a person situated in a different country than the one where RIXMIND has its registered office, the person who received the data must guarantee a personal data protection level equivalent to the level ensured by RIXMIND.

8. Contact points

For any inquiries on this Policy or other personal data processing matters, contact our Data Protection Officer via e-mail: dpo@rixmind.com

9. Compliance

The Data Protection Officer is the owner of this Policy. RIXMIND is committed to ensuring that this Policy is observed by all employees, contractors, consultants, including all personnel affiliated with third parties who may have access to any RIXMIND resources.    

Compliance with this Policy is verified by various means, including reports from available business tools, internal and external audits, self-assessment, and/or feedback to the policy owner(s). RIXMIND monitors its compliance with this Policy on an ongoing basis. Any exceptions to this Policy require the written approval of the Data Protection Officer.

Failure to comply with this Policy, including attempts to circumvent it, may result in disciplinary actions, including termination, as allowed by local laws.

Violations of regulations designed to protect Personal Data may result in administrative sanctions, penalties, claims for compensation or injunctive relief, and/or other civil or criminal prosecution and remedies.