Last updated: 26.12.2025.
1. Controller Information
This website (the “Website”) is operated by SIA “KULBA” (hereinafter referred to as the “Company”, “we”, “us”, or “our”).
Registered office:
Amulas iela 8, Riga, LV-1002, Latvia
The Company acts as the data controller within the meaning of Article 4(7) of Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR).
Further mandatory company information is available in the Imprint and Conditions of Use of this Website.
2. Scope and General Information
This Privacy Policy explains how we collect, use, store, disclose, and protect personal data when you access or use the Website, as well as your rights under applicable EU data protection laws.
Terms not otherwise defined in this Privacy Policy have the same meaning as set out in our Conditions of Use.
3. Legal Bases for Processing
We process personal data only where permitted by law, in particular on the following legal bases:
-
Article 6(1)(a) GDPR – your consent
-
Article 6(1)(b) GDPR – performance of a contract or pre-contractual measures
-
Article 6(1)(c) GDPR – compliance with a legal obligation
-
Article 6(1)(f) GDPR – legitimate interests, provided that such interests are not overridden by your fundamental rights and freedoms
Where processing is based on consent, you may withdraw your consent at any time with effect for the future.
4. Categories of Personal Data Collected
4.1 Personal Data Provided by You
When using the Website or contacting us, we may collect the following personal data:
-
Name
-
Country
- Post code
-
Email address
-
Phone number
-
Message content
4.2 Usage and Technical Data
When you access the Website, we may automatically collect technical information such as:
-
IP address
-
Browser type and version
-
Operating system
-
Pages visited and access times
-
Referrer URL
-
Device identifiers and diagnostic data
Legal basis:
Article 6(1)(f) GDPR (legitimate interest in ensuring Website security, stability, and proper operation).
5. Contact Forms and Communication
If you contact us via the contact form or email, we process the personal data provided exclusively for the purpose of handling and responding to your request.
Legal basis:
-
Article 6(1)(b) GDPR (pre-contractual communication), or
-
Article 6(1)(f) GDPR (legitimate interest in responding to inquiries)
Personal data is deleted once the request has been fully processed, unless statutory retention obligations apply.
6. Cookies and Tracking Technologies
6.1 General Information
The Website uses cookies and similar technologies to ensure functionality, security, and – subject to your consent – analytics.
Cookies are small text files stored on your device.
6.2 Cookie Categories
-
Strictly necessary cookies
Required for the operation of the Website.
Legal basis: Article 6(1)(f) GDPR. -
Analytics cookies
Used only with your prior consent.
Legal basis: Article 6(1)(a) GDPR.
You may manage or withdraw your consent at any time via the cookie banner or browser settings, in accordance with the EU ePrivacy Directive.
7. Analytics Services
Google Analytics
Where consent has been granted, we may use Google Analytics, provided by Google Ireland Limited, to analyse Website usage.
-
IP anonymisation is enabled
-
Data may be transferred to servers outside the EU/EEA based on EU Standard Contractual Clauses
-
Google processes data on our behalf as a processor
You may prevent data collection by declining analytics cookies or using Google’s opt-out tools.
Legal basis: Article 6(1)(a) GDPR (consent)
8. Data Retention
We retain personal data only for as long as necessary for the respective purposes or as required by law.
Indicative retention periods include:
-
Contact inquiries: up to 12 months
-
Technical logs: up to 90 days
-
Contractual and accounting data: statutory retention periods under Latvian and EU law
9. Transfers of Personal Data
Personal data may be processed within the Republic of Latvia and, where necessary, within the EU/EEA or third countries.
Transfers to third countries occur only where appropriate safeguards under Articles 44–49 GDPR are in place, including adequacy decisions or Standard Contractual Clauses.
10. Disclosure of Personal Data
We may disclose personal data only where required:
-
To comply with legal obligations
-
To protect and defend our rights or property
-
To prevent or investigate unlawful activities
-
To protect the safety of users or the public
11. Data Security
We apply appropriate technical and organisational measures to safeguard personal data against unauthorised access, loss, or misuse.
However, no method of transmission over the Internet or electronic storage is completely secure.
12. Children’s Data
The Website is not intended for persons under 16 years of age.
We do not knowingly collect personal data from children. If such data is identified, it will be deleted without undue delay.
13. Your Rights Under GDPR
You have the following rights:
-
Right of access (Article 15 GDPR)
-
Right to rectification (Article 16 GDPR)
-
Right to erasure (Article 17 GDPR)
-
Right to restriction of processing (Article 18 GDPR)
-
Right to data portability (Article 20 GDPR)
-
Right to object to processing (Article 21 GDPR)
-
Right to withdraw consent at any time (Article 7(3) GDPR)
You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence.
Latvian Supervisory Authority:
Datu valsts inspekcija (Data State Inspectorate)
14. Links to Third-Party Websites
The Website may contain links to third-party websites. We are not responsible for their content or data-processing practices.
Please review their privacy policies separately.
15. Governing Law
This Privacy Policy is governed by the laws of the Republic of Latvia, without prejudice to mandatory EU data protection and consumer protection laws.
16. Changes to This Privacy Policy
We reserve the right to amend or update this Privacy Policy at any time. Changes take effect upon publication on the Website.
Continued use of the Website after such changes constitutes acknowledgment of the updated Privacy Policy.
17. Contact
For questions regarding this Privacy Policy or to exercise your data protection rights, please contact:
