AS “VIRŠI-A”
SIA “VIRŠI Renergy”
Version: 01
LOYALTY PROGRAMME PRIVACY STATEMENT
1. General Terms and Conditions
1.1. By implementing Regulation (EU) 2016/679 of the European Parliament and of the Council of
27 April 2016 on the protection of individuals 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),
hereinafter – the Regulation, AS “VIRŠI-A” (unified reg. No. 40003242737, registered address: Kalna
iela 17, Aizkraukle, Aizkraukle Rural Territory, Aizkraukle Municipality, LV-5101, Latvia) and SIA “VIRŠI
Renergy” (unified reg. No. 45403058402, registered address: Kalna iela 17, Aizkraukle, Aizkraukle Rural
Territory, Aizkraukle Municipality, LV-5101, Latvia), hereinafter both jointly referred to as VIRŠI or the
Joint Controllers, provides you with transparent and fair processing of your personal data, as well as
takes care of your privacy and personal data security.
1.2. In this privacy statement of the loyalty programme of VIRŠI (hereinafter – Statement) you will
find all the information about what personal data VIRŠI collects and processes, for what purposes they
are used, for how long they are stored, etc. Important information for you related to your participation
in the Loyalty Programme of VIRŠI. This is to inform you that VIRŠI shall only process your personal data
if you have provided them to VIRŠI. VIRŠI shall not collect personal data from third parties.
1.3. If you have not familiarised yourself with and approved the Terms of the VIRŠI loyalty
programme constituting the agreement between you and VIRŠI on participation in the VIRŠI loyalty
programme (hereinafter – Terms) and this Statement, VIRŠI shall not be able to provide you with the
opportunity to participate in the VIRŠI loyalty programme (hereinafter – Programme). VIRŠI shall not be
able to ensure the operation of the Programme and grant you the benefits of the Programme.
It is important that the personal information you provide is accurate and correct. If you provide
incorrect (false) personal data, forget them or fail to update them, it may be difficult for VIRŠI to ensure
the fulfilment of the obligations of the agreement (Terms) concluded with you (i.e., the use of the
Programme benefits), as well as other difficulties may arise in exercising your rights. VIRŠI shall not be
Riga. The date of the document is the date of the time stamp of its last electronic signature.
This document is signed with a secure electronic signature and contains a time stamp.
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liable for any damages you may incur if you provide incorrect personal information. If the personal data
submitted by you change, please inform VIRŠI (for example, by updating your Programme user profile
information).
2. Joint Controllers of personal data and contact information
2.1. The Joint Controllers of personal data processing set out in this Statement:
2.1.1. AS “VIRŠI-A” (unified reg. No. 40003242737, registered address: Kalna iela 17,
Aizkraukle, Aizkraukle Rural Territory, Aizkraukle Municipality);
2.1.2. SIA “VIRŠI Renergy” (unified reg. No. 45403058402, registered address: Kalna iela 17,
Aizkraukle, Aizkraukle Rural Territory, Aizkraukle Municipality, LV-5101, Latvia).
2.2. The contact information of the Joint Controllers for communication is as follows:
– postal address: Kalna iela 17, Aizkraukle, Aizkraukle Rural Territory, Aizkraukle Municipality, LV-5101,
Latvia;
– e-mail address: birojs@virsi.lv;
– telephone +371 80 700 070.
2.3. You can contact us regarding all personal data processing and protection issues in the
following ways:
– electronically by writing to the e-mail address: datuaizsardziba@virsi.lv;
– address for postal correspondence: Kalna iela 17, Aizkraukle, Aizkraukle Rural Territory, Aizkraukle
Municipality, LV-5101, Latvia.
Please address your letter to: “VIRŠI” Data Protection Officer.
3. What are personal data?
3.1. Personal data shall mean any information related to an identified or identifiable natural
person (“Data Subject”). An identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an identification number, location
data, an online identifier or to one or more factors specific to the physical, physiological, genetic,
mental, economic, cultural, or social identity of that natural person.
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4. What personal data concerning you does VIRŠI process and for what purposes, what is the
legal basis and the period of data processing?
4.1. Registration and Participation in the Programme.
You can register for the Programme in the following ways:
- on the VIRŠI website at: www.virsi.lv;
- on the VIRŠI mobile app, hereinafter referred to as the “App”;
- by purchasing the VIRŠI loyalty card at VIRŠI fuel stations.
By registering for the Programme, you are simultaneously providing your data to VIRŠI and the
right to process them in accordance with the amounts, types and purposes set forth in this Statement
and the Terms. The submission of your personal data is mandatory. By failing to submit your personal
data, you will not be able to participate in the Programme (including to use the offers and benefits
provided by VIRŠI for participation in the Programme). By registering for the Programme – creating a
Programme user profile (hereinafter – Profile), you enter into an agreement with VIRŠI and confirm that
the personal data provided by you are accurate and correct and you have the right to provide them (you
are at least 18 years old).
By registering for the Programme (after concluding the agreement), a unique profile of the
Participant of the Programme shall be created for you, according to which VIRŠI will be able to identify
you as a registered Participant of the Programme.
Data categories
In order to ensure your participation in the Loyalty Programme
(including the creation and administration of a profile), VIRŠI needs
to know and VIRŠI shall process your phone number, which will be
used as an identifier and will be attached to your profile, your name,
date of birth, gender, place of residence (city, district), e-mail
address, VIRŠI loyalty card number/bank card number, purchase
history and other information related to participation in the
Programme. For example, used or unused benefits, preferences you
have made, such as whether you want to receive personalised offers
or have expressed the wish to take part in the lotteries for goods and
services, information about registration in a profile using a Smart ID
authentication solution.
Your email address and telephone number may be used to notify you
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of changes to the Programme Terms.
For the processing of personal data, when using the VIRŠI App,
please, refer to the privacy statement of the App on the VIRŠI
website at: www.virsi.lv.
Legal basis for data
processing
For the purposes of the conclusion and fulfilment of the Agreement
regarding participation in the Programme (Article 6 (1)(b) of the
Regulation).
Period of data processing
For the entire period of the agreement on participation in the
Programme and your participation in it, i.e., while you participate in
the Programme. If you have not been registered for the Programme
or have not used the Programme for at least 12 months, VIRŠI shall
be entitled to exclude you from the Programme and delete your
profile. Information on participation in the Programme, in whole or
in part, may be retained by VIRŠI for the protection of the lawful
interests of VIRŠI.
4.2. Administration of benefits of the Programme.
As a Participant of the Programme, you may be granted discounts on a specific product or you
may obtain a product for free. In order to ensure the accounting of such transactions – VIRŠI, in addition
to the data entered by you, also processes the data on your purchases (hereinafter – Purchase Data).
In order to ensure that you have the opportunity to use the benefits
due to you and to keep records in accordance with the requirements
of regulatory enactments, VIRŠI needs to process your loyalty card
number, fuel station address, purchase date and time, product name,
quantity, purchase price and benefits, discounts and their amount,
payment method for purchases, payments made and payment
information (bank, bank account, bank payment card data), history of
offers provided to you and information on their use, information on
the concluded/not concluded electricity trade contract, conditions and
the fulfilment thereof, also encompassing information about invoice
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payment discipline, information about the volume of consumed
electricity, and information about the object (address, technical data).
The Agreement concluded by you for participation in the Programme
and the profile created by you in order to fulfil the obligations of the
Agreement (Article 6 (1)(b) of the Regulation) with regard to the use
of benefits.
In order to comply with the legal obligations of VIRŠI (Article 6 (1)(c) of
the Regulation), when performing accounting in accordance with the
requirements of the laws and regulations of the Republic of Latvia (for
example, the Value Added Tax Law, Section 11 of the Accounting Law,
etc.).
Purchase data and accounting source documents shall be stored by
VIRŠI for 5 years from the date of closure of the purchase transaction.
Information on the benefits used by you and their formation shall be
stored by VIRŠI fully or partially for a maximum of two years, subject
to the limitation period arising from the laws and regulations on
Consumer Rights.
4.3. Profiling by administering the Programme and developing personalised offers for
participants.
The Programme is designed to benefit both you and the VIRŠI business. VIRŠI makes sure that the
range of products, promotions and discounts provided at VIRŠI fuel stations best meet the needs of
VIRŠI customers, etc.
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In administering the Programme and in order to achieve the objectives set forth in the Terms and
this Statement, VIRŠI shall use automated tools for the analysis of personal data (including your
purchase data, which might entail both your electricity consumption data and data on your purchases
performed in the fuel stations) and automated decision-making. VIRŠI shall carry out your profiling, i.e.,
the analysis of your preferences and needs, in order to prepare the most relevant offers for you. VIRŠI
shall group and analyse your data available to VIRŠI about purchased goods, fuel stations visited,
services received and, taking into account other characteristics specific to you, such as gender, date of
birth, region of residence (city and district), as well as information about your actual location using the
App if such information is available to VIRŠI.
As a result of the analysis (profiling) of your data performed by VIRŠI, it shall not make any
decisions that are binding on you, i.e., you are not obliged to use the offers prepared by VIRŠI.
If you have any objections to profiling for the purpose set out in this section of the Statement,
VIRŠI shall take them into account. If your objections do not allow the Programme to be implemented in
accordance with the Terms, VIRŠI may terminate the agreement entered into with you regarding your
participation in the Programme.
Data categories
To perform data profiling, VIRŠI shall process all data available
to VIRŠI obtained from you as a Participant of the Programme,
including, but not limited to, your purchase history, information
about your activity in the Programme – whether or not you
have taken advantage of the benefits due to you, information
about the services used, information regarding the fuel station
where you most often make purchases, the time when you
make purchases, information about your participation in VIRŠI
promotions, games and lotteries (not only as a Participant of
the Programme), as well as information about your actual
location, if by using the App, you have authorised VIRŠI to
access this information.
Legal basis for data processing
The agreement on participation in the Programme concluded by
you (Article 6 (1)(b) of the Regulation), as well as Article 22(2)(a)
of the Regulation – VIRŠI shall perform profiling in order to fulfil
the agreement concluded with you regarding the preparation of
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personalised offers of the Programme.
Period of data processing
For the entire period, while the agreement is in force and you
participate in the Programme.
4.4. Provision of Programme newsletters (information).
If during registration, you have agreed to receive Programme newsletters, VIRŠI shall process your
personal data by preparing and sending such newsletters to you. The Programme newsletters shall be,
for example, information about discounts, games, lotteries and promotions, information about the
offers provided by the Programme partners, invitations to express opinions about the provided services
and products, etc. The above information shall be provided by VIRŠI in the manner of your choice. You
can select your preferred methods of receiving the Programme newsletters in your Programme
Participant’s profile (including via the App functionality). You can change this information at any time
without restriction (including opt-out from receiving further newsletters). Opting out from receiving the
newsletters shall not affect your participation in the Programme.
Data categories
In order to inform you about the news of the Programme, it is
necessary for VIRŠI to process your name, surname, telephone
number and/or e-mail address, information on whether you
are a user of social networks (if you choose to receive offers
via social networks), as well as information about the settings
on your phone (permissions you have given to receive
notifications, permissions to use the location data). In the case
of sending out the offers, VIRŠI can use technical solutions to
make sure that you have received the VIRŠI dispatch. In some
cases, VIRŠI will be able to see whether you were interested in
the offer or not (for example, if you opened the dispatch,
clicked on “find out more” of the offer, etc.).
Legal basis for data processing
Your consent (Article 6 (1)(a) of the Regulation) to receive
news (offers and information) of the Programme.
Legitimate interest of VIRŠI to make sure that you receive the
dispatches of VIRŠI and they have been interesting for you.
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Period of data processing
For as long as your consent to receive news (offers and
information) is in force.
4.5. Participation in Lotteries of Goods and Services.
If you agree to participate in the lotteries of goods and services, VIRŠI asks you to specify the
following additional personal data:
Data categories
For registration and participation in lotteries of goods and
services, VIRŠI shall process your name, contact information,
purchase information, cheque or receipt number and/or proof
of participation in the lottery sent by you (including photo of
the receipt), lottery results, winnings/prizes received (in the
case of a cash prize, also the personal identity number and
signature). In the event of a win, information identifying the
winner (for example, card number) may be published in
accordance with the rules of the relevant lottery.
Legal basis for data processing
Your consent (Article 6 (1)(a) of the Regulation) to participate
in lotteries of goods and services in respect of data collection.
Compliance with the legal obligations of VIRŠI (Article 6 (1)(c)
of the Regulation) in relation to the organisation of lotteries
for goods and services (for example, Article 7 and Article 18,
Paragraph 3, Clause 6 of the Law on Lotteries for Goods and
Services).
Protection of the legitimate interests of VIRŠI (Article 6 (1)(f)
of the Regulation) to preserve information on the progress of
the lottery of goods and services and to provide evidence for
subsequent disputes.
Period of data processing
In order to fulfil the requirements of the laws and regulations
related to the lottery of goods and services, your data will be
stored for at least 5 years after the end of the lottery (Clause 5
of Cabinet Regulation No. 16 of 2 January 2007 “Procedures
for Supervision and Control of Organising Lotteries of Goods
and Services”).
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4.6. Handling of Requests and Complaints for the Protection of VIRŠI Legitimate Interests.
VIRŠl shall use your personal data to respond to your complaints, requests, claims and enquiries,
and to administer your feedback (hereinafter – Requests). VIRŠI may use the data obtained within the
Programme as evidence of legal action (for example, that VIRŠI has complied with the laws and
regulations governing consumer rights or personal data processing).
Data categories
In order to ensure the protection of the lawful interests of
VIRŠI and to process your or any other person’s Requests,
VIRŠI may process all your personal data held by VIRŠI listed in
this Statement: name, surname, telephone number, e-mail
address, city, date of birth, system audit record data related to
the use of your profile, information relating to your purchase
history, both as a Participant of the Programme as well as
without using the benefits of the Participant of the
Programme, as well as any other information being at the
disposal of VIRŠI (also for other data processing purposes,
such as to ensure the security and protection of the lawful
interests of VIRŠI and third parties).
Legal basis for data processing
Compliance with the legal obligations of VIRŠI (Article 6 (1)(c)
of the Regulation) with regard to handling your claims (for
example, Consumer Rights Protection Law).
For the protection of the legitimate interests of VIRŠI (Article 6
(1)(f) of the Regulation) to evaluate your feedback as a
customer, to retain information about the handling of the
Request in accordance with the procedure of the laws and
regulations, and to provide evidence.
Protection of the legitimate interests of VIRŠI (Article 6 (1)(f)
of the Regulation) with respect to ensuring evidence on the
circumstances of the provision of news of the Programme
(your consent, the circumstances of its withdrawal), the
handling of claims or complaints.
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Period of data processing
VIRŠI shall only use your data to ensure the protection of the
lawful interests of VIRŠI.
VIRŠI shall store your data for the period specified in the
Statement, but for no longer than five years, unless there is a
dispute or a possibility thereof (in this case, we may store your
data for longer until the statutory time limitation periods for
filing a complaint or claim expires and/or the ruling enters into
force).
5. From what sources does VIRŠI obtain and collect your personal data?
VIRŠI shall obtain almost all of your personal data from only you or the equipment you use. When
registering for the Programme, you submit your data to VIRŠI. You give your consent (for the purposes
of fulfilment of the agreement on participation in the Programme, as set out in Regulation 6(1)(b)) to
the Joint Controllers, as separate controllers, to the transfer and inclusion in the Programme of personal
data held by them as data sources for the achievement of the purposes of the Programme. When
purchasing goods or services using your profile and an identifier (such as a loyalty card or a bank card),
VIRŠI receives your purchase data. VIRŠI shall collect and process the information reflecting your
participation in the Programme in order to achieve the data processing purposes set forth in this
Statement.
VIRŠI will collect your data from you if you submit a Request in any of the ways specified in the
Statement. In some cases, it may be necessary for VIRŠI to obtain additional information or inspect the
circumstances in order to handle your Request. In such cases, VIRŠI may link the data of your Request
with the data at the disposal of VIRŠI and/or the data collected during the handling of your Request (for
example, VIRŠI may review the data on purchase and received service operations, your profile usage
history, interview the staff of VIRŠI, etc.).
6. How does VIRŠI store and destroy data?
VIRŠI shall ensure that your data is only accessed by authorised persons and only processed in
countries of the European Union or the European Economic Area that ensure the adequate protection of
your rights and freedoms. At the end of the processing and storage period of your data set forth in this
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Statement, VIRŠI will destroy (anonymise) your data within a reasonable period of time, observing the
time limits set out in the Statement.
7. In what cases does VIRŠI disclose your data and to what personal data recipients?
We may transfer your data for processing to the personal data recipient, i.e., persons, who help
VIRŠI to execute and administer the Programme, and provide VIRŠI with the services related to the
administration of Requests. Such persons may include IT database software providers, database
administration service providers, data centre, maintenance and cloud service providers, website hosting
service providers, direct marketing service providers, market research or business analytics service
providers, and so on. In any case, VIRŠI shall provide data processors with only as big volume of data as
is necessary to perform a specific task or provide a specific service. The data controllers attracted by
VIRŠI may only process your personal data upon the instructions of VIRŠI and may not use them for
other purposes or transfer them to other persons without the consent of VIRŠI. Besides, they must
ensure the protection of your data in accordance with the applicable laws and regulations and the
relevant conditions specified in the agreements concluded between VIRŠI and the respective service
provider.
The data may also be passed on to competent/supervisory public authorities, municipal or law
enforcement agencies, such as the police, the prosecutor’s office, the court or monitoring/supervisory
authorities, as well as to the VIRŠI auditors. Data may only be transferred if it is necessary in accordance
with the applicable laws and regulations or in order to ensure the security of the state, municipal or law
enforcement authorities, VIRŠI customers, employees and IT resources, to raise, submit and defend the
lawful interests of VIRŠI, etc.
8. What are your rights and how can you exercise them?
You may freely exercise your rights as a data subject by addressing VIRŠI. Information on your
specific rights and how to exercise them is provided by VIRŠI in this Statement. VIRŠI asks you to read it
carefully:
8.1. Right to access your personal data processed by VIRŠI.
You have the right to receive information about whether VIRŠI processes your personal data. You
have the right to become acquainted with your personal data processed by VIRŠI and information about
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the purposes of data processing, categories of data to be processed, categories of data recipients, data
processing period, sources of acquisition of data, automated decision-making, including profiling, as well
as the meaning and consequences thereof. The majority of this information is provided by VIRŠI in this
Statement.
If you are a participant of the Programme, you may become acquainted with your personal data
processed by VIRŠI in your profile at any time.
If the information provided in this Statement or your profile is not sufficient for you (or you wish
to receive the purchase operation history), you can contact VIRŠI in the ways specified in this Statement.
8.2. Right to request the rectification of personal data.
If the personal data provided at the time of your registration have changed or you see that the
information processed by VIRŠI about you is inaccurate or incorrect, you have the right to request that
this information be clarified or rectified.
In order to exercise this right, you can independently rectify your personal data in your profile or
by contacting VIRŠI in the ways specified in this Statement.
8.3. Right to withdraw consent.
If VIRŠI has processed your data on the basis of your consent (in the case of Clauses 4.4 and 4.5 of
this Statement), you may withdraw your consent at any time. In such a case, the data processing based
on your consent will be terminated. The withdrawal of consent shall not affect the lawfulness of
processing based on consent before its withdrawal.
For example, you may withdraw your consent to receive the news of the Programme at any time.
Withdrawal of consent shall not restrict your participation in the Programme, but VIRŠI shall not be able
to provide you with current news through the specified communication channels. Additionally, the
withdrawal of consent shall not affect the fact that you will be able to receive up-to-date information in
your Programme Participant Profile.
You may change your consents in the Programme Participant Profile or by contacting VIRŠI in the
ways specified in this Statement.
If your consent expires, VIRŠI will delete the data, unless there is another legal basis for processing
them, and in the cases specified in the Statement – shall permanently anonymise the data.
8.4. Right to lodge a complaint.
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If you consider that VIRŠI is processing your data in violation of the requirements of the regulatory
requirements, VIRŠI kindly asks you to address VIRŠI in the ways specified in this Statement.
If you are not satisfied with the proposed solution to the problem, you may lodge a complaint
with the supervisory authority – the Data State Inspectorate.
8.5. The right to object to data processing, if the processing is based upon legitimate interests.
You have the right to object to the processing of personal data, if the personal data are processed
on the basis of legitimate interests of VIRŠI. Considering the objectives of the Programme and the
balance of legitimate interests of both parties, your objections may mean that VIRŠI will not be able to
provide you with the opportunity to continue participating in the Programme and the concluded
agreement will be terminated.
If you wish to exercise the rights set out in this section, you must submit a written request to the
VIRŠI Data Protection Officer.
8.6. Right to request to erase data (right to be forgotten).
In certain circumstances referred to in the laws and regulations (for example, if personal data are
processed unlawfully, if the legal basis of the data processing expires, if personal data are no longer
necessary in relation to the purposes for which they were collected or otherwise processed, etc.), you
have the right to request VIRŠI to erase your personal data. If you wish to exercise this right, VIRŠI asks
you to submit a written request to the VIRŠI Data Protection Officer.
You can also erase your personal data yourself at any time, by deleting your Programme profile.
By deleting your profile, you will be excluded from participating in the Programme and any benefits you
have accrued will be cancelled. VIRŠI hereby explains that by deleting a profile, any information about
you as a Participant of the Programme is deleted, retaining information about you as a customer
(information reflected on the purchase receipt to ensure compliance with the requirements of
accounting laws and regulations).
8.7. Right to request the restriction of data processing.
In certain circumstances mentioned in the laws and regulations (for example, if personal data are
processed illegally, you dispute the accuracy of the data, you file objections regarding the processing of
data for ensuring legitimate interests of VIRŠI, etc.), you have the right to request the restriction of your
data processing. Due to such restrictions of data processing, it may not be possible for VIRŠI to provide
you with all the benefits of the Programme.
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If you wish to exercise the rights set out in this section, you must submit a written request to the
VIRŠI Data Protection Officer.
8.8. Right to data portability.
You have the right to request the portability of data that you have submitted to VIRŠI in electronic
form. Upon the receipt of your request for data portability, VIRŠI shall provide you with data in a
commonly used and computer (machine) readable format. If you wish to, and if it is technically feasible
for VIRŠI, VIRŠI will send you the requested data in electronic form, in compliance with the information
provided in your request.
If you wish to exercise the rights set out in this section, you must submit a written request to the
VIRŠI Data Protection Officer.
9. How does VIRŠI handle and process your requests?
To protect the data of VIRŠI customers from unauthorised disclosure, VIRŠI shall need to verify
your identity upon receiving your request to provide you with your data or to exercise your other rights.
For this purpose, VIRŠI may ask you to specify the current data registered in your profile (for example,
name, surname, e-mail address or telephone number). VIRŠI can compare whether the data you have
specified match the corresponding data of the registered user. During this inspection, VIRŠI may send a
control notice to you to your contact information indicated in your profile (in the form of a text message
or e-mail), requesting to perform authorisation. If the verification procedure fails (for example, the data
provided by you do not match the data provided by the registered user or you do not authorise after
receiving the sent text message or e-mail notification), VIRŠI may reject your request.
Upon the receipt of your request for the exercise of any of your rights and the successful
completion of the verification procedure, VIRŠI shall provide the information requested by you as soon
as possible, but no later than within one month from the date of receipt of your request.
If your request is complicated, VIRŠI has the right to extend the above-mentioned period for
another two months, informing you of that and stating the reasons for the extension.
If your request is submitted by electronic communication means, VIRŠI will provide a reply in the
same way, unless this is impossible (for example, due to the large amount of information) or if you ask
to provide a reply in any other way. VIRŠI shall not fulfil your request if any obstacles to the execution of
such a request are identified (for example, due to circumstances specified in the laws and regulations).
10. How secure are your data?
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VIRŠI uses different technologies and procedures in order to protect your personal information
from unauthorised access, use, or disclosure. VIRŠI monitors to ensure that the measures implemented
by VIRŠI are appropriate and sufficient.
VIRŠI requests its cooperation partners to use appropriate measures to protect the confidentiality
of personal data and ensure the safety of your personal information. If the information is transmitted
through the internet or mobile communications, VIRŠI cannot completely guarantee its safety;
therefore, you have to independently assess the risks related to confidentiality of the information thus
transferred. VIRŠI recommends to take care of the security of your data. If you face any suspicious
situation (for example, it seems that VIRŠI unreasonably wishes you to enter your username, password
etc.), please immediately inform VIRŠI about this.
VIRŠI takes care in order to comply with the principle of minimisation of personal data – VIRŠI
does not process data that are not necessary for VIRŠI for the achievement of the purposes specified in
this Statement.
11. Validity and changes in the Statement
11.1. This Statement shall enter into force on 4 August 2023. Upon the entry into force of this
Statement, the privacy statement of the loyalty programme of AS “VIRŠI-A” dated 27 December 2021
shall become null and void.
11.2. This Statement may be changed (supplemented, updated) and the updated version of the
Statement will be placed on the website www.virsi.lv and on the VIRŠI App, as well as be available at the
places of performance of commercial activity of VIRŠI.
11.3. You will always find the latest version of the Statement on the website www.virsi.lv. By using
the contact information specified by you, you will be informed of any changes, inviting you to become
acquainted with them.