Cookie Policy
Effective from: July 3, 2026
SIA "SAM MARTIN GROUP"
This is an English-language translation of the original Latvian document provided for the convenience of non-Latvian-speaking users. In the event of any discrepancy or inconsistency between this translation and the Latvian-language original, the Latvian version shall prevail and is the sole legally binding version.
1. Preamble
1.1. This cookie policy (hereinafter – the Policy) establishes the manner in which SIA "SAM MARTIN GROUP", Reg. No. 40203520646, legal address: Matīsa iela 16–2, Rīga, LV-1001 (hereinafter – the Controller), uses cookies and similar technologies on its websites and online services.
1.2. The Policy forms an integral part of the Controller's Privacy Policy and applies to all visitors of the websites (hereinafter – Users) who use the Controller's online services.
1.3. The Policy has been developed in compliance with the requirements of the General Data Protection Regulation (EU) 2016/679 and the applicable legal acts of the Republic of Latvia, including the regulation of electronic communications and information society services.
1.4. If a User does not agree to the use of cookies as set out in this Policy, they are obliged to change their browser settings accordingly or refrain from using the Controller's websites.
2. Contact Information of the Controller
2.1. The controller responsible for the processing of personal data through the use of cookies is SIA "SAM MARTIN GROUP", Reg. No. 40203520646, legal address: Matīsa iela 16–2, Rīga, LV-1001.
2.2. In the event of questions, requests, or complaints regarding this Policy and the use of cookies, the User may contact the Controller:
2.2.1. by e-mail: [email protected];
2.2.2. by post: Matīsa iela 16–2, Rīga, LV-1001 (marked "Data Protection").
2.3. The User has the right to lodge a complaint with the Data State Inspectorate (Datu valsts inspekcija, Latvia's data protection supervisory authority) if they consider that the use of cookies infringes their rights to the protection of personal data.
3. The Concept and Types of Cookies
3.1. A cookie (in English, "cookies") is a small text file that is stored on the User's device via a web server when the User visits the Controller's website.
3.2. Similar technologies may also be used on the Controller's websites, for example:
3.2.1. pixels (web beacons);
3.2.2. local storage;
3.2.3. scripts and other tracking technologies.
3.3. Depending on their duration, cookies are divided into:
3.3.1. session cookies – deleted when the User closes their browser;
3.3.2. persistent cookies – stored for a specified period following the visit.
3.4. Depending on their function, cookies are divided into:
3.4.1. technically necessary cookies;
3.4.2. functional cookies;
3.4.3. analytical and statistical cookies;
3.4.4. marketing and personalisation cookies.
3.5. The Cookie Policy provides the User with clear information on how personal data is processed during the use of cookies and on how the User can manage their choices.
4. Technically Necessary Cookies
4.1. Technically necessary cookies ensure the operation of the basic functions of the Controller's website, including secure connection, navigation, session maintenance, access to protected sections, and other essential functionality.
4.2. These cookies are set automatically as soon as the User opens the Controller's website, and their use does not require the User's consent.
4.3. The legal basis for the use of these cookies is the Controller's legitimate interest in ensuring the technical operation and security of the website, as well as the performance of a contract, where the User uses the website to conclude or perform a contract with the Controller.
4.4. If the User blocks technically necessary cookies in their browser, the Controller cannot guarantee the full functioning of the website.
5. Functional Cookies
5.1. Functional cookies allow the Controller's website to remember the User's choices and settings (for example, the selected language, region, login status) and to provide a more personalised user experience.
5.2. Where a particular functional cookie is not strictly necessary for the provision of the service, the legal basis for its use is the User's consent, which is requested through the cookie settings panel.
5.3. The User has the right to withdraw consent to the use of functional cookies at any time in the cookie settings or browser settings, bearing in mind that this may affect the availability of certain functions.
6. Analytical and Statistical Cookies
6.1. Analytical and statistical cookies are used to obtain aggregated information about User behaviour on the Controller's website, such as the number of pages visited, the duration of the visit, click frequency, and error messages.
6.2. The Controller uses this data to analyse and improve the performance of the website, as well as to develop its services, without identifying specific Users, unless expressly provided otherwise and in compliance with legal acts.
6.3. The legal basis for the use of analytical cookies is the User's consent, which the User gives or withdraws in the cookie settings panel.
6.4. In certain cases, the Controller may base anonymised or aggregated statistics on legitimate interest, where the data can no longer be regarded as personal data.
7. Marketing and Personalisation Cookies
7.1. Marketing and personalisation cookies are used to:
7.1.1. display advertisements tailored to the User on the Controller's website and on third-party websites;
7.1.2. analyse the effectiveness of marketing campaigns;
7.1.3. develop offers matching the User's interests.
7.2. These cookies may be set either by the Controller or by third parties (for example, advertising networks, social media platforms).
7.3. Marketing and personalisation cookies are used only on the basis of the User's prior consent.
7.4. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal, but may affect the availability of personalised content and advertising to the User.
8. Placing Cookies on the User's Device
8.1. The Controller places cookies on the User's device only to the extent and for the purposes specified in this Policy and in the cookie settings selected by the User.
8.2. Cookies whose use requires the User's consent are activated and placed on the User's device only after the User has given free, specific, informed, and unambiguous consent via the cookie banner or the cookie settings panel, with the options to "Accept" and "Reject" cookies provided in an equally visible and accessible manner.
8.3. The User may change their choice at any time and ensure that cookies are no longer placed, by using the cookie settings panel or browser settings, as well as by deleting cookies already stored on their device.
9. List of Specific Cookies
9.1. The Controller maintains an up-to-date list of cookies, indicating:
9.1.1. the name of the cookie;
9.1.2. the type of the cookie;
9.1.3. the service provider (the Controller or a third party);
9.1.4. the retention period;
9.1.5. a description of its purpose.
9.2. The list of cookies is available in the cookie settings panel on the Controller's website (for example, via the "Cookie Settings" link in the page footer).
9.3. The Controller regularly reviews and updates the list of cookies so that it reflects the actual processing carried out.
10. Third-Party Cookies
10.1. Third-party cookies, managed for example by analytics service providers, advertising networks, and social media platforms, may be used on the Controller's website.
10.2. Third parties may be independent controllers of personal data, who carry out the processing of personal data in accordance with their own privacy and cookie policies, with which the User is obliged to become acquainted.
10.3. The Controller is not liable for the content of third-party websites or for the cookies used on them. The User visits third-party websites at their own risk.
10.4. Third-party cookies on the Controller's website are set only with the User's consent, except in cases where another legal basis exists for their use in accordance with legal acts.
11. Cookie Retention Periods
11.1. Cookie retention periods are determined by the Controller or by the relevant third party, in compliance with the principles of necessity and proportionality.
11.2. Cookies are generally not retained for longer than 13 months, unless legal acts provide for a different period or there is an objective need to retain them for longer.
11.3. The specific retention periods are indicated in the list of cookies or in the policies of the relevant third parties.
12. Personal Data Processed Through the Use of Cookies
12.1. The following personal data of the User may be processed through the use of cookies:
12.1.1. IP address;
12.1.2. type of device and browser, settings, and language;
12.1.3. date and time of the visit;
12.1.4. pages visited and actions taken;
12.1.5. referrer website;
12.1.6. unique identifiers associated with the User's device or browser.
12.2. In certain cases, this data may be linked to other information held by the Controller (for example, where the User is a registered user), in compliance with the principles of minimisation and purpose limitation.
12.3. The Controller does not carry out automated individual decision-making or profiling based solely on cookies, unless it has clearly informed the User thereof and has obtained the necessary consent.
13. Transfer of Personal Data and International Transfer
13.1. Personal data obtained through the use of cookies may be transferred to the following persons:
13.1.1. the Controller's IT, marketing, and analytics service providers;
13.1.2. advertising and social media platforms;
13.1.3. supervisory and law enforcement authorities, in accordance with the procedure established by legal acts.
13.2. Where personal data is transferred to countries outside the European Union/EEA, the Controller ensures appropriate protective measures, such as standard contractual clauses approved by the European Commission or other safeguards provided for by legal acts.
13.3. The Controller ensures that processors do not transfer or process personal data contrary to the Controller's instructions and applicable legal acts.
14. User Consent and Its Withdrawal
14.1. Upon first visiting the Controller's website, the User is shown a cookie notice (banner) with the option to select the categories of cookies to which the User consents, providing the option to both accept and reject non-mandatory cookies in an equally simple manner.
14.2. The User may change their consent at any time:
14.2.1. using the cookie settings panel on the Controller's website;
14.2.2. by changing their browser's cookie settings or deleting cookies from their device.
14.3. Withdrawal of consent does not affect the lawfulness of processing up to the moment of withdrawal.
15. Rights of the User
15.1. The User has the following rights under applicable data protection legal acts:
15.1.1. to receive information about the processing of their personal data, including processing carried out by means of cookies;
15.1.2. to access their personal data;
15.1.3. to request the rectification, erasure, or restriction of processing of data;
15.1.4. to object to processing based on legitimate interests;
15.1.5. to withdraw consent to the use of cookies;
15.1.6. to lodge a complaint with the Data State Inspectorate.
15.2. To exercise their rights, the User may contact the Controller using the contact details indicated in clause 2.2, unambiguously identifying themselves and stating the nature of the request.
16. Amendment and Updating of the Policy
16.1. The Controller is entitled to unilaterally update or amend this Policy at any time where the technologies used, the types of cookies, the legal framework, or the Controller's internal processes affecting the use of cookies change.
16.2. The current version of the Policy is always published on the Controller's website, indicating its update date, and is applied from the date specified in the relevant version.
16.3. Where changes to the Policy are material (for example, new types of cookies are introduced or the legal bases change), the Controller shall inform the User by updating the cookie banner or using other communication channels, so that the User may make a renewed, informed choice regarding the use of cookies.
16.4. This Policy is deemed to have been updated as of the date indicated at the beginning of the document in the "In effect from" section.
Questions regarding cookies: [email protected].