This privacy policy (“Policy”) summarizes the principles of personal data processing by AS Entrum, registration number 40203587696, legal address Šķūņu iela 6-22, Riga, LV-1050, Latvia (“Entrum,” “we,” “us,” or “our”), in accordance with Regulation (EU) 2016/679 (the “GDPR”) and applicable Latvian data protection laws.

Entrum is the data controller for the personal data described in this Policy. Entrum reserves the right to change this Policy from time to time by publishing the updated version on its website at https://entrum.com/privacy-policy.

Collected Information

The main categories of collected personal data include: (i) identification and contact data (name, e-mail address, phone number), and (ii) information about the person’s real estate investment interests and preferences.

Entrum collects personal data provided by the respective person, including when the person submits an inquiry or contact form on our website, responds to our advertisements on third-party platforms (such as Meta), subscribes to our newsletter, or communicates with Entrum via e-mail, telephone, or other channels.

Purpose and Legal Basis

Entrum collects and processes only such personal data and to such extent as is necessary for the purposes of its business. Such purposes primarily include: (i) responding to inquiries from prospective clients and investors, (ii) providing information about our services and investment products, (iii) sending periodic newsletters and marketing communications, and (iv) compliance with applicable legal obligations.

Personal data is processed on the following legal bases: (i) the person’s consent, in particular for receiving marketing communications, (ii) Entrum’s legitimate interests in conducting its business, communicating with prospective clients, managing client relationships, and improving its services, and (iii) compliance with legal obligations applicable to Entrum.

Where we rely on consent, the person may withdraw it at any time without affecting the lawfulness of processing carried out before the withdrawal. To unsubscribe from our newsletter, you may use the unsubscribe link included in each e-mail or contact us directly.

Processing of Enquiries

If you contact us with an enquiry, for example via our website contact form, by e-mail, or by telephone, we process your contact data (such as your name, e-mail address, and phone number) as well as any other personal data you provide in your message. This data is processed for the purpose of handling and responding to your enquiry and maintaining effective communication with prospective and existing clients.

Newsletter and Marketing Communications

Persons who subscribe to our newsletter will receive periodic e-mails about our services and investment opportunities. The legal basis for sending the newsletter is the consent given at the time of subscription (Art. 6(1)(a) GDPR). If you are an existing client or have an ongoing business relationship with Entrum, we may also use your e-mail address to inform you about services similar to those you have previously used, on the basis of our legitimate interest (Art. 6(1)(f) GDPR), unless you have objected to receiving such communications. You may object to direct marketing at any time by using the unsubscribe link in any e-mail or by contacting us directly.

Data Retention

Entrum keeps personal data for only so long as it is necessary for the purpose for which it was collected and for as long as its storage is required by applicable law. If personal data is processed in the context of any contractual or business relationship, the storage period may be extended for the statutory period of limitation under applicable laws.

Rights of Person

The person whose personal data is collected has the following rights: (i) the right to request a copy of the personal data as well as correction of any incorrect personal data, (ii) the right to request erasure of the personal data if there is no valid reason for Entrum to keep it, (iii) the right to withdraw consent at any time where Entrum was relying on consent to process the personal data, (iv) the right to request a restriction on processing the personal data or to object to processing of the personal data in specific circumstances, and (v) the right to receive the personal data in a machine-readable format and have the data transferred to another party responsible for data processing. These rights may be exercised in accordance with the requirements of applicable EU and local laws by contacting Entrum.

If the person is not satisfied with the way in which Entrum handles the personal data, the person may contact Entrum by sending an e-mail to info@entrum.com. If the person is not satisfied with Entrum’s response or considers that Entrum is processing personal data in an illegitimate or unlawful manner, the person may file a complaint with the Latvian data supervisory authority (Datu valsts inspekcija) by sending an e-mail to pasts@dvi.gov.lv or visiting www.dvi.gov.lv.

Third Parties

In the context of the purposes outlined above, personal data may be shared with third parties. Such third parties may include the companies in the Entrum group, service providers engaged by Entrum for customer relationship management, e-mail marketing and newsletter distribution, advertising platforms, as well as professional advisers, regulators, and other authorities where required by law. Entrum aims to ensure that it discloses personal data only to such third parties that implement adequate safeguards to protect the security of the personal data and use it in accordance with applicable law. Where relevant, Entrum enters into data processing agreements with third parties stipulating their obligations in respect of handling such personal data.

Personal data is generally processed within the EU/EEA. If, however, it is necessary for Entrum to transfer personal data to a country outside the EU/EEA, Entrum shall take all required legal, technical, and administrative steps to ensure that such data is managed securely and with a suitable level of protection comparable with the protection offered within the EU/EEA, including by relying on adequacy decisions, standard contractual clauses, or other appropriate safeguards as required by the GDPR.

Provision of Personal Data

Providing your personal data via our website forms, lead forms, or newsletter subscription is voluntary. However, if you do not provide the requested information, Entrum may not be able to respond to your enquiry or provide you with the requested services.

Contact Information

Any enquiries in relation to the personal data collected or processed by Entrum or this Policy should be addressed by email to: info@entrum.com or by post to: AS Entrum, Šķūņu iela 6-22, Riga, LV-1050, Latvia