DVI (Latvia) - SIA “HH Invest”

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DVI - SIA “HH Invest”
Authority: DVI (Latvia)
Jurisdiction: Latvia
Relevant Law: Article 13 GDPR
Type: Investigation
Outcome: Violation Found
Decided: 15.12.2020
Published: 15.12.2020
Fine: 15000 EUR
Parties: SIA "HH Invest""
National Case Number/Name: SIA “HH Invest”
European Case Law Identifier: n/a
Appeal: Pending appeal
Original Language(s): Latvian
Original Source: Datu valsts inspekcija (in LV)
Initial Contributor: n/a

The Latvian DPA (Datu valsts inspekcija) fined the online store HH Invest SIA €15,000 for failing to provide sufficient information to a data subject regarding the processing of their data.

English Summary[edit | edit source]

Facts[edit | edit source]

As part of its own initiative, the Latvian DPA assessed the website of HH Invest SIA. In particular, it found that HH Invest's privacy policy had not been provided to the data subjects in a systematic and comprehensible way, as required by Article 13 GDPR.

Dispute[edit | edit source]

Was there a violation of Article 13 GDPR?

Holding[edit | edit source]

The DPA imposed an administrative fine of €15,000 on the online store, taking into account that it had actively cooperated with the DPA during the investigation and had made an effort to remedy the issues identified by the DPA. The DPA has claimed that "as a result of this inspection, one of the largest online stores in Latvia has improved the information provided to data subjects regarding the processing of personal data".

Comment[edit | edit source]

HH Invest SIA has appealed the decision in court, which means the imposition of the fine is not final.

Further Resources[edit | edit source]

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English Machine Translation of the Decision[edit | edit source]

The decision below is a machine translation of the Latvian original. Please refer to the Latvian original for more details.

The Data State Inspectorate has imposed a fine of EUR 15,000 on the online store (SIA “HH Invest”).

An important precondition for the implementation of the data subject's control over the processing of personal data by the company is the right to receive information related to the data processing. Without receiving the information, the data subject is unable to make informed, informed decisions about the company's actions with the data.

As part of its own initiative, the Data State Inspectorate examined the content of the website's privacy policy, concluding that the information available to data subjects was not in easy-to-understand language, provided in a non-systematic way. It was concluded that certain aspects of the processing that had to be explained to the data subject in accordance with Article 13 of the General Data Protection Regulation were not clarified.

The administrative fine was imposed taking into account the fact that the online store actively cooperated with the supervisory authority during the inspection and has eliminated the discrepancies identified by the Data State Inspectorate.

As a result of the performed inspection, it is ensured that one of the largest online stores in Latvia has improved the information provided to data subjects regarding the processing of personal data.

The online store appealed the decision in court, which means that the penalty imposed is not considered extreme.