Privacy Policy

1. Data controller

The data controller for personal data collected on baltpartners.com is FPFM SIA (trading as Balt Partners), registration number 40203710743, with its registered office at Saulgožu iela 4-17, LV-1055 Rīga, Latvia. Contact: contact@baltpartners.com

2. Data collected

We collect the following data:

• - First and last name
• - Email address
• - Phone number (optional)
• - Approximate revenue
• - Content of messages sent via the contact form
• - Browsing data (analytics cookies)

3. Purposes of processing

Data is collected in order to: respond to your enquiries, provide you with a personalised quote, manage your expatriation case, send you newsletters (with your consent), and improve our website.

4. Legal basis

The processing of your data is based on: your consent (contact form, newsletter), the performance of a contract (provision of services), and our legitimate interests (service improvement, traffic analysis, measuring the performance of our ads, Article 6(1)(f) GDPR). You can object to audience and ad measurement at any time (Article 21 GDPR) through the "Manage cookies" button.

5. Data retention period

Contact data is retained for 3 years from the last interaction. Contractual data is retained for the legally required period (10 years for accounting records). In Google Analytics, event-level data is deleted after 2 months and user-level data after 14 months.

6. Your rights

In accordance with the GDPR, you have the right of access, rectification, erasure, restriction of processing, data portability, and the right to object to processing. To exercise these rights, use our contact form or write to contact@baltpartners.com. We will respond within 30 days.

7. Cookies, Consent Mode v2 and advertising

This website uses three categories of cookies and trackers: (i) strictly necessary cookies for the operation and security of the site, set without consent; (ii) analytics cookies (Google Analytics 4 through Google Tag Manager, and Microsoft Clarity for session analysis) used to measure traffic and improve the site; (iii) advertising and conversion measurement cookies (Google Ads, Google Signals) used to measure the performance of our campaigns and to retarget visitors interested in our services.

We apply Google Consent Mode v2. From the first page you view, every consent signal (ad_storage, ad_user_data, ad_personalization, analytics_storage) is set to granted by default. The analytics and advertising cookies described above, and Microsoft Clarity session analysis, are therefore active as soon as you arrive on the site. No banner appears automatically.

You can decline these cookies at any time: the "Manage cookies" button in the footer of every page opens an Accept / Decline panel. If you decline, every signal switches to denied and Microsoft Clarity is turned off. Your choice is stored in your browser (localStorage) and respected on later visits. You can also delete the cookies from your browser.

If you reach the site through a business introducer's link (a ref parameter in the URL), a first-party bp_attr cookie records the origin of your visit for 90 days so that the introducer can be credited if you become a client. It contains no advertising identifier and feeds no ad targeting.

8. Google Ads profiling and right to object

We run Google Ads campaigns (Search, Display, YouTube, Performance Max) that may involve profiling within the meaning of Article 4(4) GDPR: Google may use advertising identifiers, third-party cookies and custom audiences (remarketing, enhanced conversions) to show you targeted ads about our relocation services in Latvia. This profiling produces no automated decision with legal effect on you and does not involve sensitive data.

You have a right to object to this profiling at any time (Article 21 GDPR). You can exercise it by: (i) declining cookies through the "Manage cookies" button; (ii) turning off ad personalisation in your Google My Ad Center; (iii) using the European YourOnlineChoices tools; (iv) writing to contact@baltpartners.com.

9. Processors and transfers outside the European Union

Under Articles 28 and 44 to 49 GDPR, we use the processors listed below. Every transfer outside the European Economic Area (EEA) is covered by the European Commission's standard contractual clauses (SCCs, Decision 2021/914) and, where the processor is certified, by the EU-US Data Privacy Framework (DPF). Copies of these safeguards are available on request.

10. Data transfers outside the EU

Your data is mainly hosted and processed in the European Union (Fly.io data centre in Amsterdam, Tally in Belgium, Google Ireland in Ireland, Microsoft Ireland for Clarity). Occasional transfers to the United States (Fly.io Inc., Google LLC, Calendly LLC, Microsoft Corporation) are covered by the standard contractual clauses adopted by the European Commission on 4 June 2021 and, where applicable, by certification under the EU-US Data Privacy Framework (adequacy decision of 10 July 2023).

11. Competent supervisory authorities

FPFM SIA is established in Latvia, so its lead supervisory authority under Article 56 GDPR is the Datu valsts inspekcija (DVI), the Latvian data protection authority. Under Article 77 GDPR, you may also lodge a complaint with the data protection authority of your habitual residence, your place of work or the place of the alleged infringement.

• - Latvia (lead authority): Datu valsts inspekcija - www.dvi.gov.lv
• - Other EU and EEA countries: list of national authorities published by the European Data Protection Board - edpb.europa.eu
• - United Kingdom: Information Commissioner's Office (ICO) - ico.org.uk
• - Switzerland: Federal Data Protection and Information Commissioner (FDPIC) - www.edoeb.admin.ch

12. Contact

For any questions about this privacy policy or to exercise your GDPR rights, use our contact form or write to contact@baltpartners.com.