Legal
Privacy Policy
How SIA INVESTUM processes the data submitted through the enquiry form and uses cookies: purposes, legal basis, retention periods, recipients, your rights. The Google Ads tag is loaded and cookies are set only with your consent.
This is a translation for your convenience; in case of any discrepancy, the Latvian version of this policy is the binding one.
This policy describes the data processing that starts with the enquiry form on investum.lv and the use of cookies on the site.
1. Controller
The controller is SIA INVESTUM, registration number 43603073980.
E-mail: [email protected]. Phone: 27177070.
No data protection officer has been appointed. Send questions about your data to the e-mail address above.
2. What data we process
From the enquiry form we receive:
- the cadastral number or address of the property;
- your phone number;
- your desired price.
At the moment of submission we automatically record your IP address, the time of submission and the language of the page on which you submitted the enquiry.
If you opened the site from a Google ad and chose "Accept" in the cookie banner, we also receive the ad click identifier together with your enquiry (Section 13). Without your consent we do not receive this identifier.
The form contains an optional checkbox with which you may consent to our receiving the enquiry data also as a Telegram message (Sections 6 and 7). If you tick the checkbox, we store together with the enquiry a record that you gave this consent.
From public registers we obtain information about the property you submitted. The sources are the Land Register and the Cadastre Information System. The information includes the owner's name, area, type of use, mortgages, notations and encumbrances.
During a phone call we take notes of what you tell us about the property and the transaction.
3. Purposes and legal basis
| Purpose | Data | Legal basis |
|---|---|---|
| Evaluate the property and call you with a price or a refusal | Cadastral number or address, phone number, desired price, register information | GDPR Article 6(1)(b): steps prior to entering into a contract at your request |
| Prevent automated and abusive submissions | IP address, time of submission | GDPR Article 6(1)(f): our legitimate interest in protecting the form |
| Evaluate the property when the enquiry is submitted by a person who is not the owner | Owner's name and register information about the property | GDPR Article 6(1)(f): our legitimate interest in evaluating a property offered to us |
| Defend ourselves in case of a dispute or claim | Enquiry data and call notes | GDPR Article 6(1)(f): our legitimate interest in defending legal claims |
| Measure whether a Google ad click led to an enquiry, a call or a WhatsApp message | Google Ads cookies, ad click identifier, the fact of the event, a random enquiry identifier | GDPR Article 6(1)(a): your consent given in the cookie banner; Section 7.1 of the Information Society Services Law of Latvia |
| Receive a notification of your enquiry as a Telegram message so that we can reply faster | Cadastral number or address, phone number, desired price, page language, time of submission, enquiry identifier, ad click identifier, if any | GDPR Article 6(1)(a): your consent given via the checkbox in the form; for the transfer outside the European Economic Area, GDPR Article 49(1)(a) (Section 7) |
Ad measurement takes place only after your consent. Until then the Google tag is not loaded on the site (Section 13).
We send the enquiry data as a Telegram message only if you tick the Telegram checkbox in the form. The checkbox is optional. If you do not tick it, we accept the enquiry all the same.
We do not use enquiry data for sending advertising.
4. Is providing data mandatory
Providing data is voluntary. No law or contract requires it.
Without a phone number we cannot call you. Without a cadastral number or address we cannot evaluate the property.
The Telegram checkbox is optional. If you do not tick it, we accept and review the enquiry all the same; the only difference is that we do not receive the enquiry data as a Telegram message (Section 6).
5. How long we keep data
- If no transaction takes place, we delete the enquiry data 12 months after the date of the enquiry.
- For each enquiry we receive a notification by e-mail containing the enquiry data and, if you ticked the Telegram checkbox, also a Telegram message containing the enquiry data. We keep these notifications for as long as the enquiry and delete them afterwards. If you withdraw your Telegram consent earlier, we delete the Telegram message containing your data once we receive the withdrawal.
- We keep the record of your Telegram consent for as long as the enquiry.
- We delete the IP address 30 days after the date of the enquiry.
- If a transaction takes place, we keep the contract and payment documents for the period set by the Accounting Law of Latvia.
- Deleted data remains in backup copies for up to 35 more days. After that the copies are overwritten.
- Google Ads cookies and the ad click identifier are stored on your device for up to 90 days; if you withdraw consent, we delete the click identifier from your browser immediately. The click identifier received together with an enquiry is kept for as long as the enquiry.
6. Who receives data
We do not sell data and do not pass it to other companies for their own purposes.
The following processors process data on our behalf:
- Cloudflare, Inc. (USA): site hosting, the enquiry database and e-mail relay;
- Resend, Inc. (USA): sending us a notification e-mail for each enquiry;
- the e-mail service provider in whose mailbox we receive the enquiry notifications.
We also receive a notification for each enquiry as a Telegram message. The message is delivered by Telegram Messenger Inc. and Telegram FZ-LLC, whose servers are located outside the European Economic Area. What the Telegram message contains depends on the checkbox in the form:
- if you ticked the Telegram checkbox, the message contains the cadastral number or address of the property, the phone number, the desired price, the page language, the time of submission, the enquiry identifier and the Google ad click identifier, if any;
- if you did not tick it, the message contains only a notification without data by which you can be recognised: the page language, the desired price (or a note that no price was given) and a random enquiry identifier. In that case we do not send the property, the phone number or the click identifier to Telegram.
We never include the IP address in the Telegram message. The basis for the transfer and the risks are described in Section 7.
When delivering the site, Cloudflare processes the IP address of every visitor. This is necessary to deliver the site and to protect it against attacks.
If you choose "Accept" in the cookie banner, ad effectiveness measurement data is received by Google Ireland Limited (Ireland) and Google LLC (USA). Until you consent, the Google tag is not loaded on the site and Google receives no data from the site. What Google receives after consent is described in Section 13.
We disclose data to public authorities only where the law requires it.
7. Transfers outside the European Economic Area
Cloudflare, Inc., Resend, Inc. and Google LLC are registered in the USA. The Western Europe region has been selected for the enquiry database. Google LLC receives data only if you consent to cookies (Section 13).
The basis for transfers to Cloudflare, Resend and Google is the European Commission's adequacy decision on the EU–US Data Privacy Framework. With Cloudflare and Resend, standard contractual clauses are additionally in force.
If you tick the Telegram checkbox in the form, the enquiry notification containing your data (Section 6) is sent to the servers of Telegram Messenger Inc. and Telegram FZ-LLC outside the European Economic Area. The basis for the transfer is your explicit consent (GDPR Article 49(1)(a)), which you give by ticking the checkbox.
Before you consent, we inform you of the risks. The European Commission has not adopted an adequacy decision for the countries in which Telegram's servers are located. No standard contractual clauses or other appropriate safeguards are in place with Telegram. Your data on Telegram's servers may therefore not enjoy the protection guaranteed by European Union law, and it may be harder for you to exercise your rights regarding that data against Telegram than within the European Economic Area.
The checkbox is optional. If you do not tick it, we accept the enquiry all the same, and the Telegram message contains only a notification without data by which you can be recognised (Section 6).
You may withdraw your consent at any time by writing to [email protected]. After withdrawal we delete the Telegram message containing your data. Withdrawal does not affect the lawfulness of the transfer before the withdrawal.
You may request a copy of the standard contractual clauses (Cloudflare, Resend) by writing to [email protected].
8. If the enquiry is submitted by someone other than the owner
This section applies to an owner whose property has been submitted by another person.
In this case we do not receive your data from you. The person submitting the enquiry gives us the cadastral number or address of the property. From the Land Register and the Cadastre we obtain your name and information about the property.
The purpose is to evaluate whether we would buy the property. The legal basis is GDPR Article 6(1)(f).
We inform you about the processing on the first occasion we contact you, and no later than one month after obtaining the data.
If you do not wish to sell, tell us. We will then delete your data within 30 days.
You have all the rights listed in Section 9, including the right to object to the processing.
9. Your rights
You have the right to:
- obtain confirmation of whether we process your data and receive a copy of it;
- have inaccurate data corrected;
- request deletion of your data;
- request restriction of processing;
- object to processing based on our legitimate interest;
- receive the data you submitted yourself in a portable format;
- withdraw your consent to cookies and ad measurement at any time via "Cookie settings" in the site footer (Section 13);
- withdraw your consent to the Telegram notification at any time by writing to [email protected]; we then delete the Telegram message containing your data (Section 7).
We do not make automated decisions. We do not carry out profiling.
10. How to submit a request
Write to [email protected] or call 27177070.
In your request, state the phone number you entered in the form. We locate your enquiry by that number. The form does not ask for an e-mail address or a name.
We reply within one month. We carry out deletion requests within 30 days. Data disappears from backup copies within a further 35 days.
Handling your request is free of charge.
11. Complaint to the supervisory authority
You may lodge a complaint with the Data State Inspectorate of Latvia (Datu valsts inspekcija). The procedure is described on the Inspectorate's website dvi.gov.lv.
12. If the transaction proceeds
Preparing the contract requires additional data, for example a personal identity number and a bank account number. We inform you about this processing separately, before we receive that data.
13. Cookies and your device
On investum.lv we measure the effectiveness of Google ads: whether a click on an ad led to an enquiry, a call or a WhatsApp message. This requires your consent. We ask for it in the cookie banner when you open the site for the first time. The banner offers two choices: "Accept" and "Decline".
Before consent. The Google tag is not loaded on the site. Google receives no data, and no cookies are set on your device. The same applies if you choose "Decline".
After "Accept". The Google Ads tag (Google Ireland Limited, Google LLC) is loaded on the site. We use it only for conversion measurement. We measure three events: submission of the enquiry form, a click on the phone link and a click on the WhatsApp link. For a form submission we pass Google a random enquiry identifier so that one enquiry is not counted twice. This is not personal data. We do not pass form fields to Google.
We do not use ad personalisation (remarketing) or Google analytics. These settings of the Google tag are permanently switched off, also after consent.
After consent, when you move to another page of investum.lv, the Google tag may add the ad click identifier or a _gl parameter to the page address.
After "Accept", the following entries are placed on your device:
| Name | Set by | Purpose | Duration | Basis |
|---|---|---|---|---|
_gcl_au, _gcl_aw (cookies) |
Measure whether an ad click led to an enquiry, a call or a WhatsApp message | Up to 90 days | Your consent | |
gclid, gbraid or wbraid (browser localStorage) |
investum.lv | Remember that you came from a Google ad and attach the click identifier to your enquiry | Up to 90 days; deleted immediately after "Decline" | Your consent |
investum_consent (browser localStorage) |
investum.lv | Remember your choice and its date so that the banner is not shown again | Until you clear your browser data | Strictly necessary entry; no consent required |
investum_consent is also written after "Decline", as otherwise the banner would appear every time.
The legal basis for consent is GDPR Article 6(1)(a) and Section 7.1 of the Information Society Services Law of Latvia.
If you opened the site from an ad and chose "Accept", we send the click identifier together with your enquiry and store it with the enquiry. The basis for this processing is also your consent. This is how we know that the enquiry came from an ad.
Google LLC is located in the USA. The basis for the transfer is given in Section 7.
Withdrawal. You may withdraw your consent at any time: click "Cookie settings" in the site footer and choose "Decline". After withdrawal we no longer load the Google tag, set no new cookies and delete the click identifier from your browser. You may delete cookies already set by Google in your browser settings. Withdrawal does not affect the lawfulness of processing before the withdrawal. The site and the enquiry form work without consent as well.
If the submission of the enquiry fails, the property description and price you entered are briefly visible in the browser address bar. The phone number does not appear there. This is needed so that your input is not lost. Your browser may save this address in its history.
14. Changes
We publish changes on this page with a new revision date.
Revision: 8 October 2026.