Publication Date: June 5, 2025
Last Update Date: June 5, 2025
Latvijas Mobilais Telefons SIA (“We”, “LMT” or “Data Controller”) values and protects privacy and confidentiality of its customers (“You”, “User” or “Data Subject”) around the world. We process Your personal data in strict compliance with the applicable laws and regulations, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “General Data Protection Regulation” or “GDPR”), the Personal Data Processing Law of the Republic of Latvia and any other applicable European or national laws and regulations in the field of privacy and data protection. Any reference to the aforementioned data protection laws and regulations (the “Data Protection Regulation”) shall be deemed to include any subsequent replacement or amendment to the Data Protection Regulation.
This AER© application privacy policy (the “Privacy Policy”) applies to the processing of Your personal data (the “Personal Data”), while providing You Our AER© solution software package, which consists of a mobile application (the “Application”) and Amazon Web Services (AWS) based data analytics platform (the “Platform”), and ensuring its functionality on Your electronic device (the “Device”). AER© solution software package allows You to monitor remotely AER© smart sensor (the “AER© Sensor”) real time and historical measurements, such as level of smoke, air quality, temperature and humidity (the “AER© Sensor Data”), displayed on the interactive dashboard of Your personal profile with the Application (the “Account”). Users can also receive with the Application (i) high-priority push notifications in the event of a significant increase in the level of smoke at the location of AER© Sensor, or in the case of a failure or critically low battery charge of the AER© Sensor, (ii) medium-priority push notifications in the event of a noticeable change in the level of smoke, and air quality at the location of AER© Sensor, and (iii) low-priority push notifications in the event of a change in the level of air quality or in the comfort level of, temperature and/or humidity at the location of AER© Sensor, or in the case of a low battery charge of the AER© Sensor.
WE WILL REQUIRE YOU TO READ OUR PRIVACY POLICY CAREFULLY TO LEARN MORE ABOUT HOW WE PROCESS YOUR PERSONAL DATA, WHEN YOU USE THE APPLICATION. THIS PRIVACY POLICY CONSTITUTES AN INALIENABLE PART OF THE AER© APPLICATION TERMS OF USE (THE “TERMS OF USE”), WHICH DEFINE THE TERMS AND CONDITIONS REGULATING USE OF THE APPLICATION. IF YOU DO NOT AGREE TO OUR TERMS OF USE AND/OR PRIVACY POLICY, PLEASE REFRAIN FROM INSTALLING OUR APPLICATION ON YOUR DEVICE AND CREATING YOUR ACCOUNT WITH THE APPLICATION.
Our Privacy Policy is a reader-friendly explanation of Our data processing activities divided into various sections depending on the topic to make it easier for You to navigate through its content:
We act as data controller in relation to Your personal data listed in this Privacy Policy:
We also act as a data processor in relation to Your Account Personal Data, Your AER© Sensor Data and AER© Sensor description shared with Us by Our local partners or by You on behalf of those partners. We process such personal data in strict compliance with the terms and conditions of the legally binding data processing agreements signed with each local partner. You can check the list of Our current local partners on Our official website at https://innovations.lmt.lv/. Your Account will include detailed information about Our local partner that You have selected to provide You with the Internet of Things (IoT) products and services (the “Partner”), subject to the IoT terms of use.
If you have any questions or concerns regarding the handling of Your Personal Data as described in this Privacy Policy, please, feel free to reach out to Our Data Protection Office using the contact details provided in Section 10: Contact Information of Our Data Protection Officer.
In order to use Our Application, You will need to install it on Your Device and create Your Account. During the onboarding process, We will ask You to provide Your phone number and verify it by entering a one time password (OTP) that We send You. You will receive an OTP only if the phone number You have provided to Us matches the phone number shared with Us through the Platform by the Partner. After the successful verification, You will have to enter Your Account name. To complete the onboarding process, We will require You to read and accept Our Terms of Use and this Privacy Policy to establish Your contractual relationship with Us. As a result, You will receive access to Your Account and user rights to configure, customise and manage Your Account by adjusting relevant settings in order to exercise Partner’s IoT services also accessible with the Application. Your Account will automatically link with Your AER© Sensor through the Platform and Your AER© Sensor Data will appear on the interactive dashboard of Your Account.
3.1. We request and expect You to provide the following Personal Data, when You create Your Account:
| Type of Personal Data | Purposes of its Processing | Legal Bases |
|---|---|---|
| Your Account name, phone number, one time password (OTP) and selected language of the interface of the Application * | Create, configure, customise, manage and back up Your Account | Performance of the contract in accordance with the Terms of Use |
| Phone number * | Link (connect) Your Account to Your AER© Sensor through the Platform and unlink (disconnect) Your Account from Your AER© Sensor through the Platform | Performance of the contract in accordance with the Terms of Use |
| Your Account name, Device type and model, its international mobile equipment identity (IMEI), firmware type etc. | Create log files to deliver the Application and ensure its functionality, stability, integrity and security | Performance of the contract in accordance with the Terms of Use |
* Please note that Your Personal Data requested by Us in order to create Your Account is mandatory. If any mandatory Personal Data is missing, We will not be able to create Your Account, and You will not be able to use Our Application.
3.2. We collect Your Personal Data, when You use Your Account with the Application:
| Type of Personal Data | Purposes of its Processing | Legal Bases |
|---|---|---|
| Your Device type and model, its international mobile equipment identity (IMEI), mobile internet protocol (IP) and metadata of Your Device used to operate Our Application | Deliver Application and ensure its functionality, including Your Account backup | Performance of the contract in accordance with the Terms of Use |
| Your Account name, phone number and selected language of the interface of the Application | Access, configure, customise, back up, manage of Your Account | Performance of the contract in accordance with the Terms of Use |
| Phone number | Send high-priority, medium-priority and low-priority push notifications with the Application in the event of a change in the level of smoke, air quality, temperature and/or humidity etc. | Performance of the contract in accordance with the Terms of Use |
| Phone number | Send push notifications with the Application to inform You on the changes made to Our Terms of Use or this Privacy Policy | Performance of the contract in accordance with the Terms of Use |
| Your Account name, Device type and model, its international mobile equipment identity (IMEI), firmware type etc. | Create log files to deliver the Application and ensure its functionality, stability, integrity and security | Performance of the contract in accordance with the Terms of Use |
3.3. We request the following data, when You communicate with Us:
| Type of Personal Data | Purposes of its Processing | Legal Bases |
|---|---|---|
| Your phone number, Account name and e-mail address ** | Identify You and process Your requests to exercise Your data subject rights | Compliance with Our obligations arising out of or in connection with the Data Protection Regulation |
** Please note that Your Personal Data processed by Us in order to identify You is mandatory. If any mandatory Personal Data is missing, We will not be able to process Your request, and You will not be able to exercise Your rights.
We will disclose Your Personal Data to Our Partners and third-party service providers:
4.1. Sharing Your Personal Data with Our Partners:
4.2. Disclosing Your Personal Data to Amazon Web Services, Inc:
We retain Your Personal Data for the following duration:
| Type of Personal Data | Purposes of its Processing | Personal Data Retention Period |
|---|---|---|
| Your Account name, phone number, one time password (OTP) and selected language of the interface of the Application | Create, access, configure, customise and manage Your Account | Term of Your contractual relationship with Us, which terminates either (i) by You clicking on the designated “DELETE ACCOUNT AND AER SENSOR DATA” button in Your Account settings; (ii) by Us terminating Your rights of access and use of the Application due to Your breach of Terms of Use; (iii) by Us terminating Your rights of access and use of the Application following request of the Partner to unlink (disconnect) Your Account from Your AER© Sensor; (iv) by Us terminating Your rights of access and use of the Application due to the upcoming decommissioning of the Application *** |
| Phone number |
Link (connect) Your Account to Your AER© Sensor through the Platform and unlink (disconnect) Your Account from Your AER© Sensor through the Planform;
Send high-priority, medium-priority and low-priority push notifications with the Application in the event of a change in the level of smoke, air quality, temperature and/or humidity etc.; Send push notifications with the Application to inform You on the changes made to Our Terms of Use or this Privacy Policy |
Term of Your contractual relationship with Us, which terminates either (i) by You clicking on the designated “DELETE ACCOUNT AND AER SENSOR DATA” button in Your Account settings; (ii) by Us terminating Your rights of access and use of the Application due to Your breach of Terms of Use; (iii) by Us terminating Your rights of access and use of the Application following request of the Partner to unlink (disconnect) Your Account from Your AER© Sensor; (iv) by Us terminating Your rights of access and use of the Application due to the upcoming decommissioning of the Application *** |
| Your Device type and model, its international mobile equipment identity (IMEI), mobile internet protocol (IP) and metadata of Your mobile device used to operate Application | Deliver Application and ensure its functionality | Term of Your contractual relationship with Us, which terminates either (i) by You clicking on the designated “DELETE ACCOUNT AND AER SENSOR DATA” button in Your Account settings; (ii) by Us terminating Your rights of access and use of the Application due to Your breach of Terms of Use; (iii) by Us terminating Your rights of access and use of the Application following request of the Partner to unlink (disconnect) Your Account from Your AER© Sensor; (iv) by Us terminating Your rights of access and use of the Application due to the upcoming decommissioning of the Application *** |
| Your Account name, phone number, Device type and model, its international mobile equipment identity (IMEI), mobile internet protocol (IP) and metadata of Your mobile device used to operate Application, as well as selected language of the interface of the Application | Create Your Account backup | Two (2) weeks following creation of the backup *** |
| Your Account name, Device type and model, its international mobile equipment identity (IMEI), firmware type etc. | Create log files to deliver the Application and ensure its functionality, stability, integrity and security | Eighteen (18) months following creation of the log files *** |
| Your account name, phone number and e-mail address | Identify You and process Your requests to exercise Your rights, as a data subject | Eighteen (18) months following receipt of the corresponding request *** |
*** Please note that the duration of data retention remains contingent upon the mandatory data retention requirements that may apply to Us, particularly concerning the establishment, exercise or defence of legal claims against Us, within the applicable statutory limitation periods. We will erase or anonymise Your Personal Data when it is no longer necessary for the designated purposes, except to the extent otherwise provided by the applicable national laws or regulations.
PLEASE NOTE THAT YOUR ACCOUNT PERSONAL DATA WILL NOT BE ERASED AUTOMATICALLY IF YOU UNINSTALL THE APPLICATION ON YOUR DEVICE. YOUR ACCOUNT PERSONAL DATA WILL NOT BE ERASED IF YOU CLICK ON “DELETE AER SENSOR DATA AND RESET AER SENSOR” BUTTON IN YOUR ACCOUNT SETTINGS. IN ORDER TO DELETE YOUR ACCOUNT PERSONAL DATA AND YOUR AER© SENSOR DATA, YOU HAVE TO CLICK ON THE DESIGNATED “DELETE ACCOUNT” BUTTON IN YOUR ACCOUNT SETTINGS. YOU WILL NOT BE ABLE TO RECOVER YOUR ACCOUNT PERSONAL DATA AND YOUR AER© SENSOR DATA ONCE YOUR REQUEST IS PROCESSED BY US. FOR FURTHER DETAILS ON HOW TO DELETE YOUR ACCOUNT PERSONAL DATA AND YOUR AER© SENSOR DATA, PLEASE REFER TO OUR TERMS OF USE.
We have implemented various organisational, technical, and technological measures to ensure the security, integrity, and confidentiality of Your Personal Data, when requested, collected and processed by Us, Our Partners and third party service providers. However, We must emphasise that no internet transmission of any data, website browsing or application usage is entirely secure. Therefore, We wish to draw Your utmost attention to the potential confidentiality risks arising out of or in connection with the use of the Internet.
We request, collect, and process Your Personal Data in strict compliance with the Data Protection Regulation. As a data subject, You are entitled to the following rights regarding the processing of Your Personal Data:
| Right to be informed | You have the right to be informed in a clear, precise and transparent manner about Your Personal Data being requested, collected, used, consulted, shared, or otherwise processed by Us |
| Right of access | You have the right to request and receive a copy of Your Personal Data, including (i) the types of Your Personal Data being processed; (ii) the purpose of processing Your Personal Data; (iii) the legal basis for processing of Your Personal Data; (iv) any recipient(s) of Your Personal Data, including recipients in third countries, and information on the appropriate safeguards in case of transfer of Your Personal Data to third countries; (v) the duration of Your Personal Data processing activities (retention period); (vi) the source of Your Personal Data, if it has not been provided by You; as well as (vii) information on the rights of the data subject derived from the Data Protection Regulation |
| Right to rectification | You have the right to request Us to rectify or complete Your Personal Data without undue delay, if Your Personal Data is inaccurate or incomplete. You can also rectify, modify or complete Your Personal Data Yourself by updating Your Personal Data information through the Application |
| Right to erasure (right to be forgotten) | You have the right to request the erasure of Your Personal Data without undue delay, if Your Personal Data is (i) no longer necessary for the purpose for which it has initially been collected; (ii) it has been unlawfully processed in violation of the Data Protection Regulation; (iii) it has to be erased in order to comply with a legal obligation; (iv) it has been collected in relation to the offer of the information society services (e.g. social media) to a minor, (v) if You withdraw Your consent to the processing of Your Personal Data and there is no other legal basis for its processing by Us, or (vi) You object to the processing of Your Personal Data and (a) there is no overriding legitimate interest for continuing its processing or (b) Your Personal Data has been processed for direct marketing purposes |
| Right of restriction | You have the right to restrict Our use of Your Personal Data, if (i) You contest the accuracy of Your Personal Data; (ii) the use of Your Personal Data is unlawful, but You do not want Us to erase it; (iii) We no longer need Your Personal Data for the purpose We processed it for, but You require it for the establishment, exercise, or defence of Your legal interests; or (iv) You have objected against Us processing Your Personal Data based on Our legitimate interest, while verification of whether Our compelling interests prevail is pending |
| Right to object to processing | You have the right to object to Us processing Your Personal Data, when such processing is carried out in connection with Our legitimate interest. After exercising Your right of objection, We will stop processing Your Personal Data, unless We can demonstrate compelling legitimate interest for the processing of Your Personal Data that overrides Your interests, rights and freedoms, or if the processing of Your Personal Data serves to establish, exercise, or defend Our legal interests **** |
| Right to data portability | You have the right to obtain Your Personal Data from Us in a structured, commonly used, and machine-readable format that makes it easier for You to re-use Your Personal Data for other purposes, and to transmit Your Personal Data to another data controller of Your choice without hindrance or undue delay, provided that Your Personal Data has been processed based on Your consent or a mutual contractual relationship |
| Right to lodge a complaint | You have the right to lodge a complaint with the State Data Inspectorate (Blaumana street 11/13-15, Riga, LV-1011, Latvia phone: +371 67 223 131 , e-mail: info@dvi.gov.lv ) or any other relevant domestic data protection authority against Our processing Your Personal Data, if You consider that We are processing Your Personal Data in violation of the Data Protection Regulation |
**** When We refer to relying on Our legitimate interest to process Your Personal Data, it means that we believe Our legitimate interests are not overridden by Your interests, rights and freedoms, taking into account the circumstances and measures We take in order to protect Your Personal Data. If You want to learn more about the balancing of Our legitimate interests and Your interests, rights and freedoms, please, request additional information from Our Data Protection Office using the contact details provided in Section 10: Contact Information of Our Data Protection Officer.
If You have any enquiries regarding Your rights or You want to exercise any of the aforementioned rights, please, send Your request to Our Data Protection Office using the contact details provided in Section 10: Contact Information of Our Data Protection Officer. We will process Your enquiry or request as soon as possible, but not later than within one (1) month following receipt of the enquiry or request. We will process Your enquiry or request free of charge, unless it is clearly unreasonable or excessive.
We do not intentionally offer Our Application to the users who have not reached the legal age of maturity. It is expected that the User, who creates and manages an Account is an adult. The Application does not intentionally process personal data of minors. If such personal data has been collected through the Application, the legal representative of the minor should contact Our Data Protection Officer using the contact details provided in Section 10: Contact Information of Our Data Protection Officer in order to erase the personal data of the minor.
We may revise this Privacy Policy from time to time in our sole discretion to take into account most recent legal, regulatory, or technical developments. You can verify the date of the last update of the Privacy Policy at the top of the document under the "Last Update Date" note. Your access to and use of the Application will be subject to the most recent version of Our Terms of Use and this Privacy Policy.
If We make substantial changes to this Privacy Policy, such as changes in the identity of the Data Controller, the types of Your Personal Data being processed, the purposes of and legal bases for processing Your Personal Data, the recipients of Your Personal Data, etc., We will inform You in due course before these changes become effective. You will receive a push notification in the Application with the updated version of the Privacy Policy, which You will need to read and accept before continuing to use the Application. If You refuse to accept changes to this Privacy Policy, You will not be able to access Your Account from the date the amended Privacy Policy comes into effect.
If you have any enquiries or requests regarding the handling of Your personal data, please, feel free to reach out to Our Data Protection Office:
We will process Your enquiry or request as soon as possible, but not later than within one (1) month following receipt of the enquiry or request. We process enquiries and requests free of charge, unless they are clearly unreasonable or excessive.