1. Overview
This policy sets out the basis on which SIA Vitol Terminal Latvia (hereinafter – VTL) processes all personal data obtained through video surveillance carried out via medium-range video recordings within the territory and infrastructure area of SIA Vitol Terminal Latvia.
Please read the information below carefully to understand how we process your personal data and the basis for it. By visiting www.vtl.lv and/or entering areas or infrastructure managed by us, you accept and agree to the practices described in this policy.
On this website and in other printed and electronic communications, the terms “Vitol,” “Vitol Group,” “the Company,” or “the Group” may be used for convenience and refer to Vitol Netherlands Coöperatief U.A. and its direct and indirect subsidiaries and affiliates (including VTL), each of which are separate and distinct legal entities. Further, the words “we,” “us,” “our,” and “ourselves” are used to refer generally to the companies of the Vitol Group.
2. Definitions
Personal data – any information relating to an identified or identifiable natural person (data subject), including a person’s image, actions and movements visible in video footage where the person can be recognised.
Data subject – an identified or identifiable natural person appearing in video footage.
Controller – in this case, VTL/a legal person who alone or jointly with others carries out video surveillance and determines the purposes and means of personal data processing.
Accountability – the controller shall transparently demonstrate and substantiate, by means of appropriate documentation (or a set of documents), that data processing is carried out in compliance with the requirements of the General Data Protection Regulation (GDPR).
Legitimate – lawful, legally recognised.
3. Purpose and Legal Basis for Video Surveillance
Video surveillance in the territory and infrastructure area of SIA Vitol Terminal Latvia is based on:
- the General Data Protection Regulation (GDPR)
- the “Procedure for the identification of critical infrastructure, including European critical infrastructure, and the planning and implementation of security measures and continuity of operations”
- the Personal Data Processing Law
- the Law on Ports and the Ports Law
We collect personal data to ensure the security of the terminal as a critical infrastructure facility, to monitor technical infrastructure, and to prevent criminal activity targeting VTL infrastructure, as well as to comply with port security requirements established in national and international legal acts and mitigate associated risks.
Legitimate interests serve the purpose of preventing criminal acts, based on the legal grounds of protecting property, gathering evidence, detecting violations or otherwise preventing unlawful activity necessary to safeguard individuals, assets or property.
4. Surveillance Areas
Video surveillance is conducted within the territory of SIA Vitol Terminal Latvia and the technical infrastructure area (pipeline corridor), including access points, access roads, parking areas, jetties, and other publicly accessible areas related to terminal operations.
5. Types of Data and Retention
Video surveillance records (image, movement, date/time) are processed internally. Recordings are stored for no longer than 30 days unless needed for incident investigation or to meet legal obligations.
6. Data Access and Disclosure
Access to the data is restricted to authorised VTL personnel. Video recordings may only be used for the prevention and investigation of criminal offences. Data may be used solely for that purpose and may be disclosed to law enforcement authorities (e.g. the police), port security institutions, or insurance companies for the purpose of proving insured events, or to other state institutions in cases provided by law.
7. Rights of the Data Subject
Individuals have the right to request information regarding the processing of their data, as well as the erasure or restriction of such data, insofar as this does not compromise security interests.
Requests can be submitted:
📧 by email: terminals@vtl.lv
📬 by post: SIA Vitol Terminal Latvia, Talsu iela 75, Ventspils, LV-3602
More information about data processing is available in the SIA Vitol Terminal Latvia Privacy Policy or by contacting the terminal administration by email at terminals@vtl.lv.