Legal Document

Privacy Policy

Last updated: 2026-05-28 GDPR Compliant UK & EU Law
§ 01

Data Controller

The data controller for personal data processing is X DIGITAL ASSETS SIA, Registration No. 40203611907, Riga, Latvia.

Website xda.lv

Data processing is carried out in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and the laws of the Republic of Latvia.

§ 02

What Personal Data We Process

We process only the data necessary for the stated purposes:

Data CategorySpecific DataCollection Method
Contact informationName, email address, phone number (if provided)Contact form, email
Company dataCompany name, job titleContact form
Message contentRequest text, project descriptionContact form
Technical dataIP address, browser, visit timeAutomatically (only with analytics consent)

We do not process special categories of personal data (health data, biometric data, political opinions, etc.).

§ 03

Processing Purposes and Legal Basis

§ 04

Data Recipients and Third-Party Transfers

Personal data is not sold to third parties. Data may be disclosed to:

Data is not transferred outside the European Economic Area without appropriate safeguards in place.

§ 05

Data Retention Periods

Data TypeRetention Period
Contact form inquiries3 years from the date of contact or until the inquiry is fulfilled
Contractual data6 years (in accordance with UK limitation periods)
Technical log filesUp to 12 months
Analytics dataUntil consent is withdrawn or 26 months
§ 06

Your Rights as a Data Subject

Under the GDPR, you have the following rights:

To exercise your rights, please write to info@xda.lv with the subject line "Personal Data Request". We will respond within 30 days.

§ 07

Cookies

We use cookies to ensure the functionality of our website. Cookies are small text files stored on your device.

You can change your cookie settings at any time using the button in the bottom-right corner of the page. More information: Cookie Policy.

§ 08

Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or destruction. These measures include:

In the event of a data breach, we will notify the competent authorities and affected individuals within the timeframes prescribed by the GDPR.

§ 09

Policy Amendments

We reserve the right to update this privacy policy. Material changes will be communicated by publishing the new version on the website with an updated date. We recommend reviewing this document periodically.

§ 10

Filing a Complaint

If you believe that we are processing your data unlawfully, you have the right to file a complaint with the supervisory authority:

Data State Inspectorate (DVI)
Address: Blaumaņa iela 11/13-11, Riga, LV-1011
Phone: +371 67223131
Website: dvi.gov.lv

We encourage you to contact us first so that we can resolve the matter through direct communication.

§ 11

Client-Submitted Documents and Content

This section applies whenever a Client (natural or legal person) submits documents, files, text or other content to us (the "Submitted Content") in connection with our services - including contract drafting, legal review, system development, AI analysis or any other engagement.

11.1. Purposes and legal basis

We process Submitted Content only for the following purposes:

We do not use Submitted Content for any other purpose - including marketing, profiling, third-party services or AI model training - unless there is a separate written agreement with the Client.

11.2. Confidentiality

All Submitted Content is treated as confidential information protected by contract, professional secrecy obligations and applicable UK law (including the common-law duty of confidentiality and the Trade Secrets (Enforcement, etc.) Regulations 2018). Confidentiality continues to apply after the engagement ends, unless required otherwise by law.

Our employees, partners and processors are bound by confidentiality undertakings or equivalent legal duties.

11.3. Storage and deletion

Type of Submitted ContentRetention period
Contracts and accounting documents6 years after end of the transaction (Companies Act 2006 s. 388, Limitation Act 1980)
Client project working materialsDuration of the service + 3 years (or shorter at the Client's written request)
Text/PDF submitted to AI Demo pageNot stored - processed in memory and discarded immediately after the response is returned
Project correspondence and emails5 years from the last communication
Materials containing third-party personal dataOnly for the period necessary for service performance, not longer than the periods above

The Client may request deletion of their Submitted Content before the periods above, unless the law or our legitimate interests (e.g. retention of performance evidence) require longer storage. Send requests to info@xda.lv with the subject "Submitted Content deletion request".

11.4. Security measures

§ 12

Use of AI and Automated Processing

In some services (for example, the AI Demo page at xda.lv/en/demo or in custom AI solutions delivered under separate agreements) we use artificial intelligence (AI / LLM) models to analyse or process Submitted Content.

12.1. How it works

12.2. International transfers

Some AI providers are located outside the UK and the European Economic Area (EEA), for example in the USA. For such transfers we ensure appropriate safeguards under GDPR Art. 46, including:

The Client may request information about specific processors and their location by emailing info@xda.lv.

12.3. No automated decision-making

AI analysis results are informational and advisory. They do not constitute automated decision-making within the meaning of GDPR / GDPR Art. 22 and they do not replace professional legal, financial or technical advice. Final decisions are always made by the Client or an authorised expert.

12.4. AI Demo page - special terms

The Demo page (xda.lv/en/demo) is a public, free demonstration. Submitted text is not stored - it is processed in memory and discarded immediately after the response is returned. Nevertheless, please do not submit genuinely confidential documents, personal data, contracts or trade-secret material via the Demo page - sign a separate service agreement with us for such use cases.

§ 13

Client Warranties and Liability for Submitted Content

By submitting documents or other content, the Client represents and warrants that:

If any of these warranties is breached, the Client is liable for any resulting damages (including third-party claims against us) and shall indemnify and hold harmless X DIGITAL ASSETS SIA from such liability.

More detailed provisions are set out in our Terms of Use and, where applicable, in a separate service agreement or Data Processing Agreement (DPA) between the parties.

§ 14

Data Processing Agreement (DPA)

When the Client (as controller) shares personal data with us for processing (we act as processor), the parties are entitled - and in certain cases, under GDPR / GDPR Art. 28, required - to enter into a separate Data Processing Agreement (DPA).

A DPA template and proposal can be requested by emailing info@xda.lv with the subject "DPA request". Our standard DPA is based on the EU Commission template (Decision 2021/915) with the UK Addendum and is adapted to the specifics of our services.