UGC BALTIC
ugcbaltic.com
CONSENT TO PERSONAL DATA PROCESSING
and participation in the UGC content programme
Effective from 01 April 2026
By registering on the website ugcbaltic.com, completing any questionnaire or course application, or submitting video content, the User confirms that they have read this Consent, understand its content, and voluntarily agree to the personal data processing set out below.
1. Data controllerThe controller of your personal data is:
• Name: SIA TTW
• Registration number: 40203734031
• Legal address: 10 Raznas Street, Lipuski, Makonkalna Parish,
Rezekne Municipality, LV-4626
• Email: thetimetowish@gmail.com
• Website: ugcbaltic.com
2. What personal data we processUpon registering or using the Platform’s services, we collect the following personal data:
2.1 Identification and contact data• First and last name
• Email address
• Phone number
• Parcel locker address (for product delivery)
• Technical data, IP address, necessary cookies
2.2 Social Media data• Links to the User’s social media profiles (Instagram, Facebook, TikTok, YouTube, etc.)
• Approximate social media audience metrics (follower count, engagement level) — provided voluntarily
2.3 Video content (UGC)• Video files created by the User — product unboxing and usage videos
• Photo materials, if attached to the video description
• Voice recordings in video files
• Visual likeness (face, body) in video recordings, to the extent included by the User in the content
2.4 Wishlist data• Links to specific products on the User’s wishlist
• Product category preferences
• Comments and descriptions attached to wishlist items
2.5 Technical data• IP address, browser type and version
• Device type and operating system
• Page visit history on the Platform
• Cookies
3. Why we process this data
Processing purpose | Legal basis |
User registration and account management | Performance of a contract (GDPR 6(1)(b)) |
Processing course applications and communication | Performance of a contract (GDPR 6(1)(b)) |
Coordinating receipt of goods from sponsors | Consent (GDPR 6(1)(a)) |
Collection of UGC video content and handling of legal rights | Consent (GDPR 6(1)(a)) |
Publishing videos on the Platform’s and sponsors’ channels | Consent (GDPR 6(1)(a)) |
Organising competitions and determining winners | Consent (GDPR 6(1)(a)) |
Preparing marketing materials from UGC content | Consent (GDPR 6(1)(a)) |
Informing sponsors about suitable content creators | Consent (GDPR 6(1)(a)) |
Sending informational notifications | Consent (GDPR 6(1)(a)) |
Platform performance analysis and improvement | Legitimate interest (GDPR 6(1)(f)) |
Fraud prevention and security | Legitimate interest (GDPR 6(1)(f)) |
Accounting and tax obligations | Legal obligation (GDPR 6(1)(c)) |
4. Rights to use video contentBy submitting video content to the Platform, the User grants SIA TTW non-exclusive, royalty-free rights to use such content for the following purposes:
1. Publication on the Platform’s social media channels (Instagram, Facebook, TikTok, YouTube, etc.)
2. Publication on the sponsor’s (product manufacturer or supplier) social media channels and marketing materials
3. Inclusion in the Platform’s advertising campaigns, presentations, and commercial communications
4. Participation in competitions and prize programmes
5. Creation of educational content (e.g. as an example of good UGC content)
These rights take effect from the moment the video file is submitted to the Platform and remain in force until the User withdraws their consent in writing.
The User confirms that the video materials are their original work, that no third-party copyright-protected content has been included without permission, and that their publication does not infringe the rights of any third party.
5. Who we share your data withWe do not transfer personal data to third parties for commercial purposes. Data transfers may occur in the following cases:
• To technical service providers (server hosting, email services, CRM systems) — solely on the basis of data processing agreements
• To sponsors and brands — only anonymised statistics or with the User’s explicit consent for a specific collaboration
• To Latvian state authorities (State Revenue Service, law enforcement) — if required by law or a court order
All our partners and service providers are bound by data processing agreements compliant with GDPR requirements.
6. How long we retain dataWe will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or to meet legal obligations. Once your data is no longer needed, we will securely delete or anonymise it, as set out in Article 5(1)(e) of the GDPR.
7. Data securityWe apply the following protective measures:
• HTTPS encryption for all data transmission between the User and the Platform
• Encryption of sensitive data at rest
• Access control — data may only be processed by authorised persons
• Regular software updates and security audits
• Data backup and recovery procedures
8. Your rightsUnder the GDPR you have the following rights:
• Right of access — to receive information about what data we process
• Right to rectification — to request the correction of inaccurate data
• Right to erasure (“right to be forgotten”) — to request the deletion of your data
• Right to restriction of processing — to request that data processing be suspended
• Right to data portability — to receive your data in a structured format
• Right to object — to object to processing based on legitimate interest
• Right to withdraw consent — to withdraw the consent given at any time
9. Withdrawal of consentYou may withdraw your consent at any time by sending a written request to our email address.
Upon withdrawal of consent:
• We will cease processing your data for purposes that required consent
• Your submitted video content will not be included in new marketing materials
• Removal of existing published materials is considered on a case-by-case basis, taking into account technical feasibility
• Data whose processing does not require consent (legal obligations) will continue to be retained for the period prescribed by law
Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
10. Right to lodge a complaintIf you believe that the processing of your personal data violates the GDPR or Latvian legislation, you may contact:
Data state inspectorate• Email: pasts@dvi.gov.lv
• Phone: +371 67223131
• Address: 17 Elijas Street, Riga, LV-1050
• Website: www.dvi.gov.lv
Before contacting the Inspectorate, we encourage you to reach out to us directly — we aim to resolve all queries promptly.
11. Changes to this documentWe may update this Consent to reflect changes in the Platform’s operations or applicable legislation. In the event of material changes, we will notify Users by email and publish a notice on the ugcbaltic.lv website. Continued use of the Platform after changes take effect shall be deemed acceptance of the updated document.
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DECLARATIONBy registering on the Platform or submitting content, I confirm that:
1. I have read and understood this Consent
2. I am of legal age (or am acting with the permission of a parent/guardian)
3. I voluntarily agree to the personal data processing specified herein
4. The submitted video content is my original work and does not infringe the rights of third parties
5. I understand that I may withdraw my consent at any time by writing to thetimetowish@gmail.com
SIA TTW | thetimetowish@gmail.com | ugcbaltic.com
