Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We use different methods to collect data from and about you including through:
Where we need to collect personal data by law, or under the terms of an agreement we have with you and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you, including to provide you with the Services. In this case, we may have to cancel the Services you have with us but we will notify you if this is the case at the time.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Legitimate interest means the interest of our business in conducting and managing our business to enable us to provide you with the best Services and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose or Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as our client and decide whether and on what terms to provide the Services||Identity, Contact and Financial||Performance of an agreement with you|
|To process and deliver the Services including, to (a) provide customer support and communicate with you, (b) manage payments and fees and verify transactions, (c) collect and recover fees owed to us, and (d) resolve disputes and enforce agreements entered between us||Identity, Contact, Financial, Transaction, Marketing and Communications||Performance of an agreement with you; Necessary for our legitimate interests|
|To prevent and investigate prohibited or illegal activities or fraud, including, prevent money laundering and terrorist financing||Identity, Contact, Financial, Transaction||Performance of an agreement with you; Necessary for our legitimate interests|
|To enable you to partake in a competition or complete a survey||Identity, Contact, Profile, Usage, Marketing and Communications||Performance of an agreement with you; Necessary for our legitimate interests (to study how you use our Services, to develop them and grow our business)|
|To administer, customize, update, maintain, protect and improve the Website and the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity, Contact, Technical and Usage||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation); Necessary to comply with a legal obligation|
|To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Identity, Contact, Profile, Technical, Usage, Marketing and Communications||Necessary for our legitimate interests (to study how you use our Services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Website, Services, marketing, customer relationships and experiences||Technical and Usage||Necessary for our legitimate interests (to define types of clients for our Services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about Services that may be of interest to you||Identity, Contact, Technical and Usage, Profile||Necessary for our legitimate interests (to develop our Services and grow our business)|
We may use your identity, contact, profile, technical and usage data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you (we call this marketing). You may receive marketing communications from us if you have requested information from us or purchased Services from us and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contact us at any time.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
We reserve the right at all times to disclose any personal data that we have collected when: (a) permitted or required by law; or, (b) trying to protect against, prevent, investigate actual or potential fraud, security issues, technical issues, unauthorized transactions or other violations; or (c) trying to enforce the applicable terms of service or other agreements; or (d) protecting against violations to the rights, property or safety of us, our users or the public as required or permitted by applicable laws; or (e) you have given your consent to do so. Finally, we may transfer personal data to a successor entity in connection with a corporate merger, consolidation, partial or total sale of assets, bankruptcy, or other corporate change.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We adhere to the generally accepted industry standards to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Only our authorized employees, agents and contractors (who have agreed to keep personal data secure and confidential) have access to the personal data on a need to know basis.
Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
You agree and acknowledge that the Internet may be subject to breaches of security and that the submission of data over the Internet may not be secure. We strive to use acceptable means to protect any personal data you share with us, however we cannot guarantee its absolute security.
We will retain your personal data only for so long as it is required for the purposes for which it was collected. This period may extend beyond the end of your relationship with us, but only for so long as is reasonably necessary for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations (e.g. taxation purposes), resolve disputes and enforce our agreements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
When your personal data is no longer required, we will destroy, delete or convert it into an anonymous form.
We do not allow use of our Services and the Website by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.
Under certain circumstances, you have following rights under data protection laws in relation to your personal data:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
This version was last updated on 11.05.2018 and historic versions can be obtained by contacting us.
If you reside in the EEA, we will be the controller of your personal data provided to, or collected by, or processed in connection with our Services. You have the right to make a complaint at any time to the Estonian Data Protection Inspectorate (address 19 Väike-Ameerika St., 10129 Tallinn, Estonia, e-mail address firstname.lastname@example.org, phone +372 627 4135). We would, however, appreciate the change to deal with your concerns before you approach the Data Protection Inspectorate, so please contact us in the first instance.