This Privacy Notice applies to all personal data you provide to us and also to all personal data which we collect on you, either about how you use our website or mobile application (using “cookies”) or about your travel patterns if you make bookings with us.
1. YOUR PERSONAL DATA – WHAT IS IT?
Personal data relates to a living individual who can clearly be identified from that data, in particular your name, address, phone number, e-mail address, credit or bank card number, information on special care. Identification can be made by the information alone or in conjunction with any other information otherwise in the data controller’s possession or likely to come into such possession.
2. HOW DO WE COLLECT PERSONAL DATA?
We collect your data on our website, mobile app and via email.
3. WHY DO WE COLLECT PERSONAL DATA? (DATA PROCESSING PURPOSES)
We collect and use your personal data for the following purposes:
a) To deliver the services you have purchased from us.
b) To facilitate the purchase of third parties’ services or products on our website.
c) To communicate with you.
d) To send you newsletters.
e) To provide offers tailored to your preferences.
f) To communicate with you to carry out customer satisfaction survey for analytical purposes, for quality improvements, for service developments, to improve the performance of the website, to measure the success of our advertising campaigns or to tailor services to your needs.
g) To support administrative and legal purposes, for example anti-fraud screening, for safety and security purposes.
h) To comply with the mandatory provisions of the applicable laws.
4. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We process your personal data for the time required consistent with the purposes set out in this Privacy Notice or for the period of limitation prescribed in the relevant laws.
We keep your personal data for no longer than reasonably necessary: for a period of 6 years from the fulfillment of the contract concluded with us in order to comply with applicable data retention laws.
We store internet search data collected concerning you for four days.
If a court or disciplinary procedure is initiated, then the personal data will be retained until the termination of the proceedings, including the duration of any possible remedy, which data thereafter, in the case of civil claims, will be deleted after the civil law statute of limitation runs.
In the case of consent-based data processing, personal data will be processed until the consent is withdrawn.
5. FURTHER PROCESSING OF PERSONAL DATA
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, we will provide you with a new notice explaining all condition relating to the new processing prior to the new processing takes place. If required, we will seek your consent before commencing the new data processing activity.
6. YOUR PERSONAL DATA PROTECTION RIGHTS
Pursuant to the applicable data protection law you may have the right
- to request access to your personal data,
- to request rectification of your personal data,
- to request erasure of your personal data,
- to request restriction of processing of your personal data,
- to request data portability,
- to object to the processing of your personal data,
- to withdraw your consent, and to lodge a complaint with the supervisory authority.
6.1 Right to access
You may have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data.
6.2. Right to rectification
You may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
6.3. Right to erasure (right to be forgotten)
Under certain circumstances you may have the right to request from us the erasure of your personal data and we may be obliged to erase such personal data. In such cases we will not be able to further provide you with our services.
6.4. Right to restrict processing
Under certain circumstances you may have the right to request from us the restriction of processing your personal data. In this case the respective data will be marked and may only be processed by us for certain purposes.
6.5. Right to object and rights relating to automated decision-making
Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to no longer process your personal data.
Moreover, if your personal data is processed based on our legitimate interest, you have the right to object at any time to the processing of personal data concerning you for such purpose.
6.6. Right to data portability
Under certain circumstances you may have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format (i.e. in digital form) and you may have the right to request the transmission of those data to another entity without hindrance from us, if such transmission is technically feasible.
6.7. Right to withdraw consent
When the processing of your personal data is based on your consent, you can withdraw your consent at any time without giving any reason to us. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
If you withdraw your consent to our processing your personal data, we may not be able to provide all or parts of the services which you have requested.
6.8. Right to lodge a complaint with the supervisory authority
If you feel that your personal data rights have been breached, you can also contact and lodge a complaint with the local data protection authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.
7. HOW DO WE PROTECT YOUR PERSONAL DATA?
SIA ELVIM complies with its obligations under the applicable data protection laws by
- keeping personal data up to date;
- storing and destroying it securely;
- not collecting or retaining excessive amounts of data;
- protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We take appropriate technical and organizational measures to ensure the protection of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular but not limited to where the processing involves the transmission of data over a network, and against all other unlawful forms of processing.
8. SHARING YOUR PERSONAL DATA
SIA ELVIM, in the course of its operation, may utilize the services of various data processors and external service providers to handle and process your personal data for specific purposes, on behalf of and in accordance with the instructions of SIA ELVIM.
The data processors shall process the personal data at the most as long as the term of the data processing contract concluded with them is valid and in force, or until they are required to keep your data under the applicable data retention laws.
We may disclose your personal data to the following categories of third parties (recipients) for the purposes described below:
- third party service providers whose services you purchased on our website or in our application;
- credit card companies, payment service providers to process the payments you initiated on our website, in our application or via our call center;
- third parties running customer surveys on our behalf;
- other third party service providers involved by us for data processing;
- third parties, such as law firms, courts, other bodies or service providers in order to enforce or apply any contract with you;
- government authorities or enforcement bodies such as the police and regulatory authorities, upon their request and only as required by the applicable law or to protect our rights or the safety of our customers, staff and assets.
9. TRANSFERRING YOUR PERSONAL DATA TO THIRD COUNTRIES
The transfer of your personal data outside of the European Economic Area may be necessary in order to provide you with a service that you have requested, and your personal data may be accessed by data processors and service providers from countries that do not provide the same level of data protection as provided in the European Economic Area. Therefore, _[Company]_ will, if necessary, take all measures which in relation to the recipients of your personal data, is necessary to ensure an adequate level of protection as defined by the applicable data protection law, in particular through the application of the Standard Contractual Clauses issued by the European Commission or by a decision of the European Commission which states that the country in which the recipient of the transferred data is provides an adequate level of data protection.
If, in relation to data transfers abroad, an adequate level of protection of personal data cannot be ensured, then we shall request your express consent relating to any such data transfers abroad. Please note that such data transfers may be associated with certain risks particularly that in the country of the data recipient unauthorized third parties may also have unreasonable access to said data and you may not be able to exercise the rights of the data subject and or your right to object against acts that may harm your personal data and your right to privacy.
When you use our website, cookies are stored by your browser on your device. Please note that if you disable cookies our website may not function properly on your browser. Our aim is to ensure that our website offers visitors what they are looking for and provides them with the most relevant marketing communication. In order to achieve this goal, we may store and use your data, building usage profiles for market research, for quality improvements of our website and our services, for service developments, to improve the performance of the website, to measure the success of our advertising campaigns or to tailor services to your needs.
12. THE USE OF YOUR PERSONAL DATA FOR MARKETING PURPOSES
We send you newsletters on actual bargains and special offers if you have requested such communication from us by subscribing to such services, or if you provided us with your details. We will not contact you electronically for marketing purposes unless you have expressly indicated your consent by ticking relevant tick boxes on the data entry form in which you entered your contact information.
13. CHANGES TO OUR PRIVACY NOTICE
If we change this Privacy Notice, we will publish the updated version of it on our website, www.adameva.ee.
14. THIRD PARTY WEBSITES
The www.adameva.ee website provides links to other websites for your convenience and information. Please be aware that these sites may be owned and run by other companies and organizations and have different security and privacy policies. SIA ELVIM has no control over and takes no responsibility for any information, material, products or services contained on or accessible through those websites.
15. THIRD PARTIES LIABILITY
SIA ELVIM is not responsible for third parties’ use of your data, where such use is permitted for their own purposes. In such cases these third parties also be considered data controllers, please consult their privacy policies for further information.