1.2 RADVARK DEVELOPMENT OÜ is a limited liability company incorporated under the laws of the Republic of Estonia with the registration number 16589265. The legal address (“Registered Office”) of PROM is Maakri tn 30, Tallinn, 10145, Estonia.
2.1 The provisions herein constitute the regulatory framework of the collection, usage, control, and retention of personal information about users (“You”) of the Platform.
To review, correct, update, or delete inaccuracies regarding the information about You that PROM stores, please contact PROM directly at email@example.com. PROM will address Your request within seventy-two hours. Data protection law gives you a range of rights in connection with the processing of your personal data:
4.1 You have the right to request that PROM rectifies or deletes the personal data or restricts the processing of your personal data if you think they are inaccurate.
4.2 You have the right to object against the processing based on PROM's legitimate interests as a legal basis. PROM is required to assess and act on your request. Additionally, you also have the right to data portability if applicable.
4.3 You have the right to lodge a complaint with your local supervisory authority or the European Data Protection Supervisor (see section 5).
In compliance with Regulation 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons, PROM commits to resolve complaints about Your privacy and the collection or use of Your personal information. Users with questions or concerns about the use of their personal data should contact PROM at: firstname.lastname@example.org. If Your question or concern cannot be satisfied through this process, PROM has further committed to refer unresolved privacy complaints to the European Data Protection Supervisor (“EDPS”), an independent dispute resolution authority in the European Union. If you do not receive timely acknowledgement of your complaint or if your complaint is not satisfactorily addressed by PROM, users should visit https://edps.europa.eu/data-protection/our-rolesupervisor/complaints_en for more information or to file a complaint.
PROM collects Non-personally Identifiable Information (“Non-PII”) about users of the Platform. This information may be used for analyzing trends, administering the Platform, saving user settings, authentication, tracking user behavior around the Platform and gathering general demographic information about the userbase. For more general information or instructions on how to opt-out, please contact the Data Protection Officer at email@example.com.
Upon registration on the Platform, PROM may, in addition to the information collected about visitors, also collect Personally Identifiable Information (“PII”) about You:
PROM does not collect any Special Categories of Personal Data about You (this includes details about Your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about Your health, and genetic and biometric data, data on criminal convictions and offenses.
PROM does not knowingly collect or solicit personal information from anyone under the age of 13. In the event that PROM gets to know about the collection of personal information from a child under age 13, PROM will delete that information as quickly as possible. If You believe that PROM might have any information from or about a child under 13, please send an email to firstname.lastname@example.org.
It is important that the personal data PROM holds about You is accurate and current. Please keep PROM informed if Your personal data changes or if You become aware that any personal data that PROM holds about You is not accurate.
Where PROM needs to collect personal data by law, or under the terms of a contract PROM has with You, and You fail to provide that data when requested, PROM may not be able to perform the contract (for example, to provide You with services). In this case, PROM may have to cancel a product or service provided to You. In that event, PROM will notify You at the time.
PROM may use each or any of the following methods to collect each or any of the data specified in section 6 from and about You:
You may provide PROM with Your Identity Data, Verification Data, and Contact Data by filling in forms or by corresponding with PROM by post, phone, email, or other means of communication. This includes personal data You provide when You:
As You interact with the Platform, PROM will automatically collect Technical Data about Your equipment, browsing actions and patterns. PROM collects this data by using cookies, server logs and other similar technologies. PROM may also receive Technical Data about You if You visit other websites employing cookies by PROM.
7.2.2 A cookie is a small file of letters and numbers that is stored on Your browser or the hard drive of Your computer if You agree. Cookies contain information that is transferred to Your computer`s hard drive.
7.2.3 You can block cookies by activating the setting on Your browser that allows You to refuse the setting of all or some cookies. However, if You use Your browser settings to block all cookies (including essential cookies) You may not be able to access all or parts of the Platform.
7.2.4 Most of the cookies we use on our website are 'persistent' cookies. This means that they remain on Your device until You erase them, or they expire. The rest of these cookies are 'session' based which are more temporary in duration. This means they will be erased when You close Your internet browser.
7.2.5 PROM uses the following cookies:
7.2.6 Below you can find a list of the individual cookies used and the purposes for which PROM uses them:
|Avax||This cookie, set by Cloudflare, is used to support Cloudflare Bot Management.|
|Github||Github is a distributed version-control platform where users can collaborate on or adoptopen source code projects, fork code, share ideas and more|
7.2.8 If You are unclear about the types of functions of cookies used on the Platform, please contact PROM at email@example.com
PROM may receive personal data about You from various third parties and public sources as set out below:
PROM uses the collected information to operate and maintain the Platform, to interact with its users and to ensure compliance with Know Your Customer (KYC) regulations. The lawful basis for this use of personal data is art. 6(1)(f) of the EU General Data Protection Regulation (GDPR).
Most commonly, PROM will use Your personal data in the following circumstances:
Generally, PROM does not rely on consent as a legal basis for processing Your personal data although PROM will get Your consent before 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 PROM at firstname.lastname@example.org.
A description of all the ways PROM may use Your personal data including their legal bases is set out below. PROM may process Your personal data for more than one lawful ground depending on the specific purpose which Your data are used for. In case You require further details about the specific lawful basis on which PROM is relying in order to process Your personal data where more than one lawful basis has been set out in the table below, please contact PROM at email@example.com.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register You as a new customer|
|To manage PROM's relationship with You which will include:|
|To enable You to partake in a prize draw, competition or complete a survey|
|To administer and protect PROM's business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|
|To deliver relevant website content and advertisements to You and measure or understand the effectiveness of the advertising served to You||Necessary for PROM's legitimate interests (to study how customers use the products/services, to develop them, to grow the business and to adjust the marketing strategy)|
|To use data analytics to improve PROM's website, products/services, marketing, customer relationships and experiences||Necessary for PROM's legitimate interests (to define types of customers for products and services, to keep the website updated and relevant, to develop the business and to adjust the marketing strategy)|
|To make suggestions and recommendations to You about goods or services that may be of interest to You||Necessary for PROM's legitimate interests (to develop products/services and grow the business)|
If you have given your consent, PROM may use the collected information to send you marketing communications, including but not limited to general newsletters and individual service offers. The lawful basis for this use of personal data is art. 6(1)(a) of GDPR. If you no longer wish to receive these Emails, you may opt out of them at any point.
PROM may use Your Identity, Contact, Technical, Usage and Profile Data to form a view on what You may want or need, or what may be of interest to You. This is how PROM decides which products, services, and offers may be relevant for You.
You will receive marketing communications from PROM if You have requested information from PROM or purchased goods or services from PROM and You have not opted out of receiving promotional offers.
PROM will get Your express opt-in consent before sharing Your personal data with any third party for marketing purposes.
You can ask PROM or third parties to stop sending You marketing messages at any time by following the opt-out links on any marketing message or by contacting PROM at any time. Where You opt out of receiving these marketing messages, this will not apply to personal data provided to PROM as a result of a product/service purchase, or other transactions.
PROM will only use Your personal data for the purposes for which they were collected, unless PROM reasonably considers that there is a need to use it for another reason and that this 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 PROM at firstname.lastname@example.org. If PROM needs to use Your personal data for an unrelated purpose, PROM will notify You and explain the lawful basis which allows PROM to do so.
PROM may disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if PROM reasonably believes that such action is necessary to comply with the law and the reasonable requests of law enforcement, to enforce the Terms of Service or to protect the security or integrity of the Platform and to exercise or protect the rights, property, or personal safety of PROM, its users or others.
PROM may share Personally Identifiable Information about You with the parties set out in this policy for the purposes set out in section 8.1. PROM may also share “non-PII”, including but not limited to general anonymous usage data, referring/exit pages, visited URLs, used platform types and number of clicks with third parties to provide them with data about usage patterns for certain services. Such non-PII may be stored indefinitely.
PROM may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as usernames and Email addresses, and other user information related to the Platform may be among the items sold or otherwise transferred in these types of transactions. PROM may also sell, assign, or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified by Email of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
PROM requires all third parties to respect the security of Your personal data and to treat it in accordance with the law. PROM does not allow its third-party service providers to use Your personal data for their own purposes and only permit them to process Your personal data for specified purposes and in accordance with the regulations and guidelines set forth by PROM.
Your personal data may be stored and processed in Estonia and any other country in which PROM or its subsidiaries, affiliates or service providers maintain facilities. PROM may transfer collected information, including but not limited to Personally Identifiable Information to affiliated entities or to other third parties across borders and in-between countries or jurisdictions worldwide. If Your personal data get transferred outside of Estonia, PROM will make sure that it is protected to the same extent as it is in Estonia. PROM will use one of these legal safeguards:
PROM ensures highest standards of data protection technologies and methods to be applied at all stages of collecting, processing, and storing your personal data. The Platform is protected by the Secure Sockets Layer (SSL) protocol which encrypts any personal information you enter into registration/login forms before it is sent from your computer to the Platform while all user data are stored on the PROM servers using the latest encryption technologies.
In addition, PROM limits access to Your personal data to those employees, agents, contractors and other third parties necessary. They will only process Your personal data as instructed by PROM and they are subject to a duty of confidentiality.
Notwithstanding the aforesaid PROM cannot ensure or warrant the security of any information you transmit to PROM or guarantee that your information on the Platform may not be accessed, disclosed, altered, or destroyed by breach of any of PROM's industry standard physical, technical, or managerial safeguards.
In the event that personal information is compromised as a breach of security, PROM will promptly notify You in compliance with the applicable law.
If you have any questions about security on the Platform, please contact PROM at email@example.com.
For the purpose of maintenance and administration of a business relationship with the User, correspondence with the User, assessment of the User's needs, consultation, Prom will store information for the period of our continuing business relationship and later on for 5 years from the date of termination of our business relationship.
This time limit may be additionally extended if a competent authority conducts an investigation and the further data processing is necessary to execute it or if the Platform feels necessary to maintain data longer, especially, due to the nature of its business or business relationship.
In some circumstances You can ask PROM to delete Your data (see section 13).
In some circumstances PROM will anonymize Your personal data (so that it can no longer be associated with You) for research or statistical purposes, in which case PROM may use this information indefinitely without further notice to You.
Under certain circumstances, You have rights under data protection laws in relation to Your personal data:
To exercise any of these rights or if you have any questions about your rights under data protection law, please contact the PROM Data Protection Officer (DPO): Attn. Data Protection Officer, RADVARK DEVELOPMENT OÜ, Maakri tn 30, Tallinn, 10145, Estonia, Email: firstname.lastname@example.org.
PROM may need to request specific information from You to help confirming 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. PROM may also contact You to ask You for further information in relation to Your request to speed up our response.
You will not have to pay a fee to access Your personal data (or to exercise any of the other rights). However, PROM may charge a reasonable fee if Your request is clearly unfounded, repetitive, or excessive. Alternatively, PROM may refuse to comply with Your request in these circumstances.
PROM will try to respond to all legitimate requests within one month. Occasionally it could take longer than a month if Your request is particularly complex or if You have made a number of requests. In this case, PROM will notify You and keep You updated.
Legitimate Interest means the interest of PROM in conducting and managing its business to provide You with the best and the most secure services/products and customer experience. PROM considers and balances any potential impact on You (both positive and negative) and Your rights before processing Your personal data for the legitimate interests of PROM. Your personal data will not be used for activities where the interests of PROM are overridden by the impact on You (unless PROM has Your written consent or is otherwise required or permitted to by law). You can obtain further information about how PROM is assessing its legitimate interests against any potential impact on You in respect of specific activities by contacting PROM at email@example.com.
Performance of Contract means processing Your data where it is necessary for the performance of a contract to which You are a party or to take steps at Your request before entering into such a contract.
Compliance with a legal obligation means processing Your personal data where it is necessary for compliance with a legal obligation that PROM is subject to.
You have the right to:
Request access to Your personal data (commonly known as a "data subject access request"). This enables You to receive a copy of the personal data PROM holds about You and to check that PROM is lawfully processing it.
Request correction of the personal data that PROM holds about you. That enables You to have any incomplete or inaccurate data corrected, though PROM may need to verify the accuracy of the new data You provide to PROM.
Request erasure of Your personal data. This enables You to ask PROM to delete or remove personal data where there are no grounds for PROM continuing to process it. You also have the right to ask PROM to delete or remove Your personal data where You have successfully exercised Your right to object to processing (see below), where PROM may have processed Your information unlawfully or where PROM is required to erase Your personal data to comply with local legislation. PROM is not obliged to comply with Your request of erasure in case of opposing legal regulations, which will be notified to You, if applicable, at the time of Your request.
Object to processing of Your personal data where PROM is relying on a legitimate interest (or those of a third party) and there is something about Your particular situation which makes You want to object to processing on this basis as You have reasonable grounds to assume it impacts Your fundamental rights and freedoms. You also have the right to object where PROM is processing Your personal data for direct marketing purposes. In some cases, PROM may demonstrate evidence of compelling legitimate grounds to process Your information which override Your rights and freedoms.
Request restriction of processing of Your personal data. This enables You to ask PROM to suspend the processing of Your personal data in the following cases:
Request the transfer of Your personal data to You or to a third party. Upon your request, PROM will provide to You, or a third party You have chosen, Your personal data in a structured, commonly used, machine-readable format. This right applies only to automated information which You initially provided consent for PROM to use or where PROM used the information to perform a contract with You.
Withdraw consent at any time where we are relying on consent to process Your personal data. The use of this right will not affect the lawfulness of any processing carried out before the withdrawal of Your consent. If You withdraw Your consent, PROM may not be able to provide certain products or services to You. PROM will advise You if this is the case at the time of Your withdrawal of consent.
RADVARK DEVELOPMENT OÜ
Effective Date: 11th of November 2022