- Personal data protection terms have the same meaning as defined here or in the General Data Protection Regulation (2016/679) (“GDPR”).
- Contract means a contract entered into between us and a data subject. Term Contract also covers term Terms and Conditions.
- data subject means a natural person regarding whom we have information or information that can be used to identify a natural person.
- personal data means any information relating to an identified or identifiable natural person i.e., data subject.
- Service(s) means services offered by us, incl. via our Website.
- Visitor is a person visiting our Website.
- Website means our website accessible via https://www.cloudfactory.jewelry/ and all its subdomains.
2. GENERAL INFORMATION AND CONTACT DETAILS
- About Us. We are a private limited company Cloud Factor OÜ with registry no 14309770, address Pärnu mnt 139e/13, Tallinn, Estonia, 11317, email firstname.lastname@example.org. We are a company offering 3D printing solutions of precious metals. We are controllers of personal data of our clients, employees and other data subjects, when offering our Service.
- Contacts. You can contact us in matters related to personal data processing by e-mailing us at email@example.com.
- Lead Supervisory Authority. Our supervisory authority is Estonian Data Protection Inspectorate (address: 39 Tatari St., 10134 Tallinn, telephone +372 627 4135, e-mail firstname.lastname@example.org, web https://www.aki.ee/en/contacts). Data Subjects also have the right to turn to the supervisory authority of their domicile.
3. PRINCIPLES OF PERSONAL DATA PROCESSING
Here you will find the key principles that we are always guided by when processing your personal data.
- Compliance and aim. Our aim is to process personal data in a responsible manner where we are able to demonstrate the compliance of personal data processing with the purposes set and the applicable regulations.
- The principles. All our processes, guidelines, actions, and activities related to personal data processing are based on the following principles: lawfulness, fairness, transparency, purposefulness, minimisation, accuracy, storage limitation, integrity, confidentiality, and data protection by default and by design.
4. Information we process
Here you can find categories of personal data we process.
- Types of data. In general, we process following types of personal data:
- Personal data inserted or given to us by the data subject (e.g., in the contact form on the Website - name, contact information etc.);
- Personal data resulting from standard communication between us and the data subject (e.g., when you contact us by email);
- Personal data resulting from the usage of our Service;
- Personal data obtained from third parties (if any);
- Personal data generated and combined by us (e.g., data about the usage of Service etc.).
- Categories of Data Subjects. Generally, we may process personal data of the following data subjects’:
- our client's (if natural person) and
- our client’s representatives;
- representatives of our cooperation partners;
- our employees or contractors;
- Website Visitors.
- Data we process as Controller. As Controller we process among other the following personal data:
- About Visitors – data gathered from use of Website incl., by Cookies (if enabled);
- Our client’s representatives– name, contacts, communications with us, Service usage data;
- Clients if natural persons – name, email address, phone nr, address, Cookies data, technical data, Service usage data, type of client (e.g., creator, gamer, brand), location data (if enabled), communications with us, information on the interest in our Service.
Contact us if you need more precise information on your personal data processing.
5. GENERAL PURPOSES, GROUNDS FOR, AND ACTIVITIES OF PROCESSING
Here you will find information about the purposes and grounds for processing of your personal data.
- Entry into and performance of a Contract. Upon entering into and performing a Contract, we may process personal data for the following purposes:
- taking steps prior to entering into a Contract, which are necessary for entering into a Contract or which the data subject requests;
- identifying you to the extent necessary for entering into and performing a Contract or taking steps to enable usage of our Service;
- performing the obligations assumed (e.g., billing);
- communicating with you, incl. sending information and reminders about the performance of the Contract or about the usage of the Service;
- protection of rights and claims;
- to detect, prevent and address technical issues;
- to provide customer support;
- to provide and maintain our Service, incl. monitor usage of our Service and Website;
- to notify you about changes to our Service or to give you other Contract/Service related notice.
Please note that exact purpose and grounds may also be defined in the Contract.
Legal obligation. We process personal data to comply with a legal obligation in accordance with and to the extent provided by law.
- Legitimate interest. Our legitimate interest means our interest in managing or directing our activities and enabling us to offer the best possible Service. In case we are using legitimate interest, we have previously assessed our and your interests. You have the right to see conducted assessment connected to processing of your personal data. We may process your personal data (except special categories of personal data) based on legitimate interest for the following purposes:
- managing and analysing a client database and Service (if not covered with the Contract) to improve the availability, functions and quality of Service, e.g., using a CRM or analytics solutions to enable the foregoing;
- development of our Service and Website;
- ensuring a better client experience, to provide higher quality Service; we may monitor the usage of our Service and Website, analyse identifiers and personal data collected when our Website, Service, our social media pages and other sales channels are used, and we may collect statistics about clients and Visitors;
- organizing campaigns, incl. organising personalised and targeted campaigns. The terms and conditions of campaigns are set out separately;
- sending offers/information to the client or potential client if the respective person has previously purchased or shown interest in a similar product, and if such processing is allowed in respective jurisdiction. In this case, the person is always guaranteed to have a simple opportunity to resign from the communication, and we have considered our and the (potential) client’s interests;
- conducting satisfaction surveys and measuring the effectiveness of marketing activities performed;
- making recordings and logging; we may record messages and orders given both in our premises and using means of communication (e-mail, phone etc.) as well as information and other activities we have performed. If necessary, we use these recordings to prove orders or other activities;
- technical and cyber security reasons, for example measures for combating piracy and ensuring the security of the Website as well as for making and storing back-up copies and preventing/repairing technical issues;
- processing for organisational purposes, foremost for management and processing of personal data for internal management purposes (but also audits and other potential supervision), including for processing the personal data of clients or employees, and disclosure of personal data within our group companies (subsidiaries, affiliates);
- establishing, exercising or defending legal claims, incl. assigning claims to, for example, collection service providers, or using legal advisors;
- protecting our health and property and the health and property of our employees and clients’, for example, we may use cameras that may also record sound to ensure safety and security on our territory;
- If you have given us information about not sending you a certain type of information – retaining the information about such prohibition.
- New purpose. Where personal data is processed for a new purpose other than that for which the personal data are originally collected or it is not based on the data subject’s consent, we carefully assess the permissibility of such new processing. We will, in order to ascertain whether processing for a new purpose is compatible with the purpose for which the personal data are initially collected, take into account, inter alia:
- any link between the purposes for which the personal data are collected and the purposes of the intended further processing;
- the context in which the personal data are collected, in particular regarding the relationship between the data subject and us;
- the nature of the personal data, in particular whether special categories of personal data are processed or whether personal data related to criminal convictions and offences are processed;
- the possible consequences of the intended further processing for data subjects;
- the existence of appropriate safeguards, which may include encryption or pseudonymisation.
6. TRANSFER AND AUTHORISED PROCESSING OF PERSONAL DATA
Here you will find information about the transfer and authorised processing of personal data.
- Usage of Cooperation Partners. We cooperate with persons to whom we may transmit data, including personal data, concerning the data subjects within the context and for the purpose of that cooperation. We may have different type of controller-processor-sub-processor relationships with those cooperation partners. When transferring personal data to third parties (generally our cooperation partners), we comply with the applicable data protection requirements.
- Requirements for the Usage of Processors. Such third parties may include, among other, advertising and marketing partners, payment service providers, customer satisfaction survey companies, advisers, logistics partners, IT partners, i.e., service providers for various technical services, provided that:
- the respective purpose and processing are lawful;
- personal data is processed pursuant to the instructions of the controller and on the basis of a valid contract.
- Other transfers. In other cases, we transmit your personal data to third parties provided that we have your consent, a legal obligation, or there is an exception in the event that the transfer is necessary to protect your vital interests.
- Other disclosures. We may disclose personal data also on the fallowing cases:
- For Law Enforcement. Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities. We always assess the lawfulness of information requests before disclosing any personal data.
- For business transactions. If we or our subsidiaries are involved in a merger, acquisition or asset sale, your personal data may be transferred.
7. STORAGE AND SECURITY OF PROCESSING PERSONAL DATA
Here you will find a description of how we protect your personal data and for how long we store personal data.
- Storage. When storing personal data, we comply with the purpose of processing, limitation periods for potential claims in the event of filing claims, and storage periods provided for in the law. We store personal data as long as need depending on the purpose of the processing. Client personal data is generally retained, for the duration of the period of validity of the Contract + 3 years for possible defence of claims. Certain personal data is stored depending on the requirement deriving from applicable law e.g., 7 years accounting data, 10 years data of employment contracts. Personal data for which the storage period has expired are destroyed or made anonymous.
- Security measures. We have established guidelines and rules of procedure on how to ensure the security of personal data through the use of both organisational and technical measures. Among others, we do the following to ensure security and confidentiality:
- We have access-level management system in use;
- we use software solutions that help ensure a level of security that meets the market standard.
The security of your data is important to us and we take all reasonable steps to ensure the security of personal data.
- Incident. In the event of any incident involving personal data, we do our best to mitigate the consequences and alleviate the relevant risks in the future. We will follow notice requirements of the GDPR.
8. GDPR Data Protection Rights
Here you can read about your rights in connection to your personal data. These rights are applicable if you are a resident of EEA.
- We would like to make sure you are fully aware of all of your data protection rights. Every data subject is entitled to the following rights (under certain preconditions):
- The right to access and a copy – you have the right to access and to request copy of your personal data.
- The right to rectification – you have the right to request that we correct any information that is inaccurate.
- The right to erasure – you have the right to request that we erase your personal data, under certain conditions e.g., processing is done only under consent.
- The right to restrict processing – you have the right to request that we restrict the processing of your personal data, under certain conditions.
- The right to object to processing – you have the right to object to our processing of your personal data, under certain conditions.
- Rights related to automated processing and profiling – you have on grounds relating to your particular situation, the right to object at any time to the processing of personal data concerning you based on automated decisions/profiling and to require human intervention. You may also require an explanation regarding the logic of making an automated decision. Automated processing/profiling may also be partially based on data collected from public sources. For avoidance of doubt, we do not use automated processing or profiling that has a significant effect on the you or your rights.
- The right to data portability – you have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
- The right to file a complaint – you have the right to file a complaint with us or supervisory authority or court if you think that your rights in connection to personal data have been infringed. We kindly ask you to contact us first for finding a solution. If needed our data protection supervisory authority is Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) contacts can be found: https://www.aki.ee/en/contacts.
- Responses and additional information. If you make a request, we have one month to respond to you. If you would like to exercise any of these rights or need more information on your rights, please contact us. Please note, that we may need to identify you before granting you any of the rights connected to your personal data.
8. Children's Information
- We do not knowingly collect any personal data from children under the age of 16. If we find out that we have obtained data of children, we will delete such data immediately or seek approval from legal guardian or parent. In case where we are a processor all grounds for processing derive from our client.
- Publication: 05.01.2023
- Entry into force: 05.01.2023
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