- General provisions
1.1. This privacy policy governs the principles governing the collection, processing and storage of personal data. Personal data is collected, processed and stored by the personal data controller TMA Solutions OÜ (hereinafter data controller).
1.2. For the purposes of the privacy policy, a data subject is a customer or other natural person whose personal data is processed by the data controller.
1.3. For the purposes of the privacy policy, a customer is anyone who purchases goods or services from the data controller’s website or uses the software application.
1.4. The data controller follows the principles of data processing provided by legislation; among other things, the data controller processes personal data legally, fairly and securely. The data controller is able to confirm that personal data has been processed in accordance with the legislation.
- Collection, processing and storage of personal data
2.1. The personal data collected, processed and stored by the data controller is collected electronically, mainly via the website, software application and e-mail.
2.2. By sharing their personal data, the data subject gives the data controller the right to collect, organise, use and manage personal data for the purposes defined in the privacy policy, which the data subject shares directly or indirectly with the data controller when purchasing goods or services on the website or using the software application.
2.3. The data subject is responsible for ensuring that the data provided by them is accurate, correct and complete. Submitting false information intentionally is considered a violation of the privacy policy. The data subject is immediately obliged to inform the data controller of any changes in the submitted data.
2.4. The data controller shall not be liable for any damage caused to the data subject or third parties caused by the submission of false data by the data subject.
- Processing of customers’ personal data
3.1. The data controller may process the following personal data of the data subject:
3.1.1. First name and surname;
3.1.2. Date of birth;
3.1.3. Personal identification code;
3.1.4. Phone number;
3.1.5. E-mail address;
3.1.6. Delivery address;
3.1.7. Bank account;
3.1.8. Payment card details;
3.1.9. Usage data of software application.
3.2. In addition to the above, the data controller has the right to collect data about the customer that is available in public registers.
3.3. The legal basis for the processing of personal data is clauses 6 (1) (a), (b), (c) and (f) of the General Data Protection Regulation (GDPR):
3.3.1. the data subject has consented to the processing of their personal data for one or more specific purposes;
3.3.2. the processing of personal data is necessary for the performance of an agreement to which the data subject is a party or for taking pre-contractual measures as per the request of the data subject;
3.3.3. the processing of personal data is necessary to fulfil the data controller’s legal obligations;
3.3.4. the processing of personal data is necessary in the event of a legitimate interest of the data controller or of a third party, unless such an interest outweighs the interests of the data subject or the fundamental rights and freedoms for which personal data must be protected, in particular where the data subject is a child.
3.4. Processing of personal data according to the purpose of the processing:
3.4.1. Purpose of processing – safety and security
The maximum retention period of personal data – according to the terms prescribed by law
3.4.2. Purpose of processing – order processing
The maximum retention period of personal data – 360 days
3.4.3. Purpose of processing – ensuring the functioning of the services of the online store
The maximum retention period of personal data – 360 days
3.4.4. Purpose of processing – customer management
The maximum retention period of personal data – 360 days
3.4.5. Purpose of processing – financial activities, accounting
The maximum retention period of personal data – according to the terms prescribed by law
3.4.6. Purpose of processing – marketing
The maximum retention period of personal data – 360 days
3.5. The data controller has the right to share the personal data of customers with third parties, such as authorised data controllers, accountants, transport and courier companies, and companies providing transfer services. The data controller is the controller of personal data. The data collector forwards the personal data necessary for making payments to the authorised processor ESTO AS.
3.6. When processing and storing the personal data of the data subject, the data controller shall implement organisational and technical measures to ensure the protection of the personal data against accidental or unlawful destruction, alteration, disclosure and any other unlawful processing.
3.7. The data controller retains the data of data subjects depending on the purpose of the processing, but no longer than 7 years.
- Rights of the data subject
4.1. The data subject has the right to access and inspect their personal data.
4.2. The data subject has the right to receive information about the processing of their personal data.
4.3. The data subject has the right to supplement or correct inaccurate data.
4.4. If the data controller processes the personal data of the data subject on the basis of the data subject’s consent, the data subject has the right to withdraw their consent at any time.
4.5. The data subject can contact the online store customer support at info@celeon.eu to exercise their rights.
4.6. In order to protect their rights, the data subject has the opportunity to submit a complaint to the Data Protection Inspectorate.
- Final provisions
5.1. This privacy policy has been drawn up in accordance with Regulation (EU) No 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR), the Personal Data Protection Act of the Republic of Estonia and other legislation of the Republic of Estonia and the European Union.
5.2. The data controller has the right to partially or completely change the data protection conditions by notifying the data subjects of the changes via the website www.celeon.eu.