PRIVACY NOTICE

Personal data are information that can be used to directly or indirectly identify you as a private individual (“Personal Data”). The source of the collected Personal Data depends on how you interact with us. We may obtain and process the following categories of Personal Data:

• Main data: first name, last name, e-mail address, phone number, authentication and profile data received from third parties (e.g., Google LLC) according to your instructions and choices if you register or log in using such third parties (“Main Data”).
• Source: Personal Data you directly provide to us, is provided to us by the legal entity you work for or represent or is provided to us by third parties according to your instructions and choices.
• For concluding and managing contractual relationships with you or the legal entity you work for or represent, we may process the following Personal Data: Main Data, billing information, industry you work at, legal entity’s name you work for or represent, registry code and your job title (“Contract Data”).
• Source: Personal Data you directly provide to us, is provided to us by the legal entity you work for or represent or is provided by payment service provider.
• If you interact with us via the Website, live chat, social media platforms or e-mails, we may process the following Personal Data: Main Data, Contract Data, your username of the platform through which you interact with us, date and time of the message, contents of your message. („Communication Data“).
• Source: Personal Data you directly or a third party provides to us.
• Marketing data: Main Data, position. Additionally, we may supplement the Personal Data that you have provided to us directly with information that has been obtained from publicly available resources (i.e. LinkedIn, e-mail search, country specific commercial registrars) (“Marketing Data”).
• Source: Information you directly provide to us and the information we have obtained from publicly available resources.
• When you use the Service, we may process the following data, which may include your Personal Data: user ID, user role, action made in product, attributes to that action, error logs (“Usage Data”).
• Source: While you are using the Service, the product infrastructure itself generates or automatically collects the Usage Data.
• Upon visiting the Website, our server may process the following data: IP address, access-provider, general location, referring and exit URL, date, time, language settings used, access tokens, session key, browser type and version, operating system, your navigation on the Website, amount and state of transferred data (“Technical Data”).
• Source: While you are browsing through the Website, the Website itself generates or collects the Technical Data from your device automatically.
• Cookie data. We implement cookies on the Website, for optimising the Website and its functionalities. The cookies may collect your Personal Data. For further information on the purposes and functions of the cookies, please see our cookie notice.

If you do not provide the required information, we may not be able to contact you, provide our Services or fulfil any other purposes provided in Section 4 of this Notice.

We will store your Personal Data as long as reasonably necessary to attain the objectives stated in Section 4 of this Notice, or until the legal obligation stipulates that we do so. 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 processing purposes and whether we can achieve these purposes through other means, and applicable statutory obligations. Whilst retaining the Personal Data, we take into account the need to resolve disputes and enforce the contract between us or anonymize your Personal Data and retain this anonymized information indefinitely.

• Main Data and Contract Data relating to transactions will be stored for seven years from the end of the financial year they relate to. Other Main Data and Contract Data will be stored up to 3,5 years after the deletion of the client’s account.
• In case the legal basis for processing your Personal Data is consent and you decide to withdraw the consent, we will stop processing Personal Data for the previously communicated purpose, however, we will retain a note regarding your withdrawal for the purposes of administering your decision and our data processing activities at least for a period of 3,5 years.

You may, at any time, exercise the following rights with respect to our processing of your Personal Data:

• Right to access: you have the right to request access to any data that can be considered your Personal Data. This includes the right to be informed on whether we process your Personal Data, what Personal Data categories are being processed by us, and the purpose of our data processing;
• Right to rectification: you have the right to request that we correct any of your Personal Data if you believe that we are processing inaccurate or incomplete Personal Data;
• Right to object: you are entitled to object to certain processing of Personal Data, including for example, the processing of your Personal Data for marketing purposes or when we otherwise base our processing of your Personal Data on our legitimate interest;
• Right to restrict Personal Data processing: you have the right to request that we restrict the processing of your Personal Data if: (i) you wish to dispute the accuracy of certain Personal Data we are processing, such right applies until we have had the opportunity to satisfy ourselves of the accuracy of the Personal Data; (ii) we have been processing your Personal Data unlawfully, but you only request the restriction of the use of the Personal Data in question instead of its deletion; (iii) we no longer need the Personal Data for the original purposes of processing, but you still need such Personal Data to assert, exercise or defend against legal claims; (iv) you have objected to our processing of certain of items of your Personal Data until a determination is made whether or not your concerns are outweighed by our legitimate interests in processing your Personal Data;
• Right to erasure: you may request your Personal Data to be erased if the Personal Data is no longer necessary for the purposes for which it was collected, or if you consider that the processing is unlawful, or if you consider that the Personal Data has to be erased to enable us to comply with a legal requirement;
• Right to data portability: if your Personal Data is being automatically processed with your consent or on the basis of a mutual contractual relationship, you may request that we provide you that Personal Data in a structured, commonly used and machine-readable format. Moreover, you may request that the Personal Data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible;
• Right to withdraw your consent: in cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time;
• Right to contact the supervisory authority: if you are not satisfied with our response to your request in relation to Personal Data processing or you believe we are processing your Personal Data not in accordance with the law, you can submit your claim to the data protection authority, in Estonia to a Estonian Data Protection Inspectorate (in Estonian Andmekaitse Inspektsioon) at info@aki.ee (https://www.aki.ee/).

We have taken necessary technical and organizational security measures to protect your Personal Data. These measures vary based on the sensitivity of the personal information we collect, process and store and the current state of technology. We have implemented comprehensive technical and organizational security measures to protect your Personal Data. These measures include:

Data Protection Policy

Data Access

• Access Control: Only authorized personnel have access to personal data based on their job responsibilities. Access is granted using role-based access controls (RBAC) and is reviewed regularly.
• Authentication: Strong authentication mechanisms, including multi-factor authentication (MFA), are implemented to verify user identities before granting access to personal data.

Data Protection

• Data Minimization: We collect and process only the data necessary for specific purposes.
• Anonymization and Pseudonymization: We use techniques to anonymize or pseudonymize data where appropriate to enhance privacy and security.

Data Encryption

• Encryption in Transit: Personal data is encrypted during transmission using secure protocols such as TLS.
• Encryption at Rest: Personal data is encrypted when stored on our servers using industry-standard encryption algorithms.

Data Backup

• Regular Backups: We perform regular backups of all critical data, including personal data, to secure and geographically distributed locations.
• Backup Testing: We regularly test backup procedures to ensure data can be restored promptly in case of data loss.

Data Storage

• Secure Storage: Personal data is stored in secure environments with robust physical and logical security measures.
• Data Retention: Personal data is retained only as long as necessary for the purposes for which it was collected, in accordance with our data retention policy.

External Access to Data

• Third-Party Processors: We ensure third-party processors comply with GDPR and other relevant data protection regulations through comprehensive due diligence and data processing agreements.
• Data Transfers: We implement appropriate safeguards, such as Standard Contractual Clauses (SCCs) or Binding Corporate Rules (BCRs), for transferring personal data outside the EU.

GDPR Compliance

• Data Protection Impact Assessments (DPIAs): We conduct DPIAs for processing activities that pose high risks to data subjects' rights and freedoms.
• Data Protection by Design and by Default: We incorporate data protection principles into the design of new systems and processes.

Incidents Management Process

• Data Breach Response: We have an incident response plan to address data breaches promptly, including containment, eradication, and recovery.
• Vulnerability Management: We regularly scan for and address security vulnerabilities in our systems and applications.
• Threat Monitoring: We continuously monitor for external threats using advanced security tools and threat intelligence services.
• Unauthorized Access Prevention: We use intrusion detection and prevention systems (IDPS) to detect and prevent unauthorized access to our systems and data.
• Data Theft Prevention: We implement robust security controls, such as encryption, access controls, and monitoring, to prevent data theft.
• Network Security: We implement firewalls, intrusion detection systems (IDS), and intrusion prevention systems (IPS) to protect our network from intrusions.
• Physical Security: We implement physical security measures, such as access controls, surveillance, and security personnel, to protect our facilities.

Physical Security

• Access Control: We use access control systems to restrict entry to our facilities to authorized personnel only.
• Surveillance: We have installed surveillance cameras in key areas to monitor and record activities.
• Security Personnel: We employ security personnel to oversee physical security measures.

Network Security

• Firewalls: We deploy firewalls to protect our network from unauthorized access and external threats.
• IDS/IPS: We implement intrusion detection and prevention systems to monitor and respond to potential security incidents.
• Secure Configurations: We ensure all network devices are securely configured and regularly updated to protect against vulnerabilities.
• VPNs: We use Virtual Private Networks (VPNs) to secure remote access to our network.

Where we provide links to websites of third parties, this Notice does not apply to data processing conducted by such third parties. The content and links displayed on such websites are outside of our control, and we are not responsible for the practices of websites linked from our own Website (or linking to our Website). To find out more about how third parties process your personal data, please refer to the respective privacy notices of the other websites you visit.

This Notice may be amended or modified from time to time to reflect changes in the way we process Personal Data, and in such case, the most recent version of the Notice will be published on this page. Please check