PARTIES INVOLVED IN PROCESSING OF PERSONAL DATA
Controller of personal data
The “controller” (the party liable for processing) of personal data means a legal person, who determines the purposes and methods for the processing of personal data.
Controller: SOL Baltics OÜ
Registry code of the company: 10419987
Address: Telliskivi 61b, 10412 Tallinn
Contacts: +372 6 771 551, firstname.lastname@example.org
Processors of personal data
During the provision of services, SOL can process your personal data in connection with third parties, and to transfer your personal data to them (for example, when providing the delivery service). The “processor” (the party authorised to process) of personal data can be a natural or legal person, public authority, an institution or any other entity, who processes personal data on behalf of the holder of data (SOL). SOL does not disclose personal data to third parties unless the disclosure obligation arises from law, is necessary for performance of a contract or has been permitted by the relevant person.
CUSTOMER LOYALTY PROGRAM
The personal data of loyal customers participating in the customer loyalty program are gathered into a loyal customer register and are processed by SOL for the purposes of identifying a loyal customer on the basis of an ID-card and offering services targeted at loyal customers for favorable conditions.
Data processed in the loyal customer register consist of personal data gathered on the basis of the subscription form for customer loyalty program, or data added or amended by customers at a later point. Purchases made by loyal customers are also recorded in the loyal customer register, to enable more accurate direct marketing. Purchases are registered with the registration of the ID-card when making the purchase.
PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA
- Transparency – SOL processes your personal data in a fair and transparent manner and only when processing of your personal data is permitted by law.
- Purpose limitation – SOL collects your personal data for specified, explicit and legitimate purposes. We do not process your personal data in a manner that is not compatible with the initial purpose, unless it is based on legal grounds arising from law or your consent.
- Gathering of minimum data – SOL will do its utmost to ensure that the personal data processed by SOL are sufficient, relevant and minimum what is required for the purpose of the data processing.
- Accuracy – our goal in SOL is to ensure that your personal data are accurate and relevant as needed. We will make every effort to ensure that inaccurate personal data are deleted or amended immediately.
- Storage limitation – SOL stores your personal data in a format which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. SOL processes and stores personal data only as long as required according to applicable laws, binding contracts or binding legal obligations.
- Reliability – SOL processes your personal data in a manner which ensures required security, including protection against unauthorized or unlawful processing.
- Data protection by design and by default – SOL develops, selects and uses applications, services and products which are based on the processing of personal data or process personal data, taking into account the need for protection of personal data.
SOL keeps all the personal data disclosed to it confidential and protects customers’ personal data against unlawful disclosure to third parties by means of efficient security measures, including IT, technical and organisational measures.
RIGHTS OF A DATA SUBJECT
- You have the right to request from SOL access to your personal data processed by SOL.
- If you notice that your personal data are out of date, incorrect or need correction, you can turn to SOL for correction or supplementation of your data.
- You have the right to contact SOL and request deletion of your data. SOL will delete your data, except in cases where SOL has legal grounds for further processing of the personal data.
- You have the right to prohibit SOL from processing your personal data. As a result, SOL may only be permitted to store the existing personal data, but no longer to process these any further.
- You have the right to request SOL to transfer your personal data to another administrator of personal data, if this is technically possible.
- You have the right to object to the processing of your personal data at any time. In such case SOL will stop processing your personal data, unless there are overriding legitimate reasons for the processing.
- If you suspect that the requirements of legislation have not been followed in the processing of your personal data, you have the right to make a complaint about the processing of your personal data to the data protection supervision authority, which in Estonia is the Data Protection Inspectorate.
- If the processing of personal data is based on your consent, you have the right to withdraw your consent at any time by sending such notice to SOL.
You can exercise your rights by contacting SOL by e-mail email@example.com.
PURPOSES OF PROCESSING PERSONAL DATA
SOL processes personal data for the following purposes:
- Sales activities and related additional services;
- Marketing, direct marketing of loyal customer discounts and for campaigns;
- Data analysis for marketing purposes;
- Settlement of invoices and relevant correspondence with customers.
CATEGORIES OF PROCESSED PERSONAL DATA
SOL processes the following data of data subjects:
- first name and surname;
- telephone number, e-mail and address (the latter in case of the delivery service);
- data about customer’s purchases;
- other data required for performance of contract or provision of service or which have been voluntarily disclosed by the customer to SOL.
LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
SOL processes personal data on the following legal grounds.
SOL processes your personal data, if the processing is necessary for the execution of a contract. For example for providing a service offered to you.
For the purposes of sending loyal customer and campaign offers, SOL processes your personal data on the basis of your consent.
In connection with services in an information society, the data protection rules and conditions applicable to the consent of a child are stricter. If the child is 16 years old or below the age specified in the applicable law, the processing is deemed legal only in case the consent has been given by a parent or a person with parental responsibility over the child.
PROFILING AND MARKETING
Profiling means that SOL conducts automated processing of personal data in any form, which includes using personal data to assess certain personal aspects related to the data subject. For example, for the purposes of marketing and sales, SOL could conduct profiling in order to analyse the consumption patterns of customers. Based on the results of profiling SOL makes targeted service offers to customers. SOL can use various profiling methods. For example, in making offers SOL distinguishes between the recipients based on age (to make an offer that is the most suitable for a specific age group) or previous purchases (to send offers to customers based on the most frequently purchased services).
When personal data are processed for direct marketing purposes, data subjects can “cancel” the use of their personal data for such purposes and to use their right to object the use of their personal data for direct marketing. For example, if SOL sends you newsletters or SMSs with various offers and you no longer wish to receive these, then you can always unsubscribe from such offers by informing SOL. After unsubscribing from offers, customers can later express their will to receive the offers again.