1. Introduction

1.1 We are committed to safeguarding the privacy of [our website visitors, service users, individual customers and customer personnel].

1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can [specify whether you would like to receive direct marketing communications and limit the collection, sharing and publication of your personal data].

1.4 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and API services , we will ask you to consent to our use of cookies when you first visit our website. You can review our cookie policy

1.5 In this policy, "we", "us" and "our" refer to DIGICATECH OÜ.[ For more information about us, see Section 14.]

2. Credit

2.1 This document was created using a template from Docular ( https://seqlegal.com/free-legal-documents/privacy-policy).

3. The personal data that we collect

3.1 In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

3.2 We may process data enabling us to get in touch with you "contact data". The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.

3.3 We may process your website user account data ("account data").The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.

3.4 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website] ("transaction data"). The transaction data may include your name, your contact details, your payment details and the transaction details. The source of the transaction data is you and/or our payment services provider.

3.5 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

3.6 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.

4. Purposes of processing and legal bases

4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.

4.2 Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

4.3 Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.

4.4 Direct marketing - We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent OR our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.

4.5 Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is consent OR our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

4.6 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

4.7 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

4.8 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

4.9 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

5. Providing your personal data to others

5.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

5.2 Your personal data held in our website database OR will be stored on the servers of our hosting services providers identified at https://www.arubacloud.com/gdpr-data-protection-eu-regulation.aspx and/or https://contabo.com/en/legal/privacy/.

5.3 Financial transactions relating to our website and services handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://stripe.com/privacy ,https://www.paypal.com/myaccount/privacy/privacyhub, .

5.4 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6. International transfers of your personal data

6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under EU data protection law.

6.2 We may transfer your personal data from the European Economic Area (EEA) to the UK or USA and process that personal data in the UK or USA for the purposes set out in this policy and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.

6.3 The hosting facilities for our website are situated in Germany and Italy. The competent data protection authorities have made an adequacy determination with respect to [the data protection laws of each of these countries].][ Transfers to [each of these countries] will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which you can obtain from [source]] OR [[specify appropriate safeguards and means to obtain a copy]].]

6.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use or misuse of such personal data by others.

7. Retaining and deleting personal data

7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.3 We will retain your personal data as follows:

(a) contact data will be retained for a minimum period of 1 years following the date of the most recent contact between you and us, and for a maximum period of 1 years following that date;
(b) account data will be retained for a minimum period of 1 years following the date of closure of the relevant account, and for a maximum period of 1 years following that date;
(c) transaction data will be retained for a minimum period of 1 years following the date of the transaction, and for a maximum period of 1 years following that date];
(d) communication data will be retained for a minimum period of 1 years following the date of the communication in question, and for a maximum period of 1 years following that date;
(e) usage data will be retained for 6 months following the date of collection; and
(f) [[data category] will be retained for a minimum period of [period] following [date], and for a maximum period of [period] following [date]].
[additional list items]

7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8. Your rights

8.1 In this Section 8, we have listed the rights that you have under data protection law.

8.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting [https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/].

8.4 You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].

9. How long will my data be kept?

9.1 We will delete your personal data as soon, as we no longer have a need or a legal basis to process it.We’ll always delete your data when we receive a request from you to do so. Please take a look here, to learn how to make such a request. In the unlikely event that we are still obliged under the law to keep your data, we’ll inform you about that.We will not store or otherwise process your data for “unlimited period” in other cases. If we rely on legitimate interest for processing, your data will be kept as long as we are in a business relationship with you. If we don't start a business relationship with you, your data will be stored in our systems for some limited time for our analytics to be done. In no case we will keep it for more than 1 year, the period which is necessary for communicating with your company as our potential client and after which we treat old analytics outdated, so your personal data is not needed anymore.Don’t forget that you may always command us to delete all the information have about you as described here.

10. About Cookies that we use

10.1 Please check our Cookie Policy

13. Amendments

13.1 We may update this policy from time to time by publishing a new version on our website.

13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

13.3 We will notify you of changes to this policy by email.

14. Our details

14.1 This website is owned and operated by DIGICATECH OÜ.

14.2 We are registered in Estonia under registration number 14695939, and our registered office is at Harju maakond Kuusalu vald Pudisoo küla, Männimäe, 74626 Estonia.

14.3 Our principal place of business is at Harju maakond Kuusalu vald Pudisoo küla, Männimäe, 74626 Estonia.

14.4 You can contact us:

(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using [email protected]

15. Representatives

15.1 Our representative within the EU with respect to our obligations under data protection law is Digicatech OÜ and you can contact our representative by email: [email protected] phone: 372 6027422.

15.2 Our representative within the UK with respect to our obligations under data protection law is Digicatech OÜ and you can contact our representative by email: [email protected] phone: 372 6027422.

16. Data protection officer

16.1 Our data protection officer's contact details are: Digicatech OÜ - [email protected].

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