Policy on the processing of personal data
1. General provisions
This Personal Data Processing Policy is written in accordance with the requirements of the Estonian legislation «On Personal Data» (hereinafter – the Personal Data Act) and determines the procedure for processing personal data and measures to ensure the security of personal data, undertaken by Company in Estonia OÜ (hereinafter referred to as Operator).
1.1. The operator makes it his most important goal and condition for the implementation of his activity to respect the rights and freedoms of a person and a citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator’s Personal Data Processing Policy (hereinafter referred to as Policy) applies to all information that the Operator may obtain about visitors to the website rue.ee.
2. Basic concepts used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer tools.
2.2. The blocking of personal data is a temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as software for computers and databases, making them available on the Internet at rue.ee.
2.4. Personal Data Information System – a set of personal data contained in databases, and providing their processing information technologies and technical means.
2.5. Anonymization of personal data – actions in which it is impossible to determine without the use of additional information the belonging of personal data to a particular User or other subject of personal data.
2.6. Processing of personal data – any action (transaction) or combination of actions (transactions) performed using or without means of automation with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – State, municipal body, Legal or natural person, independently or jointly with other persons, organizing and (or) performing the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (transactions) performed with personal data.
2.8. Personal Data – any information relating directly or indirectly to a certain or defined User of the Website rue.ee.
2.9. Personal data permitted by the subject of personal data for dissemination – personal data, access to an unlimited number of persons to whom the subject has provided
Personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Personal Data Act (hereinafter personal data permitted for dissemination).
2.10. User – any visitor of the website rue.ee.
2.11. Provision of Personal Data – Actions aimed at disclosing personal data to a certain person or a certain group of persons.
2.12. Dissemination of personal data – any action aimed at disclosing personal data to an undetermined circle of persons (transmission of personal data) or at familiarizing oneself with the personal data of an unlimited number of persons, including the publication of personal data in the mass media, posting in information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign natural or foreign legal person.
2.14. The destruction of personal data – any action that results in the permanent destruction of personal data with the impossibility of further recovery of the content of personal data in the information system of personal data and (or) The material holders of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The operator has the right to:
- To receive from the subject of personal data reliable information and/or documents containing personal data.
- In the event that the subject withdraws his or her consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data on the grounds specified in the Personal Data Act.
- Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Personal Data Act and the normative legal acts adopted thereunder; unless otherwise provided by the Personal Data Act or other federal laws.
3.2. The operator shall:
- To provide the subject of personal data, upon request, with information relating to the processing of his personal data;
- To organize the processing of personal data in accordance with the procedure established by the current legislation of Estonia;
- To respond to requests and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
- To inform the authorized body for the protection of the rights of subjects of personal data on the request of this body the necessary information within 30 days from the date of receipt of such a request;
- Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
- Undertake legal, organizational and technical measures to protect personal data from improper or accidental access to it, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
- Cease transmission (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for in the Personal Data Act.
- To perform other duties stipulated by the Law on Personal Data.
4. Basic rights and obligations of subjects of personal data
4.1. Subjects of personal data have the right:
- To receive information relating to the processing of his personal data, except as provided for in federal laws. Information shall be provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data pertaining to other subjects of personal data, except in cases Where there are legitimate grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Act.
- To require the operator to clarify, block or destroy his personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and to take the measures provided for by law to protect their rights.
- To require prior consent when processing personal data in order to promote goods, works and services in the market.
- To withdraw consent to the processing of personal data.
- To appeal to the authorized body for the protection of the rights of subjects of personal data or to the judicial procedure unlawful actions or omissions of the Operator in the processing of his personal data.
- To exercise other rights provided for in Estonian law.
4.2. Subjects of personal data must:
- Provide the Operator with reliable data about themselves
- Inform the Operator about the clarification (updating, modification) of their personal data
4.3. Persons who give false information about themselves to the Operator, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the legislation of Estonia.
5. Operator may process the following personal data of the User
5.1. Last name, first name, patronymic.
5.2. E-mail address.
5.3. Phone numbers.
5.4. The site also collects and processes anonymised data about visitors (incl. files «cookies») with the help of Internet statistics services (Google Analytics and others).
5.5. The above data is hereinafter referred to in the Policy as Personal Data.
5.6. Processing of special categories of personal data, concerning race, nationality, political opinions, religious or philosophical beliefs, intimate life, The operator shall not.
5.7. Processing of personal data permitted for dissemination from among the special categories of personal data specified in the Personal Data Act is permitted,
if the prohibitions and conditions stipulated in the Personal Data Act are fulfilled.
5.8. The User’s consent to the processing of personal data, permitted for dissemination, shall be issued separately from other consents to the processing of his personal data. The conditions laid down in the Personal Data Act shall be observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of subjects of personal data.
5.8.1 The User shall give consent to the processing of personal data authorized for dissemination to the Operator directly.
5.8.2 The Operator shall, within three working days of the receipt of the said User’s consent, publish information on the conditions of processing, prohibitions and conditions for processing of personal data by an unlimited number of persons, The personal data permitted for dissemination.
5.8.3 The transmission (distribution, provision, access) of personal data authorized by the subject of personal data for dissemination must be terminated at any time at the request of the subject of personal data. This requirement must include the surname, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the subject of personal data, as well as a list of personal data whose processing is subject to termination. The personal data specified in this requirement may only be processed by the Operator to whom it is sent.
5.8.4 Consent to the processing of personal data authorized for dissemination shall cease as soon as the Operator receives the request referred to in paragraph 5.8.3. of this Policy concerning the processing of personal data.
6. Principles of Personal Data Processing
6.1. The processing of personal data is legal and fair.
6.2. The processing of personal data is limited to the achievement of specific, predefined and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
6.3. It shall not be permitted to merge databases containing personal data processed for purposes which are incompatible with each other.
6.4. Only personal data that meet the purposes of processing shall be processed.
6.5. The content and amount of personal data processed correspond to the stated purposes of processing. Redundancy of personal data processed in relation to the stated purposes of processing is not allowed.
6.6. The processing of personal data ensures the accuracy of personal data, its sufficiency, and, where necessary, its relevance to the purposes of processing personal data. The operator shall take the necessary measures and/or ensure that they are taken to remove or clarify incomplete or inaccurate data.
6.7. Personal data shall be kept in a form that allows the identification of the subject of personal data no longer than the purpose of the processing of personal data requires, unless the period of retention of personal data is established by federal law, by treaty to which the beneficiary or guarantor for which is the subject of personal data. The personal data processed shall be destroyed or anonymized when the purposes of processing have been achieved or if there is no need to achieve these purposes, unless otherwise provided by federal law.
7. Purposes of personal data processing
7.1. Purpose of processing the User’s personal data:
- Informing the User by e-mail
- The conclusion, execution and termination of civil contracts
- Providing the User with access to the services, information and/or materials contained on the website.ee
7.2. The Operator also has the right to notify the User about new products and services, special offers and various events. The User can always refuse to receive information messages by sending an e-mail to the [email protected] the mark «Refusal of notifications about new products and services and special offers».
7.3. Anonymised data of Users, collected with the help of services of the Internet statistics, serve to collect information on actions of Users on the site, improve the quality of the site and its content.
8. Legal grounds for processing personal data
8.1. The legal basis for the processing of personal data by the Operator is:
- Statutory documents of the Operator
- Contracts concluded between the operator and the subject of personal data
- Laws, other regulatory and legal acts in the sphere of personal data protection
- The consent of the Users to the processing of their personal data, to the processing of personal data permitted for dissemination
8.2. The Operator processes the User’s personal data only in case of their filling and/or sending by the User
independently through special forms located on the website rue.ee or sent to the Operator via e-mail. By filling in the relevant forms and/or sending your personal data to the Operator, the User expresses his consent to this Policy.
8.4. The subject of personal data independently decides on the provision of his personal data and gives consent freely, by his will and in his interest.
9. Conditions for processing personal data
9.1. The processing of personal data is carried out with the consent of the subject of personal data for the processing of his personal data.
9.2. The processing of personal data is necessary to achieve the purposes stipulated by the Estonian International Treaty or by law, in order for the operator to carry out the functions, powers and duties assigned by the Estonian legislation.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, the act of another body or official, which is subject to enforcement under Estonian law on enforcement proceedings.
9.4. The processing of personal data is necessary for the performance of the contract, to which the beneficiary or guarantor is the subject of personal data, as well as for the conclusion of the contract on the initiative of the subject of personal data or contract, for which the subject of personal data will be the beneficial owner or guarantor.
9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant purposes, provided that the rights and freedoms of the subject of personal data are not violated.
9.6. Processing of personal data, access to an unlimited number of persons to whom the subject of personal data or at his request (further – public personal data).
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.
10. Procedures for the collection, storage, transmission and other processing of personal data
The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
10.1. The operator shall ensure the preservation of personal data and shall take all possible measures to prevent access to personal data of unauthorized persons.
10.2. Personal data of the User shall never, under any circumstances, be transferred to third parties, except in cases, related to the implementation of the existing legislation or in the case if the subject of personal data has given consent to the Operator to transfer the data to a third person to fulfill obligations under a civil contract.
10.3. In case of detection of inaccuracies in personal data, The User can update them by sending to the Operator a notification to the e-mail address of the Operator [email protected] with the mark «Updating of personal data».
10.4. The period of processing of personal data is determined by the achievement of the purposes for which personal data have been collected, unless another period is stipulated by the contract or the legislation in force.
The User may at any time withdraw his consent to the processing of personal data by notifying the Operator via e-mail to the Operator’s e-mail address [email protected] marked «Revocation of consent to the processing of personal data».
10.6. Prohibitions imposed by the subject of personal data on the transmission (except the granting of access) and on the processing or processing (except for access) of personal data, authorized for dissemination, are not applicable in cases of processing of personal data in the public, public or other public interest defined by Estonian law.
10.7. The operator ensures the confidentiality of personal data when processing personal data.
10.8. The operator shall store personal data in a form that allows the identification of the subject of personal data no longer than is required by the purpose of the processing of personal data, if the period of retention of personal data is not established by federal law, an agreement to which, the beneficiary or guarantor of which is the subject of personal data.
10.9. A condition for terminating the processing of personal data may be the achievement of the purposes of the processing of personal data, the expiration of the consent of the subject of personal data or the withdrawal of consent by the subject of personal data, as well as detection of illegal processing of personal data.
11. List of actions carried out by the Operator with the personal data received
11.1. The operator shall collect, record, systematize, accumulate, store, clarify (update, modify), extract, use, transmit (disseminate, provide, access), depersonalize, block, delete and destroy personal data.
11.2. The operator performs automated processing of personal data with and/or transmission of the received information through information and telecommunication networks or without.
12. Cross-border transfer of personal data
12.1. The operator, prior to the commencement of a cross-border transfer of personal data, must ensure that the foreign State to which the transfer of personal data is intended to, provides security of the subject’s personal data.
12.2. Cross-border transfer of personal data in the territory of foreign countries that do not meet the above requirements, may be carried out only if the personal data subject agrees in writing to the cross-border transfer of his personal data and/or the performance of the contract to which the personal data subject is a party.
13. Confidentiality of personal data
Operator and other persons who have access to personal data shall not disclose to third parties or distribute
Personal data must not be published without the consent of the subject of personal data, unless otherwise provided by federal law.
14. Final provisions
14.1. The User may obtain any clarifications regarding the processing of his personal data by contacting the Operator by e-mail [email protected]
14.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced with a new version.
14.3. The current version of the Free Access Policy is available on the Internet at rue.ee.
At the moment, the main services of our company are legal and compliance solutions for FinTech projects. Our offices are located in Tallinn, Vilnius, and Warsaw. The legal team can assist with legal analysis, project structuring, and legal regulation.
Company in Estonia OÜ
Registration number: 14153440
Licence number: FIU000186
Phone: +372 5333 8208
Email: [email protected]
Address: Sepise 1, Tallinn, 11415, Estonia
Company in Lithuania UAB
Registration number: 304377400
Phone: +370 661 75988
Email: [email protected]
Address: Lvovo g. 25 – 702, 7th floor, Vilnius, 09320, Lithuania
Company in Poland Sp. z o.o
Registration number: 38421992700000
Phone: +48 50 633 5087
Email: [email protected]
Address: Twarda 18, 15th floor, Warsaw, 00-824, Poland
Company in Czech Republic s.r.o.
Registration number: 08620563
Phone: +420 775 524 175
Email: [email protected]
Address: Na Perštýně 342/1, Staré Město, 110 00 Prague