PRIVACY PRINCIPLES FOR CLIENTS
PRIVACY PRINCIPLES FOR CLIENTS
Valid from 16.12.2021
1.1.The controller of the customer’s personal data within the meaning of the applicable personal data protection legislation is Lapseväli OÜ (hereinafter “Lapseväli” or “we”).
1.2.Contact details of the controller:
Registry code: 16391623
Address: Aiandi 8/1-8, Mustamäe district, Tallinn, Harju county, 12915 Estonia
Phone number: +372 519 09 2 69
2.WHAT INFORMATION DO WE COLLECT AND USE?
2.1.We may collect the customer’s personal data in different ways mentioned below.
2.2.Generally, the customer gives their personal data to us when renting goods from us or communicate with us (for example through the website forms, self-service environment or customer service on our website).
2.3.We may also collect the customer’s personal data from external sources, for example from public databases.
2.4.The personal data we collect are the following:
2.4.1.general personal data like name and surname, date of birth and personal identification code;
2.4.2.contact details, for example e-mail address, delivery address and phone number;
2.4.3.order information, customer inquiries and responses, feedback and inquiries regarding the service we provide, billing and payment information, details of rented items and other data collected or created during the execution of the order;
2.4.4.used language of communication;
2.4.5.IP address, authentication and signature data in a self-service environment (type and outcome of activity, means of authentication or signature, unique customer identifier);
3.THE PURPOSE AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
3.1.Lapseväli OÜ process personal data for the following purposes and on the basis of the Regulation of the European Parliament and of the Council (EU) 2016/679, April 27th 2016, the repealing of the Directive 95/46 / EC (General Regulation on the protection of personal data) Article 6 (1) (a) (consent of the data subject), (b) (for the performance of the order), (c) (to fulfil the legal obligation of the controller) and (f) (legitimate interest). The main purpose of collecting the customer’s personal data is to enable the provision of service to the customer. The processing of personal data is based on the rental relationship between customer and us in the form of an order. Our purpose is to process whatever personal data on these purposes in a suitable, fair and sufficient way.
3.2.Lapseväli OÜ can send e-mails or SMS to the customer to notify about our newest services, ask the customer for a feedback or provide the customer with any other necessary information about our services. The processing of personal data for this purpose is based on our legitimate interest to proovide the customer with the necessary information about the company, to promote our products to the customer and to improve the current business model. The customer can opt out of marketing communications at any time. If the customer’s consent is required under applicable law to send marketing communications, we will only process the customer’s personal information for that purpose with consent of the customer.
3.3.Lapseväli OÜ also processes the customer’s personal data to improve the quality of our services and to work out new services. The basis of processing the personal data on these purposes is our legitimate interest so that we would have enough relevant information to develop the services.
3.4.Lapseväli OÜ also processes personal data to fulfill our obligations under valid accounting and tax legislation. In that case the basis to process personal data are legislations which oblige us to keep certain accounting data.
3.5.If our goods are not returned within the prescribed time, Lapseväli OÜ can process personal data to publish relevant information in debtors’ database (for example Creditinfo Eesti AS, https://www.creditinfo.ee/), by legal service providers and in databases aimed at improving the recovery of debts, in accordance with the applicable law. In this case, the processing of personal data is based on our legitimate interest in ensuring our security in our business to protect our business interests.
3.6.If necessary, Lapseväli OÜ can process personal information in pursuit of our legitimate interest in filing, processing or defending legal claims arising from rental relationship between us and the customer.
4.TRANSMISSION AND DISCLOSURE OF PERSONAL DATA
4.1.Being the chief processor of personal data, Lapseväli OÜ may forward the customer’s personal information to third parties:
4.1.1.to our employees who are responsible for customer cooperation and support customer relationships, as well as employees in accounting, IT maintenance, business analysis and business planning functions;
4.1.2.to the suppliers of IT systems used to manage our customer communications and cloud service providers and auditors
4.1.3.to the transmission of data to the Estonian Tax and Customs Board and other state agencies as such is required by law
4.1.5.to our authorized processors and other persons involved in the performance of the order. Lapseväli OÜ forwards personal data necessary for making payments to the authorized processor Maksekeskus AS.
4.1.6.to the persons who help us to exercise our rights on the basis of rental relationship between customer and us (who provide debt collection services, legal advisers, courts, credit information companies, etc.);
4.1.7.to parties involved in possible mergers, acquisitions or the sale of all or part of our assets.
5.TRANSFER OF PERSONAL DATA OUTSIDE EU/EEA COUNTRIES
5.1.We not share the customer’s personal information outside the European Union and European Economic Area.
6.2.Cookies are small text files that are placed on client’s device to collect and remember the information needed to improve the functionality of our website and make it easier to use.
7.STORAGE OF PERSONAL DATA
7.1.Lapseväli OÜ retains the customer’s personal information for as long as is necessary to achieve the purposes described in this policy or in accordance with applicable law.
7.2.The customer’s personal data will be stored until the end of rental relationship with Lapseväli.
7.3.We retain source accounting records (eg, copies of order, invoices) for 7 years from the end of the relevant financial year, as required by applicable law.
7.4.If the storage of the customer’s personal data is no longer required by law or in connection with the rights or obligations of either party, we will delete the customer’s personal data.
8.THE CUSTOMER’S RIGHTS
8.1.The customer have the right to know which personal information we are processing.
8.2.The customer have the right to access, correct, update, change or delete the data at any time. However, please note that certain data are strictly necessary to the purposes described in this policy or are required by law. The customer cannot delete this data.
8.3.The customer have the right to object to certain processing.
8.4.The customer have the right to restrict the processing of own personal data under the conditions laid down in the data protection legislation.
8.5.The customer have the right to transfer data under the conditions set out in the personal data protection legislation, i.e. the right to receive own personal data in an orderly form in a publicly available machine-readable format and to transfer them to another controller at own discretion.
8.6.The customer’s right not to be subject to decisions made solely as a result of automatic processing, including profiling, is respected, as human intervention is always part of the final decision by Lapseväli.
8.7.If the customer find that we do not process personal data properly, the customer have the right to file a complaint with the data protection authority in his country. In Estonia there is a Data Protection Inspectorate. The contact details for Data Protection Inspectorate are found here: www.aki.ee.
9.1.We use relevant technical and organizational safety measures (including physical, electronical and administrative) to protect personal data against loss, destruction, misuse and unauthorized access or disclosure. For example, we provide access to the customer’s personal data only to authorized employees and contractors who need it to perform their tasks.
9.2.Please note that while we take reasonable steps to protect the security of the customer’s personal information, no system completely eliminates all potential security risks.
10.CHANGE IN POLICY
10.1.These principles may change from time to time.
10.2.If we make changes to the policy, we will notify about that on our website.
If the customer have any questions regarding this policy or the personal data we process, please contact us by writing to firstname.lastname@example.org