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1. You don’t define your target audience.
That’s like selling children’s toys to someone who doesn’t have children. Sounds weird, doesn’t it? To be on target, not weird, define your target audience
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Describes how WAPI OÜ, Reg no. 14699305, legal address: Kadaka tee 7, Mustamae linnaosa, Talinn, Harju maakond, 12915 Estonia (hereinafter – WAPI), collects, obtains (receives), stores, protects, uses, destroys (erase), retrieves and otherwise legally processes Your Personal Data, types and categories of such Personal Data, and purposes and legal grounds of the processing, and informs You about Your rights regarding the processing of Your Personal Data by WAPI.
2.2. WAPI collects and processes Your Personal Data in accordance with: Public Information Act, Personal Data Protection Act, Electronic Communications Act (hereinafter referred to as -Acts) and the Data Protection Ordinance (hereinafter referred to as DPO), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (hereinafter referred to as GDPR), other regulatory enactments, and only:
2.3. In addition to the definitions, set forth in other sections of this Policy, such definitions are used herein:
2.3.1. “Personal Data” means any information relating to You, as an identified or identifiable natural person (‘data subject’);
2.3.2. “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
2.3.3. “Controller” means- Wapi OÜ, Reg no. 14699305, Legal address: Kadaka tee 7, Mustamae linnaosa, Talinn, Harju maakond, 12915 Estonia, email: [email protected];
2.3.4. “You” and/or “Your” means any natural person (Data subject), whose Personal Data is processed by WAPI , when:
2.3.5. “Processor” means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller;
2.3.6. “Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Data relating to him or her;
2.3.7. “Personal Data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed;
2.4. WAPI ensures the confidentiality, privacy and security of Your Personal Data, as well as the legality of the data processing in accordance with the Acts and GDPR, and other related regulatory enactments.
3.1. By using WAPI Services, You confirm, acknowledge and understand that WAPI cooperates with partners, some of whom are not located in Estonia or EEA. By accepting this Policy and using WAPI Services You acknowledge and agree that some of Your Personal Data will be processed by our partners.
3.2. WAPI warrants, that WAPI cooperates only with partners, who are providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that any Your Personal Data processing will meet the requirements of the Acts and GDPR, and other.
3.3. WAPI can share or provide Your identification data, as name, surname, ID document data, correspondence/contact data, payment requisites etc. with or to the partners in the purpose to provide to You WAPI services or services which You ordered from a partner of WAPI (WAPI is subcontractor).
3.4. If provided by law, including international treaties between Estonia and the residence state of our partners, WAPI may disclose Your identity and contact information to governmental institutions, law enforcement body, court or other authorized institution or organization of the residence state of our partners, on the basis of the legal, grounded and valid request of such authority, institution or law enforcement body, court or other authorized institution or organization.
|Type or Categories of Your Personal Data||Purpose||Legal grounds for use of Your Personal Data||
The Source of Personal Data
Service Agreement data:
Your identity information, as name, surname, identity code or number, if any, payment method (requisites), date of birth, residence address, e-mail, phone number, identity document data (when provided by law);
or Employment data:
Your identity information, as name, surname, identity code or number, if any, payment method, date of birth, residence address, e-mail, phone number, – identity document data (when provided by law), data about education, skills, knowledges, work experience and other data defined in law on employment, tax laws and other related regulatory enactments of Estonia.
Your identity information as name, surname and correspondence address /method and other Personal Data You submit to WAPI by any written or oral correspondence, including claims, complaints, offers, also job offers.
Your name and surname, e-mail and phone number;
Billing and accounting data:
Your selected tariff, other payments (including salaries) and payment terms, defined in Your agreement with WAPI and related taxes, fees and other obligatory payments.
Website (cookies) data:
(See Cookies Policy) Your IP address, Your Device, Your operating system, the date and time of Your access to the Website, the type of browser Your use, Your online activities and Your preferences, the external sites that referred you to WAPI Services
To Execute the legal requirements:
Personal Data received from law enforcement authorities or courts and/or other competent authorities.
4.1. You are solely responsible for the validity, accuracy, correctness, reliability, quality, stability, completeness or up-to-dateness of Your Personal Data, You personally provide to WAPI and/or its Agents.
4.2. WAPI does not knowingly collect personal information from or on behalf of someone under 18. If You are under 18 do not register on the Website or provide any information about Yourself to WAPI without consent, which must be given or WAPI must be authorised by the holder of parental responsibility over You. WAPI shall make reasonable efforts to verify in such cases that consent is given or authorised by the holder of parental responsibility over You, taking into consideration available technology. If WAPI learns to have collected or received Personal Data from or on behalf of someone under 18 without consent of the holder of parental responsibility WAPI will remove/erase such information and/or user account and not make future process Your Personal Data.
4.3. WAPI does not process Your sensitive and other Personal Data, which processing is forbidden or restricted by law. You should not provide sensitive or special data, that is, data concerning racial or ethnic origin, political views, religious or philosophical beliefs, trade union membership, genetic and biometric data, data concerning health, or data concerning your sexual life or sexual orientation, in any material You submit to WAPI in any way.
4.4. No automated individual decision making or profiling is performed in the course of the data processing of WAPI.
4.5. When You are using WAPI Services, WAPI offers You choices (privacy preferences) regarding how WAPI contacts You for marketing related communications (Promotional Data) and whether WAPI uses information regarding Your online activities on the Website for marketing purposes. To learn about ways to register Your privacy preferences with WAPI please contact WAPI . You may also register a do-not-contact requests by sending an email to [email protected]. If You register a do-not-contact request, WAPI may still contact You for non-promotional purposes, such as emails about Your accounts or our ongoing business relations.
5.1. Legitimate interests of WAPI are:
5.1.1. To enter into and to perform the Agreement between You and WAPI or between You and general contractor, who transferred part of contractual obligations to WAPI;
5.1.2. To ensure and protect the interests and rights of WAPI (for example, to file an objection, claim or pretension, and/or to bring an action to a court or arbitrage)
5.1.3. To provide WAPI Services;
5.1.4. To ensure the cyber, network and information security of WAPI systems;
5.1.5. To develop and to enchase the WAPI Services and business activities;
5.1.6. To support and analyse the performance of the Webpage;
5.1.7. To detect and prevent fraud, including the violations against WAPI and its rights;
5.1.8. To maintain the personnel and employment management;
5.1.9. To maintain the accountancy management;
5.1.10. To comply with local and foreign law, law enforcement, court and regulatory bodies’ (governmental and municipal /local authorities) requirements;
5.1.11. To operate the day-to-day running of the business and plan for strategic growth, including managing of customer, client, user, vendor, contractor, supplier and other relationships, sharing intelligence with stakeholders, implementing safety procedures, and planning and allocate resources and budget (General Corporate Operations and Due Diligence);
5.1.13. To respond to emergencies;
5.1.14. To communicate with the users, clients, customers, suppliers etc business partners of WAPI (send and receive Your correspondence, and provide the correspondent with an accurate, timely and apropos reply to You);
5.1.15. To initiate, render, bill, and collect payments for WAPI Services;
5.1.16. To facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government requirement; or determine eligibility for government benefits.
5.1.17. To comply with legal or regulatory obligations to which WAPI is subjected.
6.1. When and where the processing of Your Personal Data is a subject to Your Consent, You may give Your Consent and WAPI shall consider that Your Consent is received, if:
6.1.1. You have provided WAPI with Your freely given, specific, deliberate, informed and unambiguous reference, or statement of Your consent on the processing of Your Personal Data, or
6.1.2. You have performed a clear affirmative activity confirming Your consent to the processing of the Personal Data, or
6.1.3. You have in any way (in writing, orally or electronically)- accepted this Policy, including, but not limited to:
6.2. You are entitled to withdraw Your consent in any time, by submitting Your request (withdrawal) in written to WAPI OÜ, Reg no. 14699305, legal address: Kadaka tee 7, Mustamae linnaosa, Talinn, Harju maakond, 12915 Estonia, or email: [email protected].
6.3. In case if, upon receipt of Your withdrawal, WAPI has reasonable doubts concerning Your identity, WAPI may request the provision of additional information necessary to confirm Your identity.
6.4. Upon receipt of Your withdrawal, WAPI shall ascertain Your identity and will stop processingYour Personal Data, based on Your prior consent given for this processing purpose. If the processing is based on the legitimate interests of WAPI , You have a right to object to processing rather than withdrawal of consent.
6.5. The withdrawal of Your consent will not affect the lawfulness of Your Personal Data processing based on Your consent, performed before WAPI has received Your withdrawal.
6.6. If and when after withdrawal of the consent, You perform any of the confirmative actions set forth in this Clause, WAPI will consider that the consent is given again.
7.1. WAPI may disclose Your Personal Data to third parties, as follows, who provides sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of GPDR , Acts and DPO and ensure the protection of the rights of the data subject (You):
7.1.1. WAPI business partners, suppliers and contractors, who help WAPI to provide WAPI Services, including, but not limited to the banks, payment service providers, information system consultants and analytical and research service providers;
7.1.2. WAPI professional advisers (including accountants and lawyers) that assist WAPI in carrying out its business and legal activities;
7.1.3. Law enforcement agencies and other authorized persons in connection with the prevention,investigation and detection of crime or any suspected criminal, administrative or civil wrongdoing;
7.1.4. to the courts, law enforcement, court and regulatory bodies’ (governmental and municipal /local authorities)third parties, if WAPI is under a duty to disclose or share Your Personal Data in order to comply with any legal obligation or instructions of a regulatory body (including in connection with a court order), or in order to enforce or apply the terms of any agreements WAPI has with or otherwise concerning You (including agreements between You and us) or to protect rights, property or safety of customers, employees of WAPI or other third parties of the WAPI;
7.1.5. To third parties and in cases, defined in Clause 2 of this Policy;
7.1.6. WAPI may also disclose Your Personal Data to other third parties, for example:
8.1. WAPI will process Your Personal Data as long as there is at least one of the following conditions:
8.1.1. While is valid /not withdrawn Your consent to the processing of Your Personal Data, provided that there is no other legal basis or legitimate purpose of Your Personal Data processing.
8.1.2. While is valid Your Agreement with WAPI .
8.1.3. While Your Personal Data is necessary for the legal grounds, the legitimate purpose and / or aims for which they were received/collected or other way processed.
8.1.4. While in accordance with the procedures prescribed by regulatory enactments, WAPI or You may exercise their rights and legitimate interests (for example, to submit objections or claims, or to bring any action or claim before a court or arbitrage).
8.1.5. While WAPI has a legal obligation to keep Your Personal Data (for example, in accordance with the Accounting regulatory enactments, etc.).
8.1.6. After termination of the conditions indicated in this Clause, Your Personal Data will be deleted /erased or, in cases specified in regulatory enactments, transferred to the state archive (in state storage).
8.1.7. Job application and Your CV Personal Data shall be stored within 1 (one) month upon WAPI has received, excluding if You expressly defined other processing terms in Your application form, for recruitment purposes.
8.1.8. Cookies Data shall be stored within time, set forth in Cookies Policy.
9.1. You have the following rights concerning the processing of Your Personal Data:
9.1.1. Right to withdraw Your consent – You have the right to withdraw Your consent as set in Clause 6.2 of this Policy.
9.1.2. Right of access to Your Personal Data – You have the right to receive a copy of Your Personal Data that WAPI processes about You, subject to certain exemptions provided by regulatory enactments.
9.1.3. Right to rectify Your Personal Data – You have the right to ask WAPI to correct Your Personal Data that WAPI processes where it is incorrect or incomplete.
9.2. Right to erasure of Your Personal Data -You have the right to ask that Your Personal Data be deleted/erased in case if:
9.2.1. Your Personal Data is no longer necessary in relation to the purposes for which they were processed, collected or otherwise used by WAPI .
9.2.2. You withdraw Your consent and there is no other legal ground or legitimate purpose for which WAPI may process Your Personal Data;
9.2.3. You object to the processing of Your Personal Data (as set out below);
9.2.4. WAPI has used Your Personal Data unlawfully;
9.2.5. Your Personal Data needs to be erased to comply with a legal obligation.
9.3. Right to restrict the use of Your Personal Data- You have the right to suspend processing of Your Personal Data, in case if:
9.3.1. You believe that Your Personal Data is inaccurate and only for such period to enable WAPI to verify the accuracy of Your Personal Data;
9.3.2. the processing of Your Personal Data is unlawful and You oppose the erasure of Your Personal Data and request that it is suspended instead;
9.3.3. WAPI no longer needs Your Personal Data, but Your Personal Data is required by You for the establishment, exercise or defence of legal claims; or
9.3.4. You have objected to the processing of Your Personal Data and WAPI is verifying whether its grounds for the processing of Your Personal Data are of the highest importance than Your objection.
9.3.5. Right to data portability- You have the right to obtain Your Personal Data in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible. The right only applies where the processing of Your Personal Data is based on Your consent or for the performance of Your Agreement with WAPI , and when the processing of Your Personal Data is carried out by automated (i.e. electronic) means.
9.4. Right to object to the processing of Your Personal Data -You have the right to object to the processing of Your Personal Data in certain circumstances, where
9.4.1. You have grounds relating to Your particular situation and WAPI processes Your Personal Data for legitimate interests (or those of a third party) of the WAPI including for profiling; and
9.4.2. You object to the processing of Your Personal Data for direct marketing purposes, including profiling (to the extent it relates to direct marketing).
9.4.3. Right to object to decision which is based solely on automated processing – You have the rights to object to being subject to a decision which is based solely on automated processing without human intervention.
9.4.4. Right to complain to the relevant data protection authority- see Clause 10.6.You may submit a request for the exercise of Your rights in writing to WAPI.
9.4.5. If upon receipt of Your request WAPI has reasonable doubts concerning Your identity WAPI may request the provision of additional information necessary to confirm Your identity.
9.4.6. Upon receipt of Your request, WAPI shall ascertain Your identity, examine and review Your request and execute / or reasonably reject in accordance with the GDPR and other related Data protection regulatory enactments.
9.4.7. WAPI well send a reply to Your request to a mailing (contact) address provided by You in Your request, by registered mail or other way, as You asked in Your request if technically feasible, within 30 (thirty) days from the date of receipt of the request. Please note, that if You haven’t provided Your contact address and / or other way of receiving the reply, WAPI will not be able to send it to You and You should contact WAPI personally to arrange the way and time You can receive it.
9.5. Information provided and any communication and any actions taken under this Clause shall be provided free of charge. Where requests from You are manifestly unfounded or excessive, in particular because of their repetitive character, WAPI may either:
9.5.1. Charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or
9.5.2. Refuse to act on the request.
10.1. If you have any concerns or complaints regarding the privacy of Your Personal Data WAPI processes You may submit a request for the exercise of Your rights in writing to WAPI.
10.2. If upon receipt of Your request WAPI has reasonable doubts concerning Your identity WAPI may request the provision of additional information necessary to confirm Your identity.
10.3. Upon receipt of Your request, WAPI shall ascertain Your identity, examine and review Your request and provide a reply in accordance with the GDPR and other related Data protection regulatory enactments.
10.4. WAPI well send a reply to Your request to a mailing (contact) address provided by You in Your request, by registered mail or other way, as You asked in Your request, if technically feasible, within 30 (thirty) days from the date of receipt of the request. Please note, that if You haven’t provided Your contact address and / or other way of receiving the reply, WAPI will not be able to send it to You and You should contact WAPI personally to arrange the way and time You can receive it.
10.5. The reply provided and any communication and any actions taken under this Clause shall be provided free of charge. Where requests from You are manifestly unfounded or excessive, in particular because of their repetitive character, WAPI may either:
10.5.1. Charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or
10.5.2. Refuse to act on the request.
10.6. You have the right to address any Your claim concerning Your Personal Data processing by WAPI to the competent personal data protection supervisory authority which, in case of WAPI, is Office of the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), adrdress: Tatari 39, 10134 Tallinn, Tel. +372 6828 712, e-mail: [email protected], (for more information see- https://www.aki.ee/).
11.1. As soon as WAPI collected Your Personal Data, WAPI uses various security features and procedures, taking into account industry standards, to protect Your Personal Data and to prevent unauthorized access to that information. WAPI maintains a variety of appropriate technical and organisational physical, electronic, and procedural safeguards and measures, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage of Personal Data. These safeguards help protect Your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. These safeguards include:
11.1.1. ensuring the pseudonymisation and encryption of Personal Data;
11.1.2. ensuring the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
11.1.3. ensuring the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident;
11.1.4. ensuring the process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing of Personal Data.
11.2. WAPI will do all the best to protect Your information and Personal Data, for use of WAPI Services, You have to keep Your User Account, User Profile data as well as all the information and data You issue, send, post, publish share etc on/or via the Website and or Social networks and/or other way, safe by using a strong password and by complying with obligations, set forth in Your agreement with WAPI .
12.1. If You have any questions about, or complaints that concern this Policy, please call or email WAPI.
12.2. WAPI may change this Policy at any time. When WAPI changes the Policy, WAPI shall post that changes on the Website. In case of material changes to how WAPI process Your Personal Data, WAPI shall notify You by email to the email address specified by You. You are responsible for ensuring WAPI has an up-to-date, active and deliverable email address for You. You are also responsible for reviewing this Policy from time to time to check for any changes. All changes are effective immediately when WAPI posted them.
12.3. This Policy is effective from 01.09.2019.
12.4. The date Policy was last revised is identified at the top of the page.
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