Privacy policy

1. General provisions

1.1 This Privacy Policy sets out the principles governing the collection, processing and storage of personal data. Personal data is collected, processed and stored by the controller of the personal data. (Havion.Art OÜ) (hereinafter referred to as the "data controller").

1.2 For the purposes of this Privacy Policy, a data subject is a customer or other natural person whose personal data is processed by a data processor.

1.3 For the purposes of this Privacy Policy, a customer is anyone who purchases goods or services from the website of the data processor.

1.4 The data processor shall comply with the principles of data processing set out in the legislation, including processing personal data lawfully, fairly and securely. The data processor is able to confirm that the personal data have been processed in accordance with the law.

2. Collection, processing and storage of personal data

2.1 The personal data collected, processed and stored by the data processor are collected electronically, mainly through the website and e-mail.

2.2 By sharing their personal data, the data subject grants the data processor the right to collect, organise, use and manage the personal data that the data subject directly or indirectly shares with the data processor when purchasing goods or services from the website for the purposes specified in the Privacy Policy.

2.3 The data subject is responsible for the accuracy, correctness and completeness of the data he or she provides. Knowingly submitting false information will be considered a breach of the Privacy Policy. The data subject is obliged to inform the data processor without delay of any changes to the data provided.

2.4 The Data Processor shall not be liable for any damage caused by the submission of false data by the data subject to the data subject or third parties.

3. Processing of customers' personal data

3.1 The data processor may process the following personal data of the data subject:

3.1.1. First name and surname;

3.1.2. Date of birth;

3.1.3. Telephone number;

3.1.4. E-mail address;

3.1.5. Delivery address;

3.1.6. Current account number;

3.1.7. Payment card details;

3.2 In addition to the foregoing, the data controller has the right to collect data about the customer that is available in public registers.

3.3 The legal basis for the processing of personal data is Article 6(1)(a), (b), (c) and (f) of the GDPR:

(a) the data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes;

(b) the processing of personal data is necessary for the performance of a contract entered into with the involvement of the data subject or in order to take steps at the request of the data subject prior to entering into a contract;

(c) the processing is necessary for compliance with a legal obligation to which the controller is subject;

(f) the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests override the interests of the data subject or the fundamental rights and freedoms for which the personal data must be protected, in particular where the data subject is a child.

3.4. Processing of personal data in accordance with the purpose of the processing:

3.4.1. Purpose of the processing - security and safety
Maximum period of retention of personal data - in accordance with the time limits specified by law.

3.4.2. Purpose of the processing - processing of the order.
Maximum retention period of personal data - indefinitely

3.4.3. Purpose of the processing - to ensure the functioning of the services of the e-shop.
Maximum retention period of personal data - indefinitely

3.4.4. Purpose of the processing - customer management.
Maximum retention period of personal data - indefinitely

3.4.5. Purpose of processing - financial activities, accounting.
Maximum period of retention of personal data - in accordance with the time limits specified by law.

3.4.6. Purpose of the processing - marketing.
Maximum retention period of personal data - indefinitely

3.5 The Data Processor has the right to share the personal data of the Customer with third parties, such as authorised data processors, accountants, transport and courier companies, companies providing transfer services, etc. The Data Processor is the controller of the personal data. The data processor transfers the personal data necessary for the execution of payments to the processor Maksekeskus AS.

3.6 When processing and storing the personal data of the data subject, the data controller shall implement organisational and technical measures to ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure and any other unlawful processing.

3.7 Depending on the purpose of the processing, the data controller shall store the data subjects' data indefinitely.

4. Rights of the data subject

4.1 The data subject has the right of access to and inspection of his or her personal data.

4.2 The data subject has the right to receive information about the processing of his or her personal data.

4.3 The data subject has the right to complete or correct inaccurate data.

4.4 If the data processor processes the personal data of the data subject on the basis of the data subject's consent, the data subject has the right to withdraw the consent at any time.

4.5 In order to exercise his or her rights, the data subject can contact the e-shop's customer support at info@sinupusa.ee.

4.6 The data subject may lodge a complaint with the Data Protection Inspectorate in order to protect his or her rights.

5. Final provisions

5.1 These Data Protection Terms and Conditions have been drawn up in accordance with Regulation (EU) No 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC / EC (General Data Protection Regulation), the Personal Data Protection Act of the Republic of Estonia and the legislation of the Republic of Estonia and the European Union.

5.2. The data processor has the right to modify the data protection conditions in whole or in part by informing the data subjects of the modifications on the website. (www.sinupusa.ee) via.