Kintar Trading OÜ (private limited company; hereinafter “Kintar”) places great importance on the privacy and security of its customers’ personal data. To ensure this, we have developed a privacy policy that outlines the purposes, conditions, and rights related to the collection and processing of data subjects’ personal data.
TERMS OF WEBSITE USE
Valid from 7 June 2024.
These Terms of Website Use (the “Terms“) regulate the use of the website owned by Kintar Trading OÜ (registration code 10231137; “we“), accessible at www.kintar.ee and its subdomains (the “Website“). Please read the Terms carefully before using the Website. By using the website, we consider that you have agreed with the Terms.
If you disagree with any part of these Terms or no longer wish to use the Website, please stop using it.
1. USE OF THE WEBSITE
1.1. You are entitled to use the Website and its features for the intended purposes in accordance with these Terms.
1.2. Use of the Website is allowed only for lawful purposes that comply with applicable laws and accepted standards of conduct. The following actions, among others, are prohibited when using the Website: (I) attempting unauthorised access to the Website or parts thereof; (II) collecting, processing, or distributing the Website users’ (personal) data; (III) actions that impede or disrupt the operation of the Website or related systems, as well as their security; (IV) using the Website for fraudulent or malicious purposes; (V) posting offensive, defamatory, abusive, or illegal materials;
1.3. Data entered on the Website (including when creating a user account) must be accurate, up-to-date, and complete. You are solely responsible for any material you post on the Website.
2. USER ACCOUNT
2.1. To access certain functions of our Website, it may be necessary to create a user account. You must be at least 18 years old to create a user account.
2.2. You are solely responsible for all activities that occur under your user account. You are also obligated to keep account details (login data, etc.) confidential and inaccessible to third parties. You must immediately notify us of any potential security breaches or suspicions of such breaches, including unauthorised use of the account.
2.3. We have the right to restrict or deny access to a user account at any time if you violate these Terms or behave in a manner that we deem inappropriate or harmful.
2.4. You can close your account at any time by notifying us at the e-mail address provided in section 7.1 of the Terms.
3. INTELLECTUAL PROPERTY
3.1. All content on our Website, including text, graphics, logos, images, and software, is protected by intellectual property rights owned by us or third parties and is not transferred to Website users as a result of their use. Reproduction, distribution, modification, and other actions that violate our or third parties’ intellectual property rights are prohibited.
3.2. By using the Website, you grant us a non-exclusive, worldwide, and royalty-free licence to use, reproduce, distribute, process, publicly perform, and display materials entered by you on the Website in accordance with the purposes of the Website.
4. PERSONAL DATA
4.1. When using the Website, your personal data may become known to us. We process personal data in accordance with our data protection terms, available at the bottom of this page.
5. LIMITATION OF LIABILITY
5.1. To the maximum extent permitted by law, we do not assume liability for any direct or indirect damage that may occur in connection with the use of the Website.
5.2. We do our best to ensure the availability and usability of the Website, but we do not guarantee that the Website will always be available, uninterrupted, secure, or free from errors or malware. Access to the Website may also be temporarily restricted or suspended due to maintenance, updates or other reasons.
5.3. The Website may contain links to third-party websites, the content and activity of which are not under our control. We are not responsible for the content, security, or privacy of such third-party websites. If you click on a link to a third-party website, do so at your own risk and familiarise yourself with the terms of use of the respective website.
6. AMENDMENTS
6.1. We have the right to amend or update the Terms at any time. The amended Terms take effect upon their publication on the Website. By continuing to use the Website after the amended Terms have taken effect, you are deemed to have accepted them.
6.2. We reserve the right to change, limit, or supplement the features, structure, and content of the Website at any time without prior notice or to cease providing the Website.
7. FINAL PROVISIONS
7.1. All proposals, inquiries, and complaints related to the use of the Website must be submitted to the e-mail address info@kintar.ee.
7.2. These Terms are governed by the laws of the Republic of Estonia. Any possible disputes related to the use of the Website shall be resolved through negotiations, and, in case of their failure, in the Harju County Court, unless mandatory jurisdiction stipulates otherwise.
PRIVACY POLICY
Version 1, valid from 7 June 2024.
The Privacy Policy (the “Policy”) sets out the principles of processing personal data by Kintar Trading OÜ (public limited company; registration code 10231137, address: Harju county, Rae rural municipality, Rae village, Koplipere Street 17, 75310 (Harju maakond, Rae vald, Rae küla, Koplipere tee 17, 75310), e-mail info@kintar.ee; “we“) as the data controller regarding the processing of your (“your“) personal data.
We process your personal data primarily within the framework of contractual relationships, use of the website and communication between us. Additionally, we process personal data of individuals applying for jobs with us.
When we act as a data processor, we do so in accordance with the data processing agreements concluded between us and the data controllers, as well as in accordance with applicable legislation. In addition to ensuring that personal data is processed in accordance with the relevant legislation, we maintain the confidentiality (subject to possible applicable exceptions) and security of all other data that become known to us and are subject to confidentiality obligations.
Before using the Website, entering into a contract with us, or applying for a job with us, please read the Policy carefully. If you do not agree with the Policy, please stop using the Website, do not enter into a contractual relationship with us, or do not apply for a job with us. We reserve the right to update the Policy from time to time, notifying you of important changes on our Website and/or by e-mail.
1. COMPOSITION OF PERSONAL DATA
To achieve the objectives specified in the Policy, we process some or all of the following personal data, with the exact composition varying for each case. However, we always adhere to the principle of processing as little personal data as necessary to achieve the goal:
- First and last name
- Personal identification number
- E-mail address
- Address
- Data related to means of payment
- User account information (username, preferences, etc.)
- Phone number
- Data related to job applications
- Other personal data that becomes known to us or is provided during the normal course of contract fulfillment and website usage, or in communication with individuals.
We also collect data on the duration of website visits, the number of clicks, and user actions on our website solely for the purpose of analysing and improving website usability. We only use secure services such as Google Analytics. We also compile relevant statistical summaries for commercial purposes, but in the process your personal data is anonymised, and statistical summaries are stored securely.
2. PURPOSES AND LEGAL BASIS OF DATA PROCESSING
We process personal data if it is necessary for the use of the website (including the digital ordering portal) or the fulfilment of our contractual obligations to our customers. We may also process your personal data to send notifications related to contractual relationships, including responses to your comments, questions, and requests.
In the case of our legitimate interest, we may process your personal data to protect and secure our interests (including in the event of disputes), to apply the “Know Your Customer” principle, to organise client events, to assess and predict the fulfilment of contractual and legal obligations of our partners, and for general client relationship management. We also process personal data based on legitimate interest when you call or e-mail us, to respond to your inquiries and improve customer service quality.
We may process your personal data to fulfil obligations set out in legislation, such as obligations related to anti-money laundering and counter-terrorism financing, personal data protection, storing personal data for any period necessary to fulfil legal obligations (e.g., for accounting purposes), and other obligations arising from applicable legislation.
With your consent, we process your personal data to send you newsletters, blog updates, advertisements, marketing, and other information via e-mail. You can unsubscribe from such mailing lists at any time by clicking the appropriate button at the bottom of the e-mail.
In areas and/or premises of properties owned or managed by us, video surveillance may be used. We may use video surveillance based on our legitimate interest, primarily to enhance security, protect property and other rights, and to monitor the fulfilment of contractual obligations. If the video recording needs to be submitted or forwarded to law enforcement authorities, the legal basis for complying with such a requirement is the fulfillment of a legal obligation. Video surveillance is generally stationary, digital, with audio recording and zoom capabilities. Video recordings are accessible for viewing. Video surveillance is conducted around the clock. Access to video recordings and the surveillance system is only available to a limited number of authorised persons.
As part of applying for a job, we process personal data based on our legitimate interest in order to find out the suitability of the job applicant for a specific position, based on the requirements of the position and the nature of the job. If necessary, we have the right to check whether the data provided by the job applicant is correct, using public sources. Non-public sources may be used to collect data if there is a legal basis or the written consent of the job applicant. If the job applicant has provided us with the contact details of referees and/or previous employers, additional consent to collect data from these persons is not required. We process, among other things, the following personal data: (I) applicant’s basic data, such as name*, surname*, date of birth*, personal identification code* and/or other identifier, native language*; (II) contact details of the applicant, such as personal e-mail address*, personal telephone number, home address; (III) information regarding a vacant job, such as information regarding the position in question, including information about the nature and type of employment and the contact persons designated for the application process, salary proposal/expectation, information about when the job applicant can start working; (IV) other information provided by the applicant about themselves, their background, etc., in connection with the submission of the job application, such as education and other educational information*, degrees obtained*, profession, work experience (for example, previous employers, start dates and durations of previous employment relationships, previous duties), language skills*, other special skills, description of personal characteristics, various certificates and assessments, links to profiles and portfolios found on the internet, referees; (V) information about the applicant’s recruitment process, such as information about upcoming additional job interviews or termination of the recruitment process; (VI) other information that the applicant has voluntarily provided in connection with the recruitment process or has otherwise expressly disclosed for professional purposes (e.g. on LinkedIn), whereby by submitting a job application, the applicant consents to the collection of data from their professional profiles to the extent that such collection is necessary considering the nature of the vacant position. Providing the information marked with an asterisk is mandatory for considering your application in the recruitment process.
We always seek your prior explicit consent to process personal data if we use it for purposes not specified in the Policy. You can withdraw such consent at any time.
3. SECURITY MEASURES
We process personal data only when there is a legal basis and only for lawful purposes. We apply security measures and store personal data in a manner that ensures its security and confidentiality. Access to personal data is granted only to persons who need it in connection with the performance of their job duties or for whom disclosing personal data is in accordance with the Policy or legislation.
Access to systems containing personal data is permitted only to our employees who need to process such personal data in connection with their job duties. Each user has a personal username and password to access the system. Data is collected in databases protected by firewalls, passwords, and other technical measures. Databases and their backups are stored in locked rooms, and access to them is restricted to pre-authorised persons. We also store paper copies of personal data in locked rooms, and access to them is granted only to persons with relevant rights in connection with their job duties.
We apply appropriate physical, organisational, and information technological security measures to protect personal data from accidental or unlawful destruction, loss, alteration, or unauthorised access and disclosure. Personal data is not transferred outside the European Union or the European Economic Area.
We are not responsible for the unlawful use of your personal data caused by malware on your device.
4. DATA RECIPIENTS
We have the right to disclose and transfer personal data without your prior consent to authorised data processors acting on our behalf and based on relevant data processing agreements (e.g., HR and IT service providers, cloud service providers), as well as to fulfil obligations arising from legislation, such as disclosing data to government authorities. To protect our rights, we are entitled to disclose personal data to third parties, including debt registers and other third parties for debt collection, legal advisers, auditors, etc.
We do not transfer personal data outside the European Union or the European Economic Area.
5. DATA STORAGE AND DELETION
We store personal data only as long as it is necessary to achieve the purposes described in the Policy, protect our rights, or fulfil obligations under the legislation. We limit the processing of your personal data and process it only when necessary. We regularly review the necessity of storing data, considering applicable law. In addition, we take all reasonable measures to avoid storing data that contradicts the purposes of processing, is outdated, or inaccurate. We promptly correct or delete such data.
We generally store the personal data of job applicants for up to 1 year from the date of receipt of the job applicant’s personal data. If the job applicant becomes our employee, their recruitment documents are stored in accordance with the terms of processing employee personal data.
To comply with accounting requirements, we store primary accounting documents for 7 years from the end of the financial year in which the document was recorded in the accounting.
We store personal data during the validity of the business relationship and in order to ensure possible follow-up service and communication, and to protect our legal rights, we retain personal data for 3.5 years from the end of the business relationship or, in the case of a dispute exceeding the aforementioned deadline, until the dispute is finally resolved.
Despite the termination of the client relationship, we may process your personal data for direct marketing purposes with your prior consent until the consent is withdrawn. Upon withdrawal of consent, information about the prohibition will be retained to the extent necessary to ensure compliance with the prohibition on sending marketing communications.
Video surveillance recordings are stored for up to 6 months, after which the recordings are automatically overwritten. Video recordings related to special incidents on our immovables (e.g., damage incidents, etc.) are stored and processed on a case-by-case basis based on the legitimate interests of us, our contractual partners, and/or visitors, depending on the situation. For example, if a violation is detected, video recordings containing your personal data may be used as evidence as long as necessary to investigate the violation in accordance with applicable laws and regulations.
We have the right to process non-personalised data (including personal data that has been irreversibly processed so that it cannot be linked to any identifiable individual, i.e., anonymised) during the term of our contract and thereafter, both independently and by allowing our partners to process it for the development of our services and solutions, and for statistical analysis purposes.
6. YOUR RIGHTS
You may request information from us about the processing of your personal data at any time. In accordance with applicable laws, you have or may have the right to:
- request the deletion of your personal data;
- request the correction of your personal data;
- request the restriction of the processing of your personal data, but in this case you may not be able to use our website or services to their full extent;
- object to the use of your personal data;
- receive your personal data in a structured, commonly used format and in a machine-readable form and transfer this data to another data controller.
A job applicant has the right to review the data collected about them during a background check and to provide their own explanations regarding the collected data.
If we process personal data based on consent, you can withdraw your consent at any time, in which case the processing of personal data will be terminated. This does not affect any previous processing activities. We respond to inquiries as quickly as possible, taking into account the deadlines arising from legislation.
7. COOKIES
We use cookies on our website. A cookie is a text file that the web server stores in the browser of your computer, mobile phone, or other device when you visit our website. Cookies are used to provide you with a more personalized experience and more convenient navigation on our website. You can remove unwanted cookies at any time through your web browser settings, but please note that removing cookies may impede access to our website and limit its functionality.
8. INQUIRIES AND COMPLAINTS
For questions or complaints related to the processing of personal data, please contact us
(info@kintar.ee) or the Data Protection Inspectorate (info@aki.ee; +372 627 4135).
