Profidiagnostik OÜ has committed to being a reliable partner in processing of Personal Data and respecting the rights of customers and employees. Based on this, we have developed a privacy policy regarding the collection, use, disclosure, transmission and storage of customer data.

1. DEFINITIONS

1.1. A data subject is a natural person about whom Profdiagnostik OÜ has information, or information that can be used to identify a natural person. Data subjects are, for example, individual customers and employees for whom Profdiagnos OÜ holds Personal Data.

1.2. Privacy Policy consists of this text which sets out the principles for Data Processing in Profdiagnostik OÜ.

1.3. Personal Data means any information about an identified or identifiable natural person.

1.4. Processing of Personal Data means any activity performed on the Data Subject’s Personal Data.

For example, collecting, storing, organizing, retention, amendment and disclosing personal information, granting access, making inquiries and extracts, using, transmitting, cross-using, merging, closing, deleting or destruction, or several of the above operations, regardless of the manner in which the operations are performed and the means are used.

1.5. Customer is any natural or legal person who uses or has expressed a wish to use services of Profdiagnostik OÜ.

1.6. The website www.tehnoülevaatus.ee belongs to the Profdiagnostik OÜ.

1.7. A visitor is a person who uses the website of Profdiagnostik OÜ.

1.8. Services are any services and products offered by Profdiagnostik OÜ.

1.9. Cookies are data files that the website sometimes stores on the Visitor’s device.

1.10. A Data Protection Officer of Profdiagnostik OÜ is a person who follows the application of the principles of Personal Data Processing in Profdiagnostik OÜ and with whom the Data Subject can contact in case of a complaint.

1.11. Sales channels are the methods of communication with the Data Subject used by Profdiagnostik OÜ, a tool created for the sale of goods and the provision of services. Including e-mail, telephone, public and social media, various chat lines, personalized and interactive ads, and other similar tools on Websites and elsewhere.

1.12. A Product Portfolio is business units of Profdiagnostik OÜ and various products and Services, the list of which is available on the website www.tehnoulevaatus.ee.

In the Privacy Policy, the Contract, the General Conditions and the communication between the parties shall have the meanings stated above.

2. GENERAL PROVISIONS

2.1. The controller of Personal Data is Profdiagnostik OÜ, registry code 10788514, located at Ehitajate tee 116, Tallinn 13517.

2.2. The Privacy Policy applies to the Data Subjects and rights and obligations specified in the Privacy Policy shall apply to all employees and cooperation partners of Profdiagnostik OÜ who have contact with the Personal Data held by Profdiagnostik OÜ.

2.3. The Privacy Policy may supplement the Privacy Statements posted on the Website or devices, and may also amend and supplement the Privacy Policy.

3. PRINCIPLES

3.1. Profdiagnostik OÜ always processes Personal Data based on the interests, rights and freedoms of the Data Subjects.

3.2. The goal of Profdiagnostik OÜ is responsible Personal Data Processing, in which case the best practice is followed, bearing in mind that it is always ready to demonstrate that the Personal Data Processing meets the set objectives.

3.3. All processes, instructions, operations and activities related to the Processing of Personal Data of Profdiagnostik OÜ are based on the following principles:

3.3.1. Legality. In the case of the processing of Personal Data, there is a legal basis for this, such as consent;

3.3.2. Justice. The processing of Personal Data is fair, in particular by requiring the Data Subject to have sufficient information on how the Personal Data is processed;

3.3.3. Transparency. The processing of Personal Data is transparent to the Data Subject;

3.3.4. Purposefulness. Personal Data shall be collected for specified, explicit and legitimate purposes and will not be subsequently processed in a manner contrary to those purposes.

3.3.5. Correctness. The Personal Data is correct and, if necessary, updated, and all reasonable measures have been taken to ensure that incorrect Personal Data with regard to the purpose of the Personal Data Processing is deleted or corrected.

3.3.6. Retention restriction. Personal Data will be retained in a format which enables to identify the Data Subjects only until this is necessary for achievement of the purpose for which the Personal Data is processed. This means that if Profdiagnostik OÜ wishes to keep the Personal Data longer than is necessary due to the purpose of collection, Profdiagnostik OÜ will anonymise the data so that the Data Subject is no longer identifiable. For data held by Profdiagnostik OÜ received through a customer or other similar relationship, Profdiagnostik OÜ shall retain the data processed in accordance with the best practice and on the basis of the consent in general until the withdrawal of the consent.

3.3.7. Reliability and confidentiality. The processing of Personal Data shall take place in a manner that ensures appropriate security of the Personal Data, including protection against unauthorized or unlawful processing, accidental loss, destruction or damage using reasonable technical and organizational measures. Profdiagnostik OÜ has internal instructions, rules for employees, as well as separate agreements with each authorized processor, which provide best practices, continuous risk assessment and appropriate technical and organizational measures for the processing of Personal Data.

4. CONTENT OF PERSONAL DATA

4.1. Profdiagnostik OÜ collects the following types of Personal Data, among others:

4.2.1. Personal Data (e-mail address, telephone number) published by the Data Subject to Profdiagnostikk OÜ.

5. CONTENT OF PERSONAL DATA, OBJECTIVES AND GROUNDS FOR PROCESSING

5.1. Profdiagnostik OÜ Processes Personal Data exclusively on the basis of consent or law.

5.2. On the basis of consent, Profdiagnostik OÜ processes personal data exactly within the limits, to the extent and for the purposes specified by the Data Subject. In case of consents, the basic principle of Profdiagnostik OÜ is that each consent must be clearly distinguishable from other matters, and in an understandable and easily accessible form, in a clear and simple language. Consent has been given electronically. The Data Subject gives consent voluntarily, specifically, knowingly and unambiguously, for example by ticking a box on a website.

5.3. Legitimate interest means the interest of Profdiagnostik OÜ in the management and control of its own company to enable it to offer the best possible Services on the market. In particular, the processing of Personal Data on the basis of a legitimate interest may take place for the following purposes:

5.3.1. Sending reminders if the Customer has registered to use the Service;

5.3.2. Customer base management and analysis to improve the availability, selection, quality of Services and products;

5.3.3. Profdiagnostik OÜ uses the collected data for web analysis, operation, improvement, statistics and analysis of the Visitor’s behaviour and user experience.

5.4. Profdiagnostik OÜ processes Personal Data in order to fulfil the obligations provided by law or to apply the uses permitted by law. For example, there are legal obligations to process payments.

5.5. In case the Processing of Personal Data takes place for a new purpose than that for which the Personal Data was originally collected or is not based on the consent of the Data Subject, Profdiagnostik OÜ will carefully assess the permissibility of such new Processing.

6. DISCLOSURE AND/OR TRANSMISSION OF CUSTOMER DATA TO THIRD PARTIES

6.1. Profdiagnostik OÜ cooperates with persons to whom Profdiagnostik OÜ may transfer data related to Data Subjects, including Personal Data, within the framework and for the purpose of cooperation.

6.2. Such third parties may include marketing partners, e-operators conducting customer satisfaction surveys, payment default registers, (e-)postal intermediaries and organizations, provided that:

6.2.1. the respective purpose and Processing is lawful;

6.2.2. The processing of Personal Data takes place in accordance with the instructions of Profdiagnostik OÜ and on the basis of a valid contract.

7. SECURITY OF PERSONAL DATA PROCESSING

7.1. Profdiagnostik OÜ retains Personal Data for up to seven years or until the Customer’s consent is revoked. Personal Data that has expired will be destroyed using best practices.

7.2. Profdiagnostik OÜ has established instructions and internal rules on how to ensure the security of Personal Data through the use of organizational and technical measures.

7.3. In the event of any incident related to the Personal Data, Profdiagnostik OÜ will take all necessary measures to relieve the consequences and mitigate the relevant risks in the future. Among other things, Profdiagnostik OÜ registers all incidents and notifies the Data Protection Inspectorate and the Data Subject directly in the case provided for.

8. RIGHTS OF DATA SUBJECTS

8.1. Rights associated with consent:

8.1.1. The data subject has the right to notify Profdiagnostik OÜ at any time of his/her wish to withdraw his/her consent of the processing of Personal Data.

8.1.2.  The consent of the recipient of the reminder given to Profdiagnostik OÜ can be revoked from the link below the reminder.

8.2. When processing personal data, the Data Subject also has the following rights:

8.2.1. The right to receive information or the Data Subject’s right to receive information about the Personal Data collected about him/her;

8.2.2. The right to correct incorrect Personal Data;

8.2.3. The right of erasure. Only if the Customer has no valid reservations in the future.

8.2.4. The right to request restrictions on the Processing of personal data. This right arises, inter alia, if the Processing of Personal Data is not permitted by law or if the Data Subject disputes the accuracy of the Personal Data. The Data Subject has the right to demand a restriction on the processing of Personal Data for a period of time that allows the controller to verify the accuracy of the Personal Data or if the processing of the Personal Data is illegal, but the Data Subject does not request the erasure of the personal data;

8.2.5. The right to an assessment by the supervisory authority as to whether the processing of the Data Subject’s Personal Data is lawful.

9. EXERCISING RIGHTS AND SUBMITTING COMPLAINTS

9.1. Exercising of rights:

9.1.1. A Data Subject has the right to contact Profdiagnostik OÜ by e-mail helgi@tehnoulevaatus.ee in the event of a question, application or complaint related to the Processing of Personal Data.

9.2. Filing complaints:

9.2.1. A Data Subject has the right to file a complaint with Profdiagnostik OÜ, the Data Protection Inspectorate or a court if the Data Subject finds that the processing of Personal Data has violated his/her rights.

9.2.2. The contact details of the Data Protection Board (AKI) can be found on the AKI website at: http: //www.aki.ee/et/inspektsioon/kontaktid-nouandetelefon.

10. COOKIES AND OTHER WEB TECHNOLOGIES

10.1. Profdiagnostik OÜ may collect data about the Visitors of the Websites and other information society services using Cookies (i.e. small fragments of information stored by the Visitor’s browser on the Visitor’s computer or other device’s hard drive) or other similar technologies (e.g. IP address, device information, location information) and process this data.

10.2. Profdiagnostik OÜ uses the collected data to enable the provision of the Service in accordance with the Visitor’s habits; ensure the best quality of Service; make ads more relevant; facilitate login and data protection. Data collected is also used to count Visitors and record their usage habits.

10.3. Profdiagnostik OÜ Websites use session and third party cookies. A session cookie is automatically deleted after each visit; persistent cookies remain when using the Website repeatedly. Third Party Cookies are used by the websites of Profdiagnostik OÜ partners. Profdiagnostik OÜ does not control the occurrence of these cookies, so you can get information about these cookies from third parties.

10.4. Most web browsers allow Cookies. Without fully enabling Cookies, the functions of the Website will not be available to the Visitor. Enabling or disabling Cookies and other similar technologies is under the Visitor’s control through their web browser settings, information society service settings and such privacy enhancing platforms.

11. IMPORTANT DOCUMENTS, INSTRUCTIONS, PROCEDURES

11.1.  The application of the Privacy Policy of Profdiagnostik OÜ is based on the following documents, procedures, instructions: risk analysis, action plan, internal rules for processing of personal data, standard questions and answers, incident policy, privacy policy, infringement notification form, controller form, authorized processor form.

12. CONTACT DETAILS AND INFORMATION

12.1. Important contact information for the data subject of Profdiagnostik OÜ:

12.1.1. Profdiagnostik OÜ can be contacted for personal data questions at the e-mail address helgi@tehnoülevaatus.ee.

13. OTHER CONDITIONS

13.1. Profdiagnostik OÜ reserves the right to unilaterally change this Privacy Policy.

Profdiagnostik OÜ shall inform the Data Subject of the change on the website www.tehnoülevaatus.ee.