Salvest Privacy Policy

Here, you can find information on how we at Salvest AS (hereinafter Salvest) handle personal data. Our objective is to be a reliable partner that respects your rights.
1. DEFINITIONS
1.1 A Data Subject means a physical person for whom Salvest holds information, or information that can be used to identify a physical person. Data Subjects may include natural persons such as Customers, Visitors, partners and employees for whom Salvest holds personal data.
1.2 The Privacy Policy means this text, which lays out the principles for the Processing of Personal Data at Salvest.
1.3 Personal Data means any information about an identified or identifiable natural person.
1.4 The Processing of Personal Data is any act performed with the Data Subject’s Personal Data, such as collecting, storing, organising, storing, modifying and disclosing Personal Data, providing access, performing queries and retrieving, using, transmitting, cross-linking, merging, closing, deleting or destroying, or several of the aforesaid operations, regardless of the manner in which the operations are performed and the means used.
1.5 A Customer means any natural or legal person that uses or has expressed a wish to use Salvest’s Services.
1.6 An Agreement means a Service agreement or any other agreement entered into between Salvest and the Customer or a partner.
1.7 The Website means the Salvest website: http://www.salvest.ee/.
1.8 A Visitor means a person that uses/visits Salvest’s Website.
1.9 Services mean any type of service or product offered by Salvest.
1.10 Cookies mean data files that the Website sometimes stores on the Visitor's device.

2. GENERAL TERMS
2.1 Personal data may be processed by Salvest for the following purposes:
(1) defining the purposes and means of processing as the processor;
(2) as processor in accordance with the instructions of the processor;
(3) as a recipient to whom that Personal Data is transmitted.
2.2 This Privacy Policy Privacy forms an integral part of the Agreement entered into between Salvest and the Customer or a partner.
2.3 The Privacy Conditions apply to the Data Subject, and the rights and obligations specified in the Privacy Policy are the responsibility of all Salvest employees and cooperation partners who have contact with Personal Data held by Salvest.

3. PRINCIPLES
3.1 Salvest always processes Personal Data based on the interests, rights and freedoms of the Data Subjects.
3.2 Salvest’s objective is to be responsible for the processing of Personal Data, which is based on best practice, bearing in mind that it is always ready to demonstrate that the Processing of Personal Data meets the set objectives.
3.3 All of Salvest’s processes, instructions, operations, and activities related to the Processing of Personal Data are based on the following principles:
(1) Legality. There is a statutory basis for processing Personal Data, such as consent;
(2) Justice. This means in particular that the Data Subject has sufficient information and information on how the Personal Data are processed;
(3) Transparency. Processing of Personal Data is transparent for the Data Subject (i.e. the Data Subject can easily obtain information relating thereto);
(4) Purposefulness. Personal Data are collected for specified, explicit and legitimate purposes, and are not further processed in a way incompatible with those purposes;
(5) Minimisation, or the minimal processing of data. Personal data are relevant, significant and limited to what is necessary for the purpose for which they are processed. Salvest bases the Processing of Personal Data on the principle of minimal processing, and if Personal Data are not necessary or are no longer necessary for the purpose for which they were collected, the Personal Data are deleted;
(6) Fairness. Personal data are correct and, where necessary, up to date, and all reasonable steps have been taken to ensure that Personal Data are erased or corrected without delay for the purposes for which the Processing of Personal Data is being made;
(7) Restriction on storage. Personal data is stored in a form that permits identification of the Data Subjects for no longer than is necessary for the purpose for which the Personal Data is processed. For data that Salvest has received through a customer or similar relationship, Salvest retains the data processed in accordance with best practice and subject to general consent until the withdrawal of consent;
(8) Reliability and Confidentiality. Processing of Personal Data is carried out in such a way as to ensure appropriate security of the Personal Data, including protection against unauthorised or unlawful Processing and accidental loss, destruction or damage through reasonable technical or organisational measures;
(9) Default and integrated data protection. Salvest ensures that all systems used meet the required technical criteria. Appropriate data protection measures are designed to update or design every information and data system.
3.4 Salvest bases its Processing of Personal Data on the principle that it is always able to prove compliance with the aforementioned principles, and additional information can be requested from Salvest regarding adherence to these principles.

4. CONTENT OF PERSONAL DATA
4.1 Salvest does not actively collect the Personal Data of Clients or partners, but in some cases, Salvest has an interest or need to process personal data. The following types of Personal Data are processed by Salvest:
(1) Personal Data given by the data subject to Salvest;
(2) Personal Data resulting from the normal communication between the Data Subject and Salvest;
(3) Personal Data (including employment contracts) disclosed and arising within the framework of the performance of the Agreement between the Data Subject and Salvest;
(4) Personal data (e.g. in social media) which are clearly disclosed by the Data Subject;
(5) Personal Data resulting from the visit and use of the Website;
(6) Personal Data from third parties or persons working with collaborative materials (e.g. product campaigns);
(7) Personal data created and combined by Salvest (e-mail correspondence or order history lists, satisfaction and product quality information within the customer relationship).
5. CONTENT OF PERSONAL DATA, AND OBJECTIVES AND GROUNDS FOR PROCESSING

5.1 Salvest processes Personal Data exclusively if there is a suitable legal basis.
5.2 On the basis of this consent, Salvest will process Personal Data exactly within the limits, extent and purposes determined by the Data Subject. In the case of consents, Salvest is guided by the principle that each consent must be clearly distinguishable from other issues and in a clear and easily accessible form, in plain and simple language. Consent may be given in writing or by electronic means or as an oral statement.
5.3 Upon the conclusion and performance of the Contract, Processing of Personal Data may be further specified in a specific Agreement, but Salvest may process Personal Data for the following purposes:
(1) Pre-contractual measures at the request of the Data Subject;
(2) Customer identification to the extent required by due diligence;
(3) Fulfilment of the Customer's obligations regarding the provision of its Services;
(4) Communication with the Customer;
(5) Enforcement of the Customer's payment obligation;
(6) Claiming, realising and protecting claims.
5.4 In order to enter into a contract of employment, on the basis of a concluding the contract and a legitimate interest, the Processing of Personal Data of a candidate for a position at Salvest comprises the following:
(1) Processing of data submitted by the candidate to Salvest for the purpose of concluding an employment contract;
(2) the Processing of Personal Data received from the person nominated by the applicant as a reference;
(3) Processing of Personal Data collected from national databases and registers and from public (social) media.
If the candidate for employment is not elected, Salvest will keep the Personal Data collected for the employment contract only for 1 year in order to make a job offer to the candidate upon release of a suitable job position. Data related to participation in the Trainee Practice Program will be retained for 1 year in order to make a job offer.
5.5 Legitimate interest means Salvest's interest in administering and managing the company to provide the best possible Services on the market. Under the law, Salvest Processes Personal Data only after careful evaluation to determine that Salvest has a legitimate interest under which the Processing of Personal Data is necessary and in accordance with the data subject's interests and rights (after conducting a three-step test). In particular, the Processing of Personal Data may be based on legitimate interest for the following purposes:
(1) To ensure a trustworthy customer relationship / collaboration, such as Processing of Personal Data that is strictly necessary to identify actual beneficiaries or prevent fraud;
(2) Identifiers and Personal Information collected when using the Website, Salvest social media pages, mobile applications, and other Services. Salvest uses the collected data for web analysis or analysis of mobile and information society services, to guarantee work, to improve, to produce statistics and to analyse the visitor's behaviour and usage experience, and to provide a better and more personalised Service;
(3) Organising campaigns, i.e. carrying out personalised and targeted campaigns, conducting Customer and Visitor Satisfaction Surveys, and measuring the effectiveness of marketing activities;
(4) Analysing the behaviour of Customers and Visitors in different sales channels and on the Website;
(5) Monitoring service. Notices and orders given on site as well as through communication channels (e-mail, telephone, etc.), as well as information and other activities that Salvest has performed and, if necessary, used to verify Salvest operations or other transactions;
(6) Measures taken for network, information and cyber security, such as combating piracy and securing the Website and making and storing backups;
(7) For organisational purposes. In particular, for financial management and within Salvest’s internal transmission of Personal data within the Company, for internal administration purposes, including the Processing of Personal Data of Customers or partners or employees;
(8) For the preparation, filing or defence of legal claims;
(9) Salvest processes contact details of employees’ next of kin that the employee has communicated to Salvest for emergency situations, such as in case of an accident at work, to inform the next of kin or to perform a legal obligation, or strictly on the basis and within the limits of consent; (10) Salvest uses cameras in its premises to ensure safety and security.
5.6 In order to fulfil an obligation arising from law, Salvest Processes Personal Data for the performance of obligations provided by law or for uses permitted by law. For example, statutory obligations arise from processing payments or complying with money laundering rules. Salvest also has obligations arising from food safety requirements.

6. DISCLOSURE AND/OR TRANSMISSION OF CUSTOMER DATA TO THIRD PARTIES
6.1 Salvest co-operates with persons to whom data from Data Subjects, including Personal Data, may be transferred to Salvest within the framework of and for the purpose of co-operation.
6.2 Such third parties may include advertising and marketing partners, companies that conduct customer satisfaction surveys, debt collection service providers, payment default registers, ICT partners, i.e. providers of various technical services, billing service providers, provided that:
(1) the relevant purpose and Processing is legal;
(2) Processing of personal data is carried out in accordance with Salvest’s instructions and pursuant to a valid Agreement.
6.3 Salvest may, if necessary or by law, transmitted Personal Data to national authorities.
6.4 Salvest does not transmit Personal Data outside of the European Union. If in exceptional circumstances Personal Data is transferred outside of the European Union, this will be done only strictly in accordance with the relevant provisions of the General Data Protection Regulation on the transfer.

7. SECURITY FOR PROCESSING OF PERSONAL DATA
7.1 Salvest retains Personal Data only for the strict minimum of time. Personal Data for which the retention period has expired is destroyed using best practices and in accordance with the procedures established by Salvest.
7.2 Salvest has established guidelines and procedural rules to ensure the security of Personal Data, through the use of both organisational and technical measures.
7.3 In the event of any incident with respect to Personal Data, Salvest takes all necessary measures to limit the consequences and mitigate future risks.

8. PROCESSING OF CHILDREN’S PERSONAL DATA
8.1 Salvest does not ordinarily process children’s Personal Data.
8.2 Salvest does not knowingly collect information about persons under the age of 13, i.e. children, and we follow the wishes of the parent or guardian (for example, with the consent of the parent or the wish to use child-related rights or benefits).

9. DATA SUBJECT RIGHTS
9.1 Rights associated with consent:
(1) The Data Subject has the right at any time to notify Salvest of his wish to withdraw the Processing of Personal Data.
9.2 The Data Subject also has the following rights in the Processing of Personal Data:
(1) The right to receive information, i.e. the right of the Data Subject to receive information about the Personal Data collected about him.
(2) The right of access to data, Including the right of the Data Subject to a copy of Processed Personal Data.
(3) The right to correct inaccurate Personal Data. The data subject has the right to request the rectification of his Personal Data.
(4) The right to erasure of the data, meaning in some cases the Data Subject has the right to demand that the Personal Data be deleted, such as where Processing is performed only on the basis of consent.
(5) The right to restrict the Processing of Personal Data. This right arises inter alia where the Processing of Personal Data is not permitted by law or if the Data Subject contests the accuracy of the Personal Data. The Data Subject shall have the right to request that the Processing of Personal Data be restricted for a period of time that enables the controller to verify the accuracy of Personal Data or if the Processing of Personal Data is illegal, but the Data Subject does not request the deletion of Personal Data.
(6) The right to transfer data, i.e. the Data Subject has the right to receive Personal Data in a machine-readable form or in some cases to transfer it to another controller.
(7) Rights to automated Processing means that the Data Subject has the right, at any time, to object to the Processing of Personal Data that is based on automated decisions based on his specific circumstances. For the sake of clarity - Salvest can process Personal Data for automated business decision-making (e.g. in the marketing context for segmentation and personalised messages, initiating an employment relationship, and ensuring that our employees comply with our internal security rules). Automated Processing can also partly rely on data collected from public sources. You have the right to prevent any decisions based on the automatic Processing of Personal Data if they can be classified as profiling;
(8) The right to request a supervisory authority assess whether the processing of the Data Subject's Personal Data is lawful;
(9) The right to compensation for damage if the Processing of Personal Data has caused damage to the Data Subject.

10. EXERCISING RIGHTS AND SUBMITTING COMPLAINTS
10.1 Exercising rights:
(1) The data subject has the right to contact Salvest via the contact information listed in paragraph 13 in the case of a question, request or complaint related to the processing of Personal Data.
10.2 Submitting complaints:
(1) The Data Subject has the right to appeal to Salvest, the Data Protection Inspectorate or the court if the Data Subject finds that his rights have been violated when processing the Personal Data.
(2) The contact details of the Data Protection Inspectorate (AKI) can be found on the AKI website:: http://www.aki.ee/et/inspektsioon/kontaktid-nouandetelefon.

11. COOKIES AND OTHER WEB TECHNOLOGIES
11.1 Salvest may collect data about Visitors to the Website and other information services by using Cookies (i.e., small pieces of information stored by the Visitor's browser on the hard disk of the Visitor's computer or other device) or other similar technologies (e.g., IP address, device information, location information) and to process such data.
11.2 Salvest uses the data collected to provide the Service in accordance with the habits of the Visitor or the Customer; to secure the best quality of service; inform the visitor and the Customer of the content and make recommendations; make ads more relevant and improve marketing efforts; and facilitate login and data protection. The data collected is also used to enumerate Visitors and to determine their usage patterns.
11.3 Salvest uses session, permanent, and ad Cookies. A session Cookie is automatically deleted after each visit; permanent Cookies remain for the recurring use of the Website; and advertising and third-party Cookies are used by websites of Salvest’s partners that are linked to Salvest’s Website. These Cookies are not controlled by Salvest, therefore information about these Cookies is available from third parties.
11.4 As regards cookies, visitors agree to their use on the Website, in the settings of the information service or in the web browser.
11.5 Most browsers allow cookies. Without fully accepting Cookies, the Website features are not available to the Visitor. Enabling or disabling cookies and similar technologies is under the control of the visitor through their own web browser settings, information settings, and such privacy enhancement platforms (see Section 12: Important Documents, Instructions, Procedures).
12. IMPORTANT DOCUMENTS, INSTRUCTIONS, PROCEDURES
12.1 The following documents, procedures, instructions apply to the Salvest Privacy Policy:
(1) All About Cookies: Descriptions of cookies and other web technologies;
(2) Your Online Choices; About Ads; Network Advertising: A platform for checking and monitoring cookies and other web technologies that allows the Data Subject to change and control how Personal Data are used and collected.

13. CONTACT DETAILS AND INFORMATION
13.1 SALVEST contact details for Data Subjects:
You can contact SALVEST about personal data issues by e-mail at salvest@salvest.ee

14. OTHER CONDITIONS
14.1 Salvest reserves the right to unilaterally change this Privacy Policy. Salvest will notify the Data Subjects of the change on the Salvest Website or by e-mail or in some other format.