1.4. When processing personal data, the Company is based on the general regulation on the protection of personal data (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, and repealing Directive 95/46/EC (General Data Protection Regulation)), on the Personal Data Protection Act in force in the Republic of Estonia (hereinafter PDPA) and other applicable legislation.
2. Personal data to be collected and purposes of processing thereof
2.2. The Company processes the following personal data:
2.2.1. Identification data – Client’s name, personal identification number, identity document data;
2.2.2. Contact information – e-mail address, telephone number, postal address;
2.2.3. the data of the Client’s immovable property
2.2.4. Transaction data – data on the declarations of intent related to the contract, the content of the transaction, invoices, and payment information, as well as data on the execution of the contract;
2.3. Generally, the Company collects personal data from the Clients themselves. In certain exceptional cases, the Company may also collect personal data from publicly available sources. For example, the Company may collect data from the land register in justified cases.
2.4. The Company processes the Client’s personal data primarily for the following purposes:
2.4.1. To identify the Client or their representative;
2.4.2. By providing services to the Client or concluding contracts to fulfill the necessary obligations for performing activities and provision of advice;
2.4.3. To conduct pre-contractual negotiations or exchange pre-contractual information;
2.4.4. For the exchange of information related to the provision of services, the conclusion of contracts and economic activity, for the documentation of business activities (including the forwarding of information to fulfill the obligations imposed on the Company by legislation);
2.4.5. To improve and develop the quality of customer service;
2.4.6. To prepare and issue invoices;
2.4.7. To carry out activities essential for the Company’s economic activity (for example, contacting the owner of neighboring immovable property in connection with carrying out work on the Company’s immovable property, determining access to the acquired immovable property or logging rights, etc.);
2.4.8. To prepare, present or defend the Company’s legal claims, including the forwarding of personal data to a legal or lawyer’s office and a debt collection company;
2.4.9. To contact the Client and respond to the Client’s inquiries.
3. Legal basis for the processing of personal data
3.1. The processing of personal data is usually based on a contract concluded with the Client, the Client’s consent, a legal obligation, or the Company’s legitimate interest, which outweighs the Client’s interests and fundamental rights and freedoms.
3.2. The Company deals with forest management and also provides corresponding services. The Company processes personal data mainly for the preparation, conclusion, and execution of immovable property transfer transactions, logging right transfer transactions, or other forest management service contracts. The legal basis for the processing is Article 6(1)(b) of the GDPR. The Company may also process personal data to resolve possible disputes arising from the contract. The transfer of personal data for the preparation and execution of the contract is a necessary requirement for the conclusion of the contract. Without providing the requested personal data, the Company cannot conclude contracts with you.
3.3. The Company processes your personal data in order to make offers to you if you have given your consent to receive offers (Article 6 paragraph 1 pa of GDPR). You have the right to withdraw the consent at any time. In this case, we will stop processing your data starting from the withdrawal of the consent.
3.4. The Company may also process your personal data on the basis of consent in other cases. The purpose of processing is specified in the course of the process of giving consent. Any consent given for processing is voluntary, and you have the right to withdraw the given consent at any time.
3.5. The Company processes your personal data in order to fulfill the obligations arising from the legislation (Article 6 (1)(c) GDPR). Obligations stem from, for example, the Accounting Act, the Law of Obligations Act, and other applicable legislation. For example, the Company has tax reporting and accounting obligations, for the fulfillment of which your personal data will be processed and used. Including your personal data may be forwarded to the tax authority and other authorities, as well as to the auditor or legal advisors.
3.6. The Company processes your personal data due to the legitimate interest of the Company (Article 6 (1)(f) of the GDPR), including both in the interest of business operations and in the interest of security (detection of fraud). For example, the Company has a legitimate interest in storing all transaction data during the expiration period of claims arising from the contract for the purpose of protecting its rights. The Company also has a legitimate interest in contacting the owner of the neighboring immovable property in connection with the execution of works on the Company’s immovable property. On the basis of legitimate interest, the Company may also collect data about the existing/acquired immovable property or immovable property bordering the logging right and their owners, including identifying possible access routes to the immovable property.
3.7. The Company processes personal data only to the extent that is minimally necessary to achieve the purposes of the processing.
4. Storage of personal data
4.1. Arising from legislation, the Company has both the right and the obligation to store the collected personal data. The Company does not store personal data longer than it is necessary to fulfill the Company’s obligations unless you have given your consent for longer storage and processing of the data.
4.2. The Company treats all personal data as confidential information. The Company ensures the processing and storage of your data in the territory of the European Union.
4.3. The Company ensures the security of personal data processing in accordance with current legislation, including GDPR and PDPA. The protection of personal data is additionally regulated in the Company’s daily economic activities by the Company’s internal security rules.
4.4. Taking into account the latest developments in science and technology and the costs of implementation, and taking into account the nature, scope, context, and purposes of personal data processing, the Company implements appropriate technical and organizational measures to ensure the level of security corresponding to the threat.
4.5. In general, the Company will store your personal data for five years from the last deadline regarding the execution of the contract. The Company may store personal data for ten years from the last deadline regarding the performance of the contract if there is a reasonable suspicion of an intentional violation of obligations. According to the law, we store the data contained in the accounting documents for seven years.
4.6. In the event that the Company transfers personal data to another responsible processor (e.g., notaries, courts, banks, Environmental Board, Tax and Customs Board, etc.), the data storage terms are determined by the recipient of the data.
5. Client’s rights
5.1. In the cases stipulated by law, the Client has the right to:
5.1.1. Request from the Company access to personal data concerning the Client;
5.1.2. Receive information from the Company about the scope and use of the Client’s data processing;
5.1.3. Request correction and deletion of personal data;
5.1.4. Restrict the processing of personal data;
5.1.5. Object to the processing of personal data;
5.1.6. Submit a complaint to the data protection supervisory authority (Estonian Data Protection Inspectorate, www.aki.ee) or go to court;
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