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VANEREX OÜ PRIVACY POLICY

1. DEFINITIONS

1.1. The Data Subject is a natural person about whom Vanerex OÜ has information or information with which it is possible to identify a natural person. Data Subjects are, for example, individual Customers, cooperation partners and employees about whom Vanerex OÜ has Personal Data.
1.2. The Privacy Policy is this text, which sets out the principles of Vanerex OÜ Personal Data Processing.
1.3. Personal Data is any information about an identified or identifiable natural person.
1.4. Processing of Personal Data is any operation performed on the Data Subject’s Personal Data. For example: Collection, storage, organization, preservation, modification and disclosure, providing access, making inquiries and taking extracts, use, transmission, cross-use, connection, closure, deletion or destruction of personal data, or multiple of the above, regardless of the way in which the operations are carried out and the means used.
1.5. The Customer is any natural or legal person who uses or has expressed a wish to use the services of Vanerex OÜ.
1.6. The Contract is a Service provision or other agreement entered into between Vanerex OÜ and the Customer.
1.7. The Website www.vanerex.ee / www.vanerex.eu is the website of Vanerex OÜ.
1.8. The Visitor is a person who uses the Website of Vanerex OÜ.
1.9. A Child is a person under the age of 13 in the context of the Processing of Personal Data in the Republic of Estonia.
1.10. Services are all services and products offered by Vanerex OÜ.
1.11. Cookies are data files that are sometimes stored on the Website Visitor’s device.
1.12. Sales Channels are the ways of communication with the Data Subject used by Vanerex OÜ, a tool created for the sale of goods and the provision of Services. Incl. e-mail, telephone, public information and social media, various chat lines, personalized and interactive advertisements and other similar tools on Websites and elsewhere.
1.13. The Product Portfolio is Vanerex OÜ’s various products and Services, the composition of which is available on the Website: www.vanerex.ee / www.vanerex.eu.

In the Privacy Policy, the Contract, the General Terms and Conditions and the communication between the parties, the terms have the meanings given above.

2. GENERAL TERMS

2.1. The legal entity is Vanerex OÜ, registry code 12959966, located at Veemeistri tee 7, Haage, Tartumaa 61402.
2.2. Personal data may be processed by Vanerex OÜ:
2.2.1. as a controller, determining the purposes and means of processing;
2.2.2. as an authorized processor in accordance with the instructions of the controller;
2.2.3. as the recipient to the extent to whom the Personal Data is transmitted.
2.3. The Privacy Policy applies to the Data Subjects and all employees and cooperation partners of Vanerex OÜ who have contact with the Personal Data held by Vanerex OÜ proceed from the rights and obligations specified in the Privacy Policy.
2.3.1. The Privacy Policy may be amended or supplemented by privacy statements posted on the Website or on devices.

3. PRINCIPLES

3.1. Vanerex OÜ always proceeds from the interests, rights and freedoms of the Data Subjects when processing Personal Data.
3.2. All processes, instructions, operations and activities of Vanarex OÜ related to the Processing of Personal Data are based on the following principles:
3.2.1. Legality. There is a legal basis for Processing of Personal Data, such as consent;
3.2.2. Justice. The Processing of Personal Data is fair, in particular by requiring that the Data Subject has sufficient information and information on how the Personal Data is Processed.
3.2.3. Transparency. The Processing of Personal Data is transparent to the Data Subject.
3.2.4. Purposefulness. Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes.
3.2.5. Correctness. The Personal Data is correct and, if necessary, updated, and all reasonable measures have been taken to delete or correct the Personal Data that is incorrect for the purpose of the Processing of Personal Data.
3.2.6. Preservation restriction. Personal Data shall be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purpose for which the Personal Data are processed. This means that if Vanerex OÜ wishes to keep the Personal Data longer than is necessary due to the purpose of collection, Vanerex OÜ anonymises the data in such a way that the Data Subject is no longer identifiable. In the case of data received by Vanerex OÜ through a customer or other similar relationship, Vanerex OÜ retains the data processed in accordance with best practice and on the basis of consent until the consent is withdrawn.
3.2.7. 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 and against accidental loss, destruction or damage, using reasonable technical or organizational measures.

4. COMPOSITION OF PERSONAL DATA

4.1. Vanerex OÜ collects the following types of Personal Data, among others:
4.1.1. Personal Data published by the Data Subject (name, e-mail address, postal address, telephone number);
4.1.2. Personal Data arising as a result of normal communication between the Data Subject and Vanerex OÜ;
4.1.3. Personal Data obviously disclosed by the Data Subject (e.g. on social media);
4.1.4. Personal Data generated when consuming the Services (e.g. when purchasing from Vanerex OÜ e-store);
4.1.5. Personal Data generated as a result of visiting and using the Website (e.g. time spent on the Website);
4.1.6. Personal Data received from third parties;
4.1.7. Personal Data created and combined by Vanerex OÜ (correspondence within the customer relationship or a list of order history).

5. COMPOSITION OF PERSONAL DATA AND PURPOSES AND GROUNDS FOR PROCESSING

5.1. Vanerex OÜ Processes Personal Data exclusively on the basis of consent or law.
5.2. On the basis of consent, Vanerex OÜ Processes Personal Data exactly within the limits, to the extent and for the purposes specified by the Data Subject. In the case of consents, Vanerex OÜ proceeds from the principle that each consent must be clearly distinguishable from other issues, and in an understandable and easily accessible form, in clear and simple language. Consent may be given in writing or by electronic means or by oral statement. The Data Subject gives consent voluntarily, specifically, knowingly and unambiguously (for example, by ticking a box on the Website).
5.3. Legitimate interest means Vanerex OÜ’s interest in the management and administration of its company in order 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. To ensure a trusted customer relationship, such as the Processing of Personal Data, which is strictly necessary to identify the actual beneficiaries or to prevent fraud;
5.3.2. Customer base management and analysis to improve the availability, selection, quality of Services and products and to make more personal offers to the Customer;
5.3.3. Identifiers and Personal Data collected when using the Websites, Mobile Applications and other Services. Vanerex OÜ uses the collected data for web analysis or analysis of mobile and information society services, ensuring its operation, improvement, compiling statistics and analysing the Visitor’s behaviour and user experience, and providing a better and more personal Service;
5.3.4. Organization of campaigns, including organization of personalized and targeted campaigns, conducting Customer and Visitor satisfaction surveys and measuring the effectiveness of marketing activities performed;
5.3.5. Analysis of Customer and Visitor behaviour in different Sales Channels, Websites;
5.3.6. Service monitoring – Vanerex OÜ may record notices and orders given both at the premises of its location and by means of communication (e-mail, telephone, etc.), as well as information and other actions performed by Vanerex OÜ and, if necessary, uses these recordings to prove orders or other actions;
5.3.7. Network, information and cyber security considerations, such as measures to fight piracy and to ensure the security of the Websites and to make and store backups;
5.3.8. For the preparation, filing or defence of legal claims.
5.4. In order to fulfil an obligation arising from law, Vanerex OÜ Processes Personal Data in order to fulfil obligations provided by law or to implement the uses permitted by law. For example, the law imposes obligations when processing payments or following money laundering rules.
5.5. If 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 given by the Data Subject, Vanerex OÜ carefully assesses the admissibility of such new Processing.

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

6.1. Vanerex OÜ co-operates with persons to whom Vanerex OÜ may transfer data related to Data Subjects, including Personal Data, within the framework and for the purpose of co-operation.
6.2. Such third parties may include, for example:
persons intermediating or providing postal services, IT partners, debt collection service providers, default registers, institutions 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 Vanerex OÜ and on the basis of the valid Privacy Policy.

7. SECURITY OF PERSONAL DATA PROCESSING

7.1. Vanerex OÜ retains Personal Data only for the minimum necessary time. Personal Data, the retention of which is not necessary, shall be destroyed using the best practices and in accordance with the procedure established by Vanerex OÜ.
7.2. Vanerex OÜ has established instructions and rules of procedure on how to ensure the security of Personal Data through the use of both organizational and technical measures.
7.3. In the event of any incident related to the Personal Data, Vanerex OÜ will take all necessary measures to mitigate the consequences and mitigate the relevant risks in the future. Among other things, Vanerex OÜ registers all incidents and notifies the Data Protection Inspectorate and the Data Subject directly in the prescribed manner.

8. PROCESSING OF CHILDREN ‘S PERSONAL DATA

8.1. Vanerex OÜ does not knowingly collect information about persons under 13 years of age, i.e. Children, and in case of conscious activity in this regard, we follow the wishes of the parent or guardian.
8.2. If Vanerex OÜ learns that it has still collected Personal Data from or about a Child, Vanerex OÜ will do its best to terminate the Processing of such Personal Data.

9. RIGHTS OF THE DATA SUBJECT

9.1. Rights related to the consent:
9.1.1. The data subject has the right to notify Vanerex OÜ at any time of his / her wish to withdraw his / her consent to the Processing of Personal Data.
9.1.2. You can withdraw the consent of the recipient of the newsletter given by Vanerex OÜ from the link below the newsletter.
9.2. When processing personal data, the Data Subject also has the following rights:
9.2.1. to receive information about the Personal Data collected about him / her.
9.2.2. to get acquainted with the data which, among other things, includes the Data Subject’s right to a copy of the Personal Data to be processed.
9.2.3. correction of incorrect Personal Data.
9.2.4. deletion of data, i.e. in certain cases the Data Subject has the right to demand that the Personal Data be deleted, for example, if the Processing takes place only with the consent.
9.2.5. requiring Restrictions on the Processing of Personal Data. This right arises, among other things, if the Processing of Personal Data is not permitted on the basis of law or if the Data Subject disputes the accuracy of the Personal Data. The Data Subject has the right to demand that the Processing of Personal Data be limited to a time that allows the controller to verify the accuracy of the Personal Data or if the Processing of Personal Data is illegal, but the Data Subject does not request the deletion of personal data.
9.2.6. receiving an assessment from the supervisory authority as to whether the Processing of the Personal Data of the Data Subject is lawful.

10. EXERCISE OF RIGHTS AND SUBMISSION OF CLAIMS

10.1. Exercise of rights:
10.1.1. In the event of a question, application or complaint related to the Processing of Personal Data, the Data Subject has the right to contact Vanerex OÜ by e-mail: vanerex@vanerex.ee
10.2. Filing complaints:
10.2.1. The Data Subject has the right to file a complaint with Vanerex OÜ, the Data Protection Inspectorate or a court if the Data Subject finds that his or her rights have been violated during the Processing of Personal Data.
10.2.2. The contact details of the Data Protection Inspectorate (AKI) can be found on the AKI website at: https://www.aki.ee/en/contacts.

11. COOKIES AND OTHER WEB TECHNOLOGIES

11.1. Vanerex OÜ may collect data about the Visitors of the Websites and other information society services using Cookies (ie 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).
11.2. Vanerex OÜ uses the collected data in order to: enable the provision of the Service according to the habits of the Visitor or the Client; ensure the best quality of Service; to make the user experience of the Website more convenient for the Client; to inform the Visitor and the Client about the content and make recommendations; make ads more relevant and improve marketing; analyse Customer behaviour and thereby improve the online experience; facilitate login and data protection. The collected data is also used to count Visitors and to record their usage habits.
11.3 We use cookies in our e-store environment to identify users as unique but anonymous individuals.
11.4. Vanerex OÜ uses session, persistent and advertising cookies. The session cookie is automatically deleted after each visit; Persistent cookies remain after repeated use of the Website; Advertising cookies are used to deliver material suitable for the Visitor or to limit the number of times the same advertisement is seen on the Website. Third Party Cookies are used by the Websites of Vanerex OÜ partners. The origin of these Cookies is not controlled by Vanerex OÜ, therefore information about these Cookies can be obtained from third parties.
11.5. With regard to Cookies, Visitors agree to their use on the Website, in the settings of the information society service or in a web browser. If the Visitor does not wish to allow the use of Cookies on the Website, he / she may block them in the settings of his / her browser, use the option of private browsing or delete them completely using the instructions provided by the browser service provider.
More information about cookie management can be found on the following pages:

Chrome
Safari
iOS
Firefox
Internet Explorer

11.6. Most web browsers allow Cookies by default. Without Cookies fully enabled, the functions of the Website will not be fully available to the Visitor and there may be unforeseen problems with the functionality and user experience. Enabling, disabling or deleting Cookies and other similar technologies is under the control of the Visitor through their own browser settings, information society service settings and such privacy enhancing platforms.

12. CONTACT DETAILS AND INFORMATION

12.1. Contact details important for the Data Subject:
12.1.1. You can contact Vanerex OÜ for Personal Data questions at the e-mail address: vanerex@vanerex.ee.

13. IMPORTANT DOCUMENTS, INSTRUCTIONS, PROCEDURES

13.1. Vanerex OÜ has the right to unilaterally change this Privacy Policy. Vanerex OÜ notifies the Data Subjects on the Website www.vanerex.ee / www.vanerex.eu about the change. We assume that if you start using Vanerex OÜ’s Website www.vanerex.ee / www.vanerex.eu, you have read and agreed to the Privacy Policy.

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