Processing of personal data

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APPENDIX GF ANAPOL OÜ Data Usage Principles

1. General

1.1. The Data Usage Principles (Principles) apply to GF Anapol OÜ (hereinafter: Anapol) and any person using Anapol's Services or e-Environment.

1.2. The Principles define how Anapol may use the Client's Data in connection with providing Services and offering e-Environments, and provide information on important issues related to Data usage.

 

2. Definitions

2.1. Client – any person using Anapol's Service or e-Environment as a Client or User;

2.2. Data – personal data, communication data, or other data related to the Client that Anapol becomes aware of in connection with providing Services or using the e-Environment;

2.3. Anonymous data – information that cannot be linked to a specific client because identifying information has been removed from the data;

 

3. Anapol's Data Protection Principles

3.1. Anapol uses Data in the manner specified in the Principles and solely for the purpose for which the Data was collected, and to the extent necessary to fulfill that purpose. Anapol adheres to the Electronic Communications Act, the Personal Data Protection Act, and other laws (hereinafter: Legal Acts), as well as good business practices when using Data. Anapol may combine Data collected in connection with different Services if the Data was collected for the same purpose.

3.2. Anapol highly values the privacy and protection of Client Data, using organizational, physical, and IT security measures necessary to ensure the integrity, availability, and confidentiality of Data. These measures include the protection of employees, information, IT infrastructure, internal and public networks, office buildings, and technical equipment. The aim of security activities is to apply an appropriate level of protection for information, mitigate risks, and prevent threats.

3.3. Anapol employees are subject to confidentiality and data protection obligations and are responsible for fulfilling these duties. Authorized data processors of Anapol are required to ensure the same rules for their employees and are responsible for compliance with data usage requirements.

 

4. Client's Role in Ensuring Data Security

4.1. The Client must use Services and e-Environments securely and carefully, ensuring that devices (e.g., computer, smartphone, application, etc.) used to access Anapol's Services or e-Environment are secure. The Client must keep passwords, usernames, and any other identifying information (e.g., ID card or Mobile ID) confidential and protected from unauthorized access.

4.2. The Client must be aware that Anapol cannot guarantee Data security if the Client fails to meet the obligations stated in point 4.1 (e.g., unauthorized use of the Client's ID card, Mobile ID, or PIN codes). The Client is responsible for any consequences arising from such breaches.

 

5. Data Collection

5.1. Anapol offers a variety of Services and e-Environments. The scope of Data collected by Anapol depends on the specific Services or e-Environments used, the Data required for providing those Services, the Data voluntarily provided by the Client, and the consents given for Data processing.

5.2. Anapol collects Data as follows:

    5.2.1. Data is collected when ordering goods, registering as a Client, subscribing to newsletters, or making inquiries to Anapol;

    5.2.2. Data may also be obtained from other sources (e.g., service providers or public registers) if necessary for fulfilling a contract or with the Client's consent.

 

6. Use of Data for Fulfilling and Ensuring Contracts

6.1. Anapol may use Data without separate consent for contract fulfillment or assurance, including:

    6.1.1. Identification of the Client or their representative;

    6.1.2. Performing activities necessary for providing Services or selling goods;

    6.1.3. Preparing and sending notices and invoices related to the contract;

    6.1.4. Sending contract-related notifications by mail that are not marketing-related;

    6.1.5. Documenting business operations and exchanging business information;

    6.1.6. Improving Services and measuring customer satisfaction;

    6.1.7. Maintaining and repairing Client devices;

    6.1.8. Recording and storing phone calls for verifying agreements and better customer service;

    6.1.9. Assessing and mitigating business risks and losses;

    6.1.10. Protecting rights and collecting debts related to breaches;

    6.1.11. Assessing Client creditworthiness for financing decisions;

    6.1.12. Sharing overdue payment information with authorized credit institutions.

 

7. Use of Data for Marketing Purposes

7.1. Data may be used to send personalized offers electronically (email, SMS, MMS) if consent is provided.

7.2. Clients can give consent for marketing use during contract signing or through the e-Environment.

7.3. With consent, Anapol may:

    7.3.1. Analyze preferences to improve services;

    7.3.2. Develop personal direct marketing offers;

    7.3.3. Send promotional offers electronically;

    7.3.4. Provide customized content in the e-Environment.

 

8. Sending Offers Electronically

8.1. Clients may opt out of electronic offers at any time via provided instructions.

 

9. Use of Authorized Processors

9.1. The responsible data processor is GF Anapol OÜ, registration code 10026704, address Allka tee 14, Peetri alevik, 75312 Rae vald.

9.2. Authorized processors handle billing, fraud detection, customer support, and marketing under confidentiality agreements.

 

10. Data Retention Period

10.1. Data is retained as long as necessary for achieving the stated purpose or as required by law.

 

11. Client Rights Regarding Data

11.1. Clients have the right to:

    11.1.1. Access their Data;

    11.1.2. Request correction or deletion of Data;

    11.1.3. Object to marketing use;

    11.1.4. Contact the Data Protection Inspectorate or court for violations.

 

12. Contacting Anapol

12.1. Clients can contact Anapol at 638 0464 or info@keevitus.ee.

 

13. Use of Cookies in Anapol's e-Environments

13.1. Like most websites, Anapol's e-Environment uses cookie technology. Cookies are small text files that are downloaded to the user's computer via the e-Environment server. As a result, the web browser can send cookie information back to the e-Environment during each use, allowing the user to be recognized without identifying them (anonymously) and providing a more personalized and convenient user experience (e.g., saving user preferences and interests). Cookies are also used to analyze and improve the services offered in the e-Environment, as well as to deliver targeted offers and advertisements.

 

This version of the Data Usage Principles comes into effect for Anapol and all Clients on April 17, 2018. Anapol reserves the right to unilaterally change the Data Usage Principles in accordance with the General Terms and Conditions.