DATA PROTECTION CONDITIONS
The Data Protection Conditions of IMG Numeri OÜ aim at protecting the personal data of data subjects in conformity with the legislation of the European Union and the laws of the Republic of Estonia. The Data Protection Conditions proceed in particular from Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and in addition, from the Personal Data Protection Act and these personal data protection instructions.
1.1 Data subject: a natural person, on which IMG Numeri OÜ holds information or, the information, which can be used to identify the person. Data subjects are for example clients who are natural persons, visitors, cooperation partners and employees, on whom IMG Numeri OÜ holds personal data.
1.2 Personal data: any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.3 Personal data processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
1.4 Data controller: a natural or legal person, public sector authority, agency or other body which, alone or jointly with others, determines the purposes and means of the personal data processing.
1.5 Data processor: a natural or legal person, public authority, agency or any other body which processes personal data on behalf of a data controller.
1.6 Personal data breach: a breach of security leading to accidental or unlawful destruction, loss, alternation, unauthorised disclosure of or access to, personal data transmitted, stored or otherwise processed.
2. GENERAL PROVISIONS
2.1 IMG Numeri OÜ is a legal person with registry code 10203098, located at Sõpruse pst 145, 13417 Tallinn, Estonia
2.2 IMG Numeri OÜ may process personal data:
2.2.1 as a data controller, defining the purposes and means of processing;
2.2.2. as a data processor following the instructions of the controller.
2.3 Only persons authorised by IMG Numeri OÜ have access for changing and processing personal data. IMG Numeri OÜ follows the principle of maintaining the confidentiality of personal data and discloses personal data only within strictly limited extent in order to ensure protection of the personal data.
3.1 All activities relating to the processing of personal data proceed from the following principles:
3.1.1 lawfulness, fairness and transparency: personal data are processed lawfully, fairly and in a transparent manner in relation to the data subject;
3.1.2 purpose limitation: personal data are collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
3.1.3 data minimisation: the personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
3.1.4 accuracy: personal data are accurate and, where necessary, kept up to date; every reasonable step is taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
3.1.5 storage limitation: personal data are kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
3.1.6: integrity and confidentiality: personal data are processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
4. COMPOSITION OF PERSONAL DATA
4.1 Data disclosed by the data subject to IMG Numeri OÜ:
4.1.1 personal data (name and surname, personal identification number, date of birth, place of birth);
4.1.2 contact information (address, phone number, e-mail address);
4.1.3 financial data (salary data, bank account number; taxation data);
4.1.4 other data (qualification, education, hobbies, language skills, data on the sick days, data on holidays, data on third parties connected with the data subject, data containing special categories of personal data of the data subject).
4.2 Personal data created as a result of ordinary communication between the data subject and IMG Numeri OÜ and as a result of provision of service (incl. data of client’s employees, client data).
4.3 Personal data created as a result of visiting and using the website (cookies, log data of website with IP addresses).
5. GROUNDS AND PURPOSES OF PERSONAL DATA PROCESSING
5.1 IMG Numeri OÜ processes the personal data on the basis of the consent of the data subject, for the performance of a concluded contract or for preparatory measures prior to the conclusion of the contract pursuant to the data subject’s application, for compliance with a legal obligation or in case of legitimate interest.
5.2 Consent of the data subject: on the basis of the consent, IMG Numeri OÜ processes the personal data within the extent and for explicit purposes as determined by the data subject. The data subject shall give his or her consent for personal data processing freely, specifically, knowingly and unambiguously.
5.3 Entering into and performance of an agreement to which the data subject is party: processing of personal data is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. For example, processing of personal data may be necessary upon the establishment of customer relationship and entering into service agreements for providing the bookkeeping service, payroll service, tax consulting service, legal address service, contact person service, administration of customer’s documents.
5.4 Compliance with a legal obligation: processing of personal data for compliance with legal obligations is conducted only in the event that IMG Numeri OÜ is obligated to process the personal data, since this is requested from the company by applicable law. For example, such obligation may arise from Employment Contracts Act, Money Laundering and Terrorist Financing Prevention Act (e.g. for due diligence of customer), Auditors Activities Act or Accounting Act.
5.5 Legitimate interest: for the purpose of providing high-quality services and promoting business activity, IMG Numeri OÜ may process the personal data of the data subject, respecting the data subject’s fundamental rights and freedoms. IMG Numeri processes the personal data on the grounds arising from law only after careful assessment in order to establish that IMG Numeri OÜ has a legitimate interest, on the basis of which processing of personal data is necessary and in conformity with the interests and rights of the data subject.
6. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
6.1 IMG Numeri OÜ may transfer personal data within the provided service or pursuant to law within strictly limited extent to third parties (e.g. a notary, translation office, Tax and Customs Board, Unemployment Insurance Fund, Health Insurance Fund, Data Protection Inspectorate, auditors, Financial Intelligence Unit) for providing a higher-quality service.
6.2 IMG Numeri OÜ transfers the personal data of data subjects to third countries or international organisations only if sufficient safeguards have been implemented.
7. RIGHTS OF THE DATA SUBJECT
7.1 The right to withdraw the consent at any time. The data subject shall have the right to withdraw his or her consent at any time, where processing of personal data is based on consent. This does not affect the legality of data processing conducted before withdrawal of the consent.
7.2 Right to receive information. The data subject has a right to receive information on the personal data gathered on him or her. It is possible to receive information from IMG Numeri OÜ on the processing of personal data by sending a written request by e-mail at firstname.lastname@example.org.
7.3 Right of access. The data subject has a right to access his or her personal data and receive a copy of the personal data undergoing processing.
7.4 Right to rectification. The data subject shall have the right to have the inaccurate personal data corrected and completed.
7.5 Right to be forgotten. In certain cases, the data subject has a right to demand erasure of personal data and IMG Numeri OÜ shall be committed to erase the personal data without undue delay where one of the following grounds applies:
7.5.1 the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
7.5.2 the data subject withdraws consent given for the processing and where there is no other legal ground for the processing of personal data;
7.5.3 the data subject objects to the processing of personal data and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing;
7.5.4 the personal data have been unlawfully processed;
7.5.5 the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which IMG Numeri OÜ is subject;
7.6 Right to restriction of processing. The data subject shall have the right to demand restriction of processing of personal data in the following cases:
7.6.1 the accuracy of the personal data is contested by the data subject, for a period enabling IMG Numeri OÜ to verify the accuracy of the personal data;
7.6.2 the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
7.6.3 IMG Numeri OÜ no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
7.6.4 the data subject has objected to processing the personal data pending the verification whether the legitimate grounds of IMG Numeri OÜ override those of the data subject.
7.7 Right to data portability. In certain cases the data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to IMG Numeri OÜ, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
7.8 The right to object. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her conducted for the performance of a task carried out for reasons of public interest or in the event of a legitimate interest of IMG Numeri OÜ or a third person. IMG Numeri OÜ shall no longer process the personal data unless IMG Numeri OÜ demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
8. RETENTION OF PERSONAL DATA
8.1 IMG Numeri OÜ keeps the personal data in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed, unless IMG Numeri OÜ has a legal requirement stipulating different time limits for the storage of personal data:
8.1.1 accounting documents must be retained in conformity with the Accounting Act;
8.1.2 data gathered under the Money Laundering and Terrorist Financing Prevention Act shall be retained pursuant to the law.
8.2 If the job applicant was not elected during recruitment, the CV of the data subject shall be retained for one year as of making the negative decision. The personal data of a job applicant who was not elected shall be deleted after one year has passed from the submission of the job application.
8.3 IMG Numeri OÜ shall destroy and/or delete securely all personal data, the purpose of retention of which does not exist or the retention period of which has expired.
9.2 Cookies are small text files saved by the website in the computer or mobile device of the data subject, to retain information about the visit to the site. The visitors of the IMG Numeri OÜ website are deemed to have consented to the cookies, if the visitor has permitted cookies in his or her browser settings.
9.3 Cookies are used based on the legitimate interest to guarantee the functioning of the website as intended. For cookies used in other cases, we shall proceed from the visitor’s consent on the website.
9.4 IMG Numeri OÜ uses different types of cookies.
9.4.1 Session cookies are saved only for the time of visiting the website and are deleted automatically after each visit. IMG Numeri OÜ uses session cookies for the purpose of statistics and analysis and for remembering the language preferences.
9.4.2 Permanent cookies continue to exist if the website is used repeatedly and are used for user statistics and analysis.
10. EXERCISING OF RIGHTS AND FILING OF COMPLAINTS
10.1 Exercising of rights: The data subject has a right to contact IMG Numeri OÜ in case of questions, requests or complaints relating to the processing of personal data.
10.2 Filing of complaints:
10.2.1 If the data subject is of the opinion that the processing of their personal data has violated their rights, the data subject has the right to file this claim to IMG Numeri OÜ, the Data Protection Inspectorate or a court.
10.2.2 The contact information of the Data Protection Inspectorate is available on the webpage: https://www.aki.ee/et/inspektsioon-kontaktid/tootajate-kontaktid.
11. CONTACT INFORMATION
All questions and proposals concerning the processing of personal data may be referred to the following contacts:
IMG Numeri OÜ
Sõpruse pst 145