We’re here for you Privacy Policy 2018/19 Skeletor OÜ is the owner and, therefore, responsible for the projects indicated below, including any of their subdomains or sections (hereinafter, “Website” as corresponds): www.heldeke.ee www.heldeke.com This legal text applies to the information we collect from you when you visit our Website, as in the following cases: user registration, using any of our services, collaboration, subscription to our newsletters or personal information provided when filling in online forms. The present Privacy Policy regulates the processing of personal data belonging to the Website’s users (hereinafter, “User” or “Users”, as applicable) performed by Skeletor OÜ, collected through the use of the services offered on the Website (hereinafter, “Services”). By using and accessing our Website, the User acknowledges that they have read this Privacy Policy and that they fully agree with it. The latest update of this Privacy Policy is indicated at the top of this text and it will become effective immediately upon being posted. Heldeke! thus, recommends reviewing this Privacy Policy from time to time. Some of the Services offered on the Website may be subject to specific privacy policies that will supplement this general Privacy Policy or, in case they differ from the terms of this Privacy Policy, they will substitute the present Privacy Policy. These additional privacy policies must be accepted by the User before initiating the corresponding Service. PERSONAL DATA PROCESSING The following sections address the collection and processing of Users’ personal information through any of the projects run by Skeletor OÜ, including any of their subdomains and sections. 1. Data Controller Skeletor OÜ, as data controller, is responsible for the processing of Users’ personal information on the Website: Skeletor OÜ Registry code: 12912551 Address: Uus-Kalamaja tn 15b-5 Tallinn Harjumaa 10415 Email: dan@heldeke.ee 2. Data We Collect According to the EU General Data Protection Regulation (GDPR, 679/2016/UE), personal data refers to any information relating to an identified or identifiable natural person (User), that is, any information which can identify a natural person. Therefore, it is not applicable to anonymous data. Skeletor OÜ collects different types of personal data, which include: Identity Data: first name and last name. Contact Data: email address, telephone number and postal address. Technical Data: login information, language, Internet Protocol (IP) address, browser type and version, time zone settings, operating system, browser plug-in types and versions and other technical data used by the User when visiting the Website. Usage Data: information about how the User uses the Website, products, and services. Marketing and Communications Data: User’s preferences regarding marketing communications from Skeletor OÜ and information about enabling and disabling notifications. Data collected from Google apps – Google Docs: information collected from the searches made by the User on the Website without logging in, that is, by an anonymous user. We do not keep any personal data derived from these interactions. Skeletor OÜ does not collect any personal data related to sensitive categories (racial or ethnic origin, political opinion, religious or philosophic beliefs, membership in a union, health information and genetic or biometric data). In case the User is asked to provide personal data, by law or by contract terms, and chooses not to provide them, we may not be able to carry out the contract nor provide them with the service. If this is the case, the User will be notified in advance. Skeletor OÜ does not collect the age nor the date of birth of their Users. Consequently, a specific data treatment for minors has not been established. Skeletor OÜ is exclusively targeted to users of legal age. 3. How We Collect Data Skeletor OÜ collects data through different interactions, which include: 1. Browsing and using the Website: Generally, Users navigate our Website anonymously without revealing any personal data to Skeletor OÜ. When a User visits and uses our Website, it stores and collects information automatically using technologies or automatic tools. In general, this collected information is related to technical information about the device, browsing activity, and usage patterns. We collect this data through the use of Google Analytics and similar technologies. 2. Subscription to newsletters: When a User subscribes to our informative newsletter, Skeletor OÜ stores data. We use this data to send information, offers, promotional communications, and news about the events, happenings, and workshops organized by Skeletor OÜ, sponsors or third-parties, which provide services and products within the creative sector through newsletters or any other communication method (including e-mail and phone number). The User can choose not to receive this information at any moment through the user account or by sending an email to dan@heldeke.ee. 3. Information provided when using Google Extensions – Google Docs The User can navigate and access to some Google apps through our Website anonymously, as it is the case of Google Docs. In this case, The User will only need to sign in with their Google account and accept Google privacy policy, that you can find here. Any information provided to Freepik Company resulting from the use of Google Docs, will only be stored to ensure that the application functions properly. Under no circumstances will we collect nor store personal data of the Website’s User when using Google apps. 4. Our Purpose and Legal Basis of Data We Collect We mainly use personal data of our Website’s Users in the following cases: When the User agrees that their personal data can be collected Whenever it is required in compliance with legal obligations Whenever it is necessary to ensure the legitimate interest of Skeletor OÜ or third parties The User can withdraw their consent at any time by writing to dan@heldeke.ee or by consulting the section on the exercise of rights below. A summary table is provided below to show the different ways in which personal data can be used and the legal basis to process this information. COLLECTION OF DATATYPES OF DATAPURPOSELEGAL BASIS TO PROCESS DATA Visiting and using our Website Using Google apps Technical data Website’s usage patterns Improving our services and User’s experience Email * Name * * Required Promotional Communications: we will send communications if: The User requests for information through any of the forms available on the Website The User has not explicitly opted-out of receiving promotional communications 5. How We Keep Data We store personal information for as long as is needed to fulfill the purposes outlined in this privacy policy and, then, as long as it is permitted by applicable law. 6. Disclosure of Data Skeletor OÜ does not transfer nor share collected personal data with third parties external to the company. In addition, the Website may include extensions of Google apps, like Google Docs. Please notice that Skeletor OÜ does not collect personal data when using Google apps within the Website nor share it with third parties. We may disclose personal information of our Users to third parties only in cases when it is strictly necessary for Skeletor OÜ to perform their functions. We may also share personal information with other third parties to ensure compliance with applicable laws, including: Third parties with which Skeletor OÜ is compelled to share personal data, as permitted or required by law. These include professional advisers such as lawyers, auditors, legal and accounting consultancy services and financial institutions. Services provided by third parties are necessary for the development of Skeletor OÜ business activity. The processing of personal data is at all times subject to a contract which establishes the duties of the data processor towards the data controller. Under no circumstances will personal information be used for other purposes and it will be managed in compliance with Skeletor OÜ policy guidelines, their privacy policy and the applicable data protection regulation. Skeletor OÜ, in compliance with User privacy and data protection of Users, will only rely on service providers which adopt enough and proper technical and organizational measures to ensure that data processing complies with the applicable law regarding data protection and guarantee the protection of Users rights. 7. Rights of the User Skeletor OÜ guarantees the exercise of rights established in the General Data Protection Regulation 2016/679 (hereinafter, GDPR), that will start to be applicable on 25th of May, 2018. Please note that Skeletor OÜ may require the User to verify their identity before taking action on the request for the exercise of rights. The User has the following rights: Right to Access: The User has the right to obtain from Skeletor OÜ confirmation about whether or not personal data concerning them are being processed and, if that is the case, receive information about it. Right to Rectification: The User has the right to request us to correct personal data where it is inaccurate or incorrect. When requesting for rectification, the User must indicate the data to be rectified and provide the correct information. Right to Erasure: The User has the right to request the erasure of personal data concerning their personal subscription. Right to Object: The User has the right to object to the processing of their personal data by Skeletor OÜ at any time. In some cases, we may continue processing personal information because of legitimate grounds or for the exercise or defense of possible legal claims. Right to Restrict Processing: The User has the right to request the restriction of personal data where they have a particular reason for wanting the restrictions. The User has the right to request us to retain their personal data when: The processing is unlawful and the User opposes the erasure of the personal data and requests the restriction of their use instead Skeletor OÜ no longer needs the personal data for the purposes of the processing, but they are required by the User for the establishment, exercise or defense of legal claims. Right to Data Portability: The User has the right to request us a copy of the personal information provided to Skeletor OÜ in a structured form and of common and legible use. The user is also entitled to request that this information be sent to another service provider (where technically possible). Right to Withdraw Consent: In the cases in which the User has authorized their data processing, the User has the right to withdraw their consent at any time. The withdrawal of consent can be made effective by writing to dan@heldeke.ee, indicating specifically the consent they wish to revoke. Please note that revocation of consent does not affect the lawfulness of processing based on consent before its withdrawal. The User is responsible for updating their personal information. 8. Data Security Skeletor OÜ implements strong security controls to safeguard User’s personal information against loss, misuse, unauthorized access, disclosure or alteration. 9. Complaint Submission If you, the User, do not agree with the way Skeletor OÜ processes your personal data, you can contact us by sending an email to dan@heldeke.ee..