1. General Provisions
1.1. This Privacy Policy governs the principles for the collection, processing, and retention of personal data. The controller responsible for the collection, processing, and retention of personal data is OÜ Aeternum Koolitus ja Konsultatsioonid (hereinafter the Controller).
1.2. For the purposes of this Privacy Policy, a data subject is a customer or any other natural person whose personal data are processed by the Controller.
1.3. For the purposes of this Privacy Policy, a customer is any person who purchases goods or services from the Controller’s website.
1.4. The Controller complies with the data processing principles set out in applicable legislation, including processing personal data lawfully, fairly, and securely. The Controller is able to confirm that personal data have been processed in accordance with the requirements of applicable law.
2. Collection, Processing, and Retention of Personal Data
2.1. Personal data collected, processed, and retained by the Controller are collected electronically, primarily via the website and email.
2.2. By sharing their personal data, the data subject grants the Controller the right to collect, organize, use, and manage the personal data disclosed by the data subject directly or indirectly when purchasing goods or services via the website, for the purposes set out in this Privacy Policy.
2.3. The data subject is responsible for ensuring that the data provided are accurate, correct, and complete. The intentional submission of false data is deemed a breach of this Privacy Policy. The data subject must promptly notify the Controller of any changes to the data provided.
2.4. The Controller is not liable for any damage to the data subject or third parties arising from the submission of false data by the data subject.
3. Processing of Customers’ Personal Data
3.1. The Controller may process the following personal data of the data subject:
3.1.1. First and last name;
3.1.2. Telephone number;
3.1.3. Email address.
3.2. In addition to the above, the Controller has the right to collect customer data that are available in public registers.
3.3. The legal basis for processing personal data is Article 6(1)(a), (b), (c), and (f) of the General Data Protection Regulation (GDPR):
a) the data subject has given consent to the processing of their personal data for one or more specific purposes;
b) processing 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;
c) processing is necessary for compliance with a legal obligation to which the controller is subject;
f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
3.4. Processing of personal data by purpose:
3.4.1. Purpose – security and safety
Maximum retention period – in accordance with the time limits set out in applicable law
3.4.2. Purpose – customer management
Maximum retention period – 7 years
3.4.3. Purpose – financial operations and accounting
Maximum retention period – in accordance with the time limits set out in applicable law
3.4.4. Purpose – marketing
Maximum retention period – 7 years
3.5. The Controller has the right to share customers’ personal data with third parties, such as authorized processors and accountants. The Controller is the data controller responsible for the processing of personal data.
3.6. When processing and retaining the data subject’s personal data, the Controller implements organizational and technical measures to protect personal data against accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.
3.7. The Controller retains data subjects’ data depending on the purpose of processing, but no longer than 7 years.
4. Rights of the Data Subject
4.1. The data subject has the right to access and review their personal data.
4.2. The data subject has the right to receive information about the processing of their personal data.
4.3. The data subject has the right to supplement or correct inaccurate data.
4.4. If the Controller processes the data subject’s personal data on the basis of the data subject’s consent, the data subject has the right to withdraw consent at any time.
4.5. To exercise their rights, the data subject may contact the e-shop customer support at koolitus@aeternum.ee.
4.6. The data subject also has the right to lodge a complaint with the Data Protection Inspectorate.
5. Final Provisions
5.1. These data protection terms have been prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council 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), the Personal Data Protection Act of the Republic of Estonia, and other applicable legislation of the Republic of Estonia and the European Union.
5.2. The Controller has the right to amend these data protection terms in part or in full by notifying data subjects of changes via the website https://www.aeternum.ee/.