Policy and principles of data processing of Buyers (Clients) of OÜ InterVacTechnology
1. General provisions
1.1 This Policy (hereinafter referred to as the provision, agreement) applies to all information (including personal data) that OÜ InterVacTechnology (as an operator, organization, company) can receive about the client (hereinafter referred to as the user, visitor, subject) and other persons during their use of the site, and OÜ InterVacTechnology services, as well as within the framework of business and other cooperation (hereinafter referred to as services).
1.2 The basis for processing customer data of OÜ InterVacTechnology is Regulation of the European Parliament and of the Council of the European Union 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, as well as repealing Directive 96/95/46/EC (General Data Protection Regulation / GDPR), other relevant legal acts, including the Personal Data Protection Act, instructions of Data Protection Inspectorate and the European Union’s Data Protection Expert Group WP29, and generally accepted business practices.
1.3 This Policy defines the procedure for processing personal data and measures to ensure their security by the operator for the purposes established by this policy. This policy is a publicly available document that declares the basics of the organization’s activities in data processing and protection.
1.4 The operator of customer personal data, responsible processor – OÜ InterVacTechnology (hereinafter-the operator, organization).
1.5 Information resource of the data processor – https://intervactechnology.com/ (hereinafter referred to as the site).
1.6 The regulations are published on the OÜ InterVacTechnology website for general access, stored at the company’s address and can be sent to interested parties upon request.
1.7 The user fills in personal data and must express his “consent” to further processing of data in accordance with the current Regulations when filling out the feedback form and/or the order form on the website.
1.8 The main sources of personal data and information are: documents provided by subjects, a website, a feedback or order form, telephone conversations, official e-mail, feedback forms at exhibitions.
1.9 OÜ InterVacTechnology collects and stores only the personal information that is necessary for the provision of services or the execution of agreements and contracts, except in cases where the law provides for mandatory storage of personal information for a period specified by law.
1.10 Personal data of subjects is kept confidential, except in cases when the subject voluntarily provides information for general access to an unlimited number of persons and in cases established by law.
1.11 OÜ InterVacTechnology has the right to transfer the subject’s personal data to third parties if the transfer is provided for by applicable law within the framework of the procedure established by law.
1.12 These principles are general; additional and / or clarifying terms and conditions, as well as information about confidentiality, may also be contained in contracts, documents, forms and on the company’s website. The Principles are an integral part of their general terms and conditions for the provision of services. The site allows the client to get acquainted with the Principles at the stage of organizing cooperation. The Principles are part of all contracts, and OÜ InterVacTechnology has the right to assume that the client is aware of the Principles and has read them.
1.13 If the client considers that his data is not processed in accordance with the applicable rules and/or the law, he has the opportunity to contact the InterVacTechnology at sales@intervactechnology.com. This possibility does not affect the client’s right, if necessary, to apply also to the Data Protection Inspectorate supervising data protection or to the court.
2. Purpose and principles of customer data processing
2.1 The principles of processing customer data of OÜ InterVacTechnology apply to the company, its employees and customers.
2.2 The guidelines set out how OÜ InterVacTechnology can use the client’s data when communicating with them, and also provide information on important issues related to the use of data.
2.3 Purposes and principles of collecting and processing personal information when working with personal data:
2.3.1 OÜ InterVacTechnology collects, processes and stores only the personal information that is necessary for the provision of the Services.
2.3.2 The company uses the User’s personal information for the following purposes:
2.3.2.1 identification of the subject within the framework of cooperation;
2.3.2.2 fulfillment of agreements and conditions of concluded contracts;
2.3.2.3 delivery of goods (hereinafter referred to as “products”);
2.3.2.4 providing effective customer support;
2.3.2.5 informing about ongoing events and promotions;
2.3.2.6 conducting statistical and other research;
2.3.2.7 improving the usability of the site, improving the quality of the site, developing new offers and services, creating a user profile;
2.3.2.8 providing an opportunity to contact the person who placed the request on the site, and providing them with personalized services, information, and other valuables;
2.3.2.9 detection, prevention, mitigation of consequences and investigation of fraudulent or other illegal actions against the Operator;
2.3.2.10 for other legitimate purposes.
2.4 OÜ InterVacTechnology, due to the specifics of the method of obtaining information, does not verify the accuracy of the personal information provided by the User and does not control its relevance.
The User provides reliable personal information and keeps this information up-to -date . All responsibility, as well as possible consequences for providing false or not up-to-date personal information, is borne by the User.
2.5 Principles of personal data processing:
- processing of personal data is carried out on a legal and fair basis;
- the processing of personal data is limited to the achievement of specific, pre-defined and legitimate purposes;
- processing of personal data incompatible with the purposes of personal data collection is not allowed;
- it is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other;
- only personal data that meet the purposes of their processing are subject to processing;
- the content and scope of the personal data processed corresponds to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed;
- the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing are ensured when processing personal data. The necessary measures are taken or their adoption is ensured to delete or clarify incomplete or inaccurate personal data;
- storage of personal data is carried out in a form that makes it possible to determine the subject of personal data, no longer than the purposes of processing personal data require, if the period of storage of personal data is not established by law, an agreement to which the subject of personal data is a party, beneficiary or guarantor;
- the processed personal data is destroyed or depersonalized when the processing objectives are achieved or when it is no longer necessary to achieve these objectives, unless otherwise provided by law.
3. Terms and concepts
3.1 OÜ InterVacTechnology uses concepts in the meanings defined in the General Data Protection Regulation.
3.2 A customer is a person who has concluded an agreement with OÜ InterVacTechnology or has provided his data, as well as expressed a desire to register as a client or receive an offer to conclude an agreement, clarify information about the Product, but has not concluded an agreement.
3.3 Data is all data of the OÜ InterVacTechnology client that allows it to be directly or indirectly identified, selected, correlated or calculated.
3.4 Client data processing is any operation performed with the client’s data.
3.5 Anonymous data is information that cannot be linked to a specific Customer, because identifying information has been removed from the data.
3.6 Policy, agreement, regulation, principles – this regulation governing the relations of the Company InterVacTechnology and the client, the user throughout the entire period of cooperation and the provision of User access to the personalized services of the Site and services of the Company InterVacTechnology.
3.7 Data processing security is defined as the application of appropriate physical, organizational, and information technology security measures. These measures include protecting employees, IT infrastructure, and office buildings and technical equipment.
3.8 The purpose of taking measures is primarily to combat threats and reduce risks emanating from both individuals and technologies. To ensure the adoption of measures, mandatory internal regulations of the enterprise have been introduced, the necessary software has been installed, etc. Employees are subject to confidentiality and data protection requirements, and employees are responsible for meeting these requirements. Trusted data processors of Interface Technology are obliged to ensure that their employees comply with the same rules and are responsible for meeting the requirements for the use of data.
4. Client functions in data processing
4.1 The Client must use the services and electronic environments safely and carefully and ensure that the devices (such, as a computer, smartphone, etc.) that the Client uses to receive the services or work with the electronic environment of OÜ InterVacTechnology are protected.
4.2 The Client is obliged to keep secret from other person’s personal information related to the Client, his device, service or electronic environment, usernames and passwords or other identification information or data carriers.
4.3 The Client should know and take into account the fact that OÜ InterVacTechnology cannot ensure Data security and is not responsible if the Data is not protected due to the Client’s violation of the obligation specified in clause 4.1.-4.2. In this case, the Client is responsible for all possible consequences for him.
4.4 If the Client allows the user (for example, a family member, employee of the Client, his deputy, colleague, etc.) to use the services or the electronic environment on the basis of a contract concluded between the Client and OÜ InterVacTechnology, the Client is responsible for ensuring that the User is familiar with the Principles and agrees with them.
5. Data collection process
5.1 OÜ InterVacTechnology provides the Client with an information and electronic environment to get acquainted with the products and interact with the company. The composition of the collected Client’s Data depends on what specific services, actions, or electronic environments the Client uses, what Data is required for this purpose, to what extent does the Client transfer Data to the company for this purpose (for example, when ordering Goods, when registering on the site by the user, when leaving information in the feedback form, etc.), as well as what consents the Client gives regarding data processing.
5.2 The main data that the company collects include, for example: first and last name, first name of the user and other related information, country of origin, email address, information about the organization that the person represents, legal address, details of the legal entity, information about ordered and purchased Goods or products , etc. This includes a static IP address, domain name or serial number of the device, account information (for example, account address, link number, billing address, etc.), payment data, contact information, etc., as well as data collected in electronic environments during the Client’s use of the services.
5.3 Depersonalized data is data that is not associated with any particular Customer, but which, however, the company must also process for the delivery of goods and other purposes. Depersonalized data is, for example, data collected during the use of websites or services by customers who are depersonalized for the company.
5.4 OÜ InterVacTechnology collects Data in the following ways:
5.4.1 The Company receives Data from the Client, for example, in connection with a Product order, Customer registration, information request, etc.
5.4.2 Data arises when the Client uses the services and when
it is necessary for the performance or enforcement of the contract, if such Data processing is provided for by legal acts or the basis for Data processing is the Client’s consent.
5.4.3 The Company also receives Data related to the Client from other sources (for example, from suppliers, contractors, partners, or open registers, etc.), if this Data is necessary for the performance or enforcement of the contract, such Data processing is provided for by legal acts or the basis for Data processing is the Client’s consent.
6. Data and performance of contractual and other obligations
6.1 Data is collected for the following purposes:
6.1.1 To establish the identity of the Client and his representative.
6.1.2 To perform the necessary actions in connection with the sale of goods (including for the sale and delivery of goods and/or for transmitting information about the product to the Client).
6.1.3 For customer service and troubleshooting.
6.1.4 To develop and provide the electronic environment, its services and functionality to the Client, as well as for ease of use and personalization, as well as for transmitting information related to the use and security of the electronic environment to the Client.
6.1.5 To calculate payments for services related to the contract, to compile and send messages and invoices to the Client.
6.1.6 To send the contract and/or Product-related information to the Client by mail/e-mail.
6.1.7 For documenting business and service activities, and for sharing business information (including providing it to auditors during audits).
6.1.8 For better customer service, including improving the quality of the electronic environment and services, measuring user activity or customer satisfaction, and developing commercial activities.
6.1.9 For the maintenance and repair of Goods purchased by the Customer’s order and other actions related to post-service activities.
6.1.10 To record and store telephone conversations with the Client in order to use these records to confirm the submitted will or completed transactions and to better serve the Client.
6.1.11 To reduce commercial risks associated with the provision of services or to assess and prevent damages.
6.1.12 To ensure the performance of the contract (for example, to establish a pledge, enter into a guarantee agreement, etc.).
6.1.13 For protection of violated or disputed rights of the company and collection of debts (including for transfer by the company on the basis of a contract for the processing of relevant Data to authorized persons providing services, lawyers, etc. in connection with the violation of the contract and/or debt).
6.1.14 To assess the Client’s payment ability and availability (payment behavior) (including making a decision on deferred payment, installment payments, and prepayment).
6.1.15 For sending periodic newsletters, including for the purpose of familiarizing Customers with new Products and offers. The Client can cancel newsletters at any time without giving reasons, notifying the company about this.
6.1.16 To improve user experience by requesting customer feedback on Products and collaboration processes, and using them to compile statistics and conduct research. The client gives feedback voluntarily.
6.1.17 To improve and develop technical and IT systems, as well as the information environment, including for preventing and resolving security-related incidents.
6.1.18 For analyzing fault statistics, sales, etc.
6.1.19 For general profiling of customer groups.
6.1.20 To resolve claims and prevent fraud cases.
6.1.21 To fulfill obligations arising from the accounting and tax laws.
6.1.22 For payment operations.
6.2 The above list of uses of Contract Enforcement Data is not exhaustive. This means that for the performance of the contract, the company may also use the Data for any purpose not specified in clause
6.1, if necessary.
6.3 Basic Customer data – data related to customer relations: details of contracts concluded by the Customer, orders made and customer contacts, details, addresses, accounts and related information (for example, payment details, etc.), information entered by the Customer into the electronic environment (including, for example, data entered when registering an account or feedback form), data on the use of the electronic environment, its functions and data collected using cookies), as well as data related to the payment discipline / debt of the Client. The above list is not exhaustive. This means that, to the extent reasonably necessary and to a reasonable extent for the execution and enforcement of the contract, the company may process Data not specified in the above paragraph.
7. Duration of data storage
7.1 OÜ InterVacTechnology stores Data for as long as it is necessary to achieve the purposes of Data use specified in the Principles, or for the period stipulated by legal acts.
7.2 The company assumes the following deadlines цhen storing Data:
7.2.1 After 3 years, we delete the data of people who wanted, for example, to receive a commercial offer or information about the availability of Goods, but did not become customers of the company, as well as phone records with the support service/sales department and records of their security devices.
7.2.2 After 7 years from the date of termination of the contract, we delete its original data and data that arose during the execution of the contract (Customer requests, claims resolution, notifications, etc.), if after the expiration of the contract, no debt collection proceedings are conducted in connection with its execution.
7.3 The terms may be changed if such a need arises, for example, from a specific case, a legal act, or a legitimate interest of the company.
8. Use of cookies in the company’s electronic environments
As with most websites, the electronic environments of OÜ InterVacTechnology use cookies. the page itself is loaded into the User’s computer, as well as cookies, when the user is viewing any page of the Site. Cookies are small text files, which often contain a unique anonymous identifier sent to the User’s browser by a Website and stored on the User’s computer hard drive. Thus, it is thanks to cookies that websites are able to remember Users actions, as well as their preferences (language, font size, etc.), in order to identify the next time they visit the page and react accordingly. Cookies are used to improve the efficiency of work, as well as to obtain analytical information. The information that this Site receives through cookies helps the site to provide the Company’s services to Users in the most convenient way, and can also help the Company to get an idea of potential customers. Cookies provide Users with a personalized experience of using the site and ease of navigation on it, help to track the most visited web pages, determine the effectiveness of advertising and Internet searches. Cookies also help the User not to lose the data of filling out application forms in case of updating the site page.
The Client can find more detailed information about cookies on a separate page about cookies and in the user agreement.
9. Possible actions of Customers when processing data OÜ InterVacTechnology
The Client has the right to:
9.1 The right to access your personal data. The client can get acquainted with his basic and contact information, contract data at the company’s office, as well as through the customer support service.
9.2 Right to rectification of personal data. The Client has the right to correct his personal data if they are incorrect or incomplete. If the Client’s main or contact details have changed or the Client has discovered that his data is incorrect, he always has the right, and in certain cases it is his contractual obligation, to change them or contact customer support to correct the data.
9.3 The right to request the deletion of your personal data (to be forgotten). In certain cases, the Client has the right to request the deletion of his personal data.
9.4 The Client should also take into account that if he express the desire to be forgotten, the delivery of Goods on the basis of the contract becomes impossible. The right to file objections cannot also be used in situations where the company needs to draw up, file or defend legal claims, for example, when the Client, in the company’s opinion, has violated the contract. Objections can also not be submitted if the company processes the Client’s personal data in order to fulfill obligations arising from legal acts.
9.5 Right to file objections. The Client has the right to object at any time to the actions taken by the company regarding the processing of his personal data. the company considers and, if possible, stops processing the specified personal data, when submitting an objection, taking into account clause 9.4.
9.6 The right to restrict the processing of personal data. The Client has the right to request restriction of the processing of his personal data if, in his opinion, the data is inaccurate, if the data is necessary for the Client to draw up, submit or protect a legal claim, provided that the circumstances comply with the terms of the Contract and the law.
10. Feedback from OÜ InterVacTechnology
The Client can contact the company in connection with the processing of Customer Data by phone +372 35 71 007, as well as at sales@intervactechnology.com
This version of the Guidelines is valid for the company and all Clients as amended on 01.10.2020. The Company has the right to unilaterally change and update the Principles as necessary. We maintain the relevance and accessibility of the Principles on the site https://intervactechnology.com/
We inform you about the most important changes to the Principles through our website, by email or in any other reasonable way.