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PRIVACY STATEMENT

This privacy statement describes how Hipodroomi Development OÜ and its process the personal data of potential and existing customers, associated persons, sales contacts, websites, and social media visitors, as well as the personal data of other data subjects who are in contact with Hipodroomi Development OÜ in connection with the provision of its services (hereinafter referred to as ‘you’). This privacy policy applies if you use, have used, or have expressed your intention to use our services, including visiting our website or providing us with your email address for newsletters or have applied to us for employment. In the cases described above, we will act as data controller and are responsible for processing your personal data.

COLLECTING YOUR PERSONAL DATA. 
We collect your personal data in the following ways:

  • you provide us with your personal data yourself (such as contacting us via phone, email, or website, via social media channels, at our office, on our client days, or at other public events we organise or through other web channels or upload your CV on our website);
  • your personal data is transmitted to us by a third party (such as a broker or if the third-party payment service provider verifies whether your payment was successful or not);
  • we have collected your personal data ourselves, including automatically. See also our cookie policy.

PERSONAL DATA TO BE PROCESSED.
We process the following personal data of the following data subjects:

  • When you sign up for our newsletter on our website, we process data about your name and contact details (email address)
  • If you sign up as an interested person for development projects on our site, we process data about your name and contact information (phone number and email address) and your preferences for the apartment property you are interested in (size, price)
  • For those who register for and attend our client days, we process the name and contact information (address, phone number, and email address), as well as your preferences for the apartment property you are interested in (size, price)
  • If you sign a contract with us, we process the data about your name, personal identification code, contact information (address, phone number, and email address), and marital status; we also process the relevant data (except for marital status) for your authorised representative
  • If you apply for a job with us, we process your name and contact information (address, phone number, and email address) as well as data about your education, job skills, previous jobs, etc.
  • If you participate in our client days or other public events we organise, we will process your image (videos and photos)
  • If you are on the territory of our development site, we will process your image, your other personal data, and activities that are visible in the video surveillance area of the territory

PURPOSE AND LEGAL BASIS OF THE PROCESSING. 
We process your personal data for the following purposes and legal bases:

  • to enter into and perform a contract with you; based on our legitimate interest, such as contacting you for marketing purposes, if our previous contact indicates that you are interested in the offer and you have not expressed any dissatisfaction or objection to such contacting. In these circumstances, we believe that your interests and rights do not outweigh our legitimate interests in marketing our products and services;
  • to enforce the contract with you, including to identify, prove, and pursue violations of the agreement or the law. In a situation where you have breached the agreement or the law, your legitimate interest and rights do not outweigh our legitimate interests;
  • website traffic statistics, service usage statistics, and other non-personalised technical information about website usage with the aim of improving the website and our services;
  • to contact you for feedback on our services and products with the aim of conducting a customer satisfaction survey and you have not expressed any dissatisfaction or objection to such contacting;
  • to fulfil our legal obligations.

Your personal data may also be processed if this is necessary in a particular case for our or a third party’s legitimate interest, unless such interest is outweighed by your interests or fundamental rights and freedoms, for which personal data must be protected, as well as when necessary to protect the vital interests of you or any other natural person.
We do not process special categories of personal data.

PROCESSING ON THE BASIS OF CONSENT. 
We may also process your personal data with your consent (e.g. sending newsletters for direct marketing purposes). If processing is based on consent, you may withdraw consent at any time by contacting us by using the contact details below or by clicking the link ‘remove yourself from newsletter recipients’ at the end of each email. We note that the withdrawal of consent does not affect the legality of the consent-based processing that took place before the consent was withdrawn.

DATA PROCESSORS. 
We use carefully selected service providers to process your personal data (data processors). By doing so, we remain fully responsible for your personal data.
We use the following categories of processors: data storage service providers, email service providers, customer relationship management service providers, brokerage service providers, construction service providers, marketing service providers, payment service providers, employment mediation service providers.
If you would like more detailed information about our data processors (such as their names and location), please contact us using the contact details below.

THIRD PARTIES.
We will only share your personal information with third parties if provided in this privacy policy, if required by applicable law (for example, if we are obliged to share personal data with the authorities), or with your consent.
We may share your personal data with affiliates of Hipodroomi Development OÜ, our auditors, and legal advisers. The legal basis for such sharing is our respective legal obligation or legitimate interest.

TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN UNION
Our data processors may process your personal data outside the European Union (including in the United States). We will only transfer your personal information outside the European Union if we have a legitimate reason to do so, including to the recipient of the data: i) who is located in a country where the European Commission considers that an adequate level of protection of personal data is guaranteed (this includes organisations certified under the Privacy Shield); or ii) under an agreement that fulfils the requirements of the European Union for the transfer of personal data to processors outside the European Union.
If you would like more detailed information on the transfer of your personal data outside the European Union (e.g. the names of the recipients of the data and the legal basis for the transmission), please contact us using the contact details below.

SECURITY
We take technical and organisational security measures to protect your personal information, considering (i) the level of technology, (ii) the implementation costs, (iii) the nature, scope, context, and purposes of the processing, and (iv) the risks to you. Such security measures include, but are not limited to, access management, employee training, two-factor authentication, data encryption.

DATA RETENTION
We will retain your personal information for as long as is necessary for the purpose of collecting it, as long as it is necessary to protect our interests or as long as required by applicable law.
Once you have a contract with us, we will retain your personal data as follows:

  • in accordance with Estonian accounting and tax laws, we keep records related to accounting documents for 7 years from the end of the respective financial year;
  • in accordance with the statute of limitations in Estonian law, we retain personal data relating to contractual claims for a maximum of 10 years from the date on which the claim becomes collectible.

If you have registered an interest in any of our products, we will retain your personal information for 5 years from the date we last contacted you.
If you have participated in our client day and you have not entered into any contract with us, your personal data will be retained for 5 years from the date of the client day. We will retain the photo and video material we have captured for 5 years from the date that the material was captured.

If you have applied for a job but were unsuccessful, we will retain your personal information for 1 month from the date of appointing the candidate to the position for which you were applying. With your separate consent, we will retain this information for up to 6 months from the end of the recruitment process. If you have provided us with your contact details and uploaded your CV on our website, we will retain your personal information for up to 6 months from the date of transmission. The information we receive through the cookies on our website is maintained in accordance with the cookie policy.

YOUR RIGHTS
You have all the rights of the data subject with regard to your personal data to the extent required by the applicable data protection law.
These rights include:

  • requesting access to your personal data;
  • receiving a copy of your personal information;
  • correction of incorrect or incomplete personal data;
  • deletion of personal data;
  • limiting the processing of personal data;
  • transfer of personal data;
  • objecting to the processing of personal data based on legitimate interest and if data is processed for direct marketing purposes.

To enforce your rights, please contact us using the contact details below. If you believe your rights have been violated, you have the right to complain to the Data Protection Inspectorate or to a court.

CHANGING THE PRIVACY POLICY
If our personal data processing practices change or when we need to change the privacy policy pursuant to applicable data protection laws, regulations, judicial practice, or guidelines or practices issued by competent authorities, we have the right to unilaterally change this privacy policy at any time. If this is the case, we will give you reasonable notice by email before the changes take effect.

APPLICABLE LAW
As we are a company incorporated in the Republic of Estonia, the processing of your personal data is subject to the laws of the Republic of Estonia.

CONTACTS
If you have any questions regarding the processing of your personal data or if you would like to exercise your rights as a data subject, please contact us using the following contact details: address Tallinn, Jõe tn 4a, email address , phone number +372 6 001 004.

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