Terms of personal data processing

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Terms of personal data processing

  1. Controller
    • The controller of your personal data is Airwave limited company (hereinafter referred to as Airwave ), business register code 10619261, Kesk-Sõjamäe tn 7, Lasnamäe, Tallinn, Harju county, 11415.
    • In case of questions or statements related to the terms of personal data processing, you can contact Airwave’s customer service at the following contact details:
      E-mail address: info@airwave.ee
      Phone: +372 600 0970
      Address: Suur-Sõjamäe 50a, Lasnamäe district, Tallinn, Harju county, 11415
  2. Types and sources of personal data
    • Personal data processed by Airwave includes personal data that you have provided to Airwave (for example, when submitting a question or statement and concluding a contract) or that have become known to Airwave in another way (for example, when performing a contract), in particular:
      • personal data (for example, first name, last name, personal identification number);
      • contact information (for example, e-mail address, telephone number, postal address);
      • bank details (for example, bank name, bank account number);
      • data related to products and services (for example, data about products and services of interest or ordered, concluded contracts and the circumstances of their fulfillment and violation, including payments and debts);
      • communication data (for example, e-mail correspondence).
    • In order for Airwave to be able to process your request for consultation or offer regarding products or services, it is necessary to provide your first name, last name, e-mail address, phone number and county. In order for Airwave to be able to conclude a contract with you, it is also necessary to provide the remaining personal data specified in clauses 1.1 and 2.1.2.
  3. Purposes and basis of personal data processing
    • Based on your request, to take measures prior to the conclusion of the contract or to fulfill the contract concluded with you:
      • for the purpose of processing questions and applications – in particular personal data, contact data, communication data;
      • for the purpose of selling products or providing services – in particular personal data, contact data, data related to products and services, communication data;
      • for settlement purposes – in particular personal data, contact data, bank data, data related to products and services;
      • for the purpose of preparing, submitting and defending legal claims – personal data, contact data, bank data, data related to products and services, communication data.
    • To comply with Airwave’s legal obligation:
      • for the purpose of fulfilling accounting and tax obligations, including original accounting documents and documents that are significant from the point of view of taxation – in particular personal data, contact data, bank data, data related to products and services;
      • for the purpose of fulfilling notification and reporting obligations arising from legislation – in particular personal data, contact data, data related to products and services.
    • Based on Airwave’s legitimate interest:
      • based on Airwave’s legitimate interest in analyzing customer satisfaction with products, services and customer service and developing the product portfolio, services and customer service – for the purpose of analyzing and developing the product portfolio, services and customer service – in particular personal data, contact data, data related to products and services, communication data;
      • based on Airwave’s legitimate interest in preparing analyzes and reports of its economic activity – for the purpose of preparing economic activity analyzes and reports – in particular personal data, data related to products and services;
      • based on Airwave’s legitimate interest in preparing, presenting and defending or disposing of legal claims – for the purpose of preparing, presenting, defending and disposing of legal claims – personal data, contact data, bank data, data related to products and services, communication data;
      • based on Airwave’s legitimate interest in conducting direct marketing of products or services similar to the sold product or service under the conditions stipulated in the Electronic Communications Act – electronic contact data for the purpose of direct marketing of products or services similar to the sold product or service and accompanying profile analysis.
    • Based on your consent:
      • For the purpose of forwarding your applications to Airwave’s resale and installation partner for resolution, if your application concerns retail sales – in particular personal data, contact data, data related to products and services, communication data;
      • For the purpose of direct marketing of Airwave products and services and related profile analysis – in particular personal data, contact data, data related to products and services, communication data.
  4. Recipients of personal data
    • Airwave discloses your personal data only to recipients, including authorized processors and third parties whose categories are as follows:
      • Persons providing accounting services to Airwave;
      • Persons providing e-invoicing and financial software services to Airwave;
      • Persons providing payment services to Airwave;
      • Persons providing postal and communication services to Airwave;
      • Persons providing analysis and marketing services to Airwave;
      • Persons providing legal services to Airwave;
      • Persons providing debt collection services to Airwave;
      • persons who process personal data under the direct authority of Airwave or an authorized processor;
      • Airwave reseller and installation partners;
      • persons to whom Airwave has assigned its claims.
    • Due to legislation, Airwave may be obliged to disclose your personal data to public sector authorities, which may, in accordance with legislation, receive personal data in connection with a specific request (for example, the Data Protection Inspectorate, courts, bailiffs, etc.). The said public sector institutions are not considered recipients, but they process the data in question in accordance with the applicable data protection regulations according to the purposes of the processing.
    • Airwave discloses and/or transmits your personal data to each specific recipient only if and to the extent that it is necessary for the purposes set out in clause 3.
    • Airwave does not transfer your personal data to a third country or international organization.
    • The list of recipients of personal data can be consulted through Airwave’s customer service to the extent that the recipient’s data is not confidential or Airwave’s business secret.
  5. Personal data storage term
    • Airwave stores your personal data until the storage of personal data is necessary for the purposes set out in point 3 (for example, for the purpose of processing applications until the resolution of the application, for the purpose of selling products and providing services until the fulfillment of the relevant contract, for purposes related to billing and legal claims until the expiry of legal claims arising from legislation or until the termination of legal claims, on the basis of consent in the case of ongoing processing until the goal is achieved or consent is withdrawn, etc.) or until the retention of personal data is mandatory according to legislation (for example, for the purpose of fulfilling accounting and tax obligations, as a rule, 7 years).
    • For more detailed information about the retention periods for your personal data, please contact Airwave’s customer service using the contact details provided in point 2.
  6. Automated decisions and profiling
    Airwave will not take decisions regarding you based solely on automated processing, including profiling, and which will lead to legal consequences concerning you or have a similar significant impact on you.

Airwave will not take decisions regarding you based solely on automated processing, including profiling, and which will lead to legal consequences concerning you or have a similar significant impact on you.

  1. Your rights regarding the processing of your personal data
    • Realization of rights

To exercise your rights below, please contact Airwave’s customer service using the contact information provided in point 1.2.

  • The right to consult the data

You have the right to request confirmation as to whether personal data concerning you is being processed and, if so, to access the personal data and information about the types of personal data involved, their sources (if not obtained from You), the purposes of the processing, automated decisions and profile analysis (if applicable), recipients or their categories, the transfer (if applicable), the intended retention period or the criteria for determining the period and Your rights.

  • Right to rectification of data

You have the right to request that incorrect personal data concerning you be corrected and to supplement incomplete personal data, including by submitting an additional statement in writing.

  • Right to deletion of data (“right to be forgotten”)

You have the right to request that the personal data concerning you be deleted if the personal data are no longer needed for the purposes for which they were collected or otherwise processed; you withdraw your consent to processing and there is no other legal basis for processing personal data; you object to the processing of personal data (and, where applicable, there are no overriding legitimate grounds for the processing); personal data has been processed illegally; personal data must be deleted to fulfill a legal obligation arising from the law applicable to Airwave; or personal data was collected in connection with the provision of information society services directly to the child.

You do not have the right to request the deletion of personal data to the extent that their processing is necessary in the cases provided for in the General Regulation on the Protection of Personal Data, for example to exercise the right to freedom of speech and information, to fulfill Airwave’s legal obligation prescribed by applicable law, to prepare, present or defend legal claims, etc.

  • The right to restrict the processing of personal data

You have the right to request the restriction of personal data processing if you dispute the correctness of the personal data, during the verification of the correctness of the personal data by Airwave; the processing of personal data is illegal, but you do not request their deletion; Airwave no longer needs personal data for processing purposes, but they are necessary for you to prepare, present or defend legal claims; or you object to the processing of personal data, until it is checked whether Airwave’s legitimate reasons outweigh your reasons.

  • The right to object

If the basis for the processing of your personal data is the performance of a task in the public interest or the exercise of public authority or the legitimate interest of Airwave or a third party, you have the right to object to the processing of personal data, including profile analysis, based on your specific situation. In this case, Airwave will no longer process your personal data, unless Airwave proves that it is being processed for a compelling legitimate reason that is overwhelming, or for the purpose of establishing, presenting or defending legal claims.

  • Right to transfer data

If the processing is based on your consent or is necessary for the performance of the contract concluded with your participation or for taking measures prior to the conclusion of the contract in accordance with your request and is processed automatically, you have the right to receive the personal data concerning you that you have submitted to Airwave in a structured, commonly used format and in a machine-readable form, and the right transfer this data to another data controller.

You have the right to request that Airwave transfer the data directly to another data controller, if this is technically feasible.

  • Right to withdraw consent

If the processing of your personal data is based on your consent, you have the right to withdraw your consent to the processing of personal data at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to withdrawal.

  • The right to lodge a complaint with the supervisory authority

Without prejudice to the application of other administrative or legal means of protection, you have the right to file a complaint with the supervisory authority if you are of the opinion that the processing of personal data concerning you violates the General Regulation on the Protection of Personal Data or other legal acts concerning the protection of personal data.