VITATEKA has set itself the goal of being a reliable partner for you and respecting your rights in the processing of personal data. Based on this, we have prepared the principles of the privacy policy, which deal with the collection, use, publication, transmission and storage of customer data.

1. DEFINITIONS

1.1. A data subject is a natural person about whom VITATEKAL has information or information with which the natural person can be identified. Data subjects are, for example, natural persons Clients, cooperation partners and employees about whom VITATEKAL has personal data.

1.2. The privacy conditions are this text, which sets out the principles of VITATEKA's Personal Data Processing.

1.3. Personal data is any information about an identified or identifiable natural person.

1.4. Processing of Personal Data is any operation performed with the Personal Data of the Data Subject. For example, collecting, storing, organizing, storing, changing and disclosing, providing access, making inquiries and making extracts, using, transmitting, cross-using, connecting, closing, deleting or destroying Personal Data, or several of the aforementioned actions, regardless of the way of performing the actions and the means used.

1.5. A customer is any natural or legal person who uses or has expressed a desire to use VITATEKA's services.

1.6. The Agreement is a Service provision or other agreement concluded between VITATEKA and the Customer.

1.7. Website www.vitateka.ee is VITATEKA's website.

1.8. A visitor is a person who uses the VITATEKA website.

1.9. A child is a person under the age of 13 in the context of Personal Data Processing in the Republic of Estonia.

1.10. Services are all kinds of services and products offered by VITATEKA.

1.11. Cookies are data files that are sometimes stored on the Website Visitor's device.

1.12. VITATEKA's Data Protection Officer is a person who follows the application of VITATEKA's Principles of Personal Data Processing and whom the Data Subject can contact in case of a complaint.

1.13. Sales channels are ways of communication with the Data Subject used by VITATEKA, a tool created for the sale of goods and the provision of services. Including e-mail, telephone, public and social media, various chat lines, individualized and interactive advertisements and other similar tools on the Websites and elsewhere.

1.14. The product portfolio is VITATEKA's various products and Services, the list of which is available on the website www.vitateka.ee

In the privacy terms, the Agreement, the General Terms and the communication between the parties, the terms are used in the meaning previously indicated.

2. GENERAL PROVISIONS

2.1. VITATEKA is a legal entity VITATEKA OÜ, with registry code 12779903, address Mõisa tee 5, Kostivere alevik, Jõelähtme vald, Harju maakond, 74204, KOSTIVERE

2.2. Personal data may be processed by VITATEKA:

2.2.1. as the responsible processor, determining the purposes and means of processing;

2.2.2. as an authorized processor according to the instructions of the responsible processor;

2.2.3. as a recipient to the extent to which Personal Data is transferred.

2.3. The Privacy Terms apply to Data Subjects, and the rights and obligations specified in the Privacy Terms are based on all VITATEKA employees and cooperation partners who come into contact with the Personal Data held by VITATEKA.

2.3.1. The Privacy Terms may be supplemented by privacy notices published on the Website or on devices, and the Privacy Terms may also be amended and supplemented with them.

3. PRINCIPLES

3.1. When processing Personal Data, VITATEKA is always based on the interests, rights and freedoms of the Data Subjects.

3.2. VITATEKA's goal is responsible Personal Data Processing, which is based on best practice, bearing in mind that it is always ready to demonstrate the compliance of Personal Data Processing with the set goals.

3.3. All processes, instructions, actions and activities related to the Processing of Personal Data of VITATEKA are based on the following principles:

3.3.1. Legality. In the case of Personal Data Processing, there is a legal basis for this, for example consent;

3.3.2. Justice. The Processing of Personal Data is fair by requiring, above all, that the Data Subject has sufficient information and information about how the Personal Data is Processed.

3.3.3. Transparency. Processing of personal data is transparent to the Data Subject.

3.3.4. Purposefulness. Personal data is collected precisely and clearly for specified and legitimate purposes and is not subsequently processed in a way that is inconsistent with these purposes.

3.3.5. Right. Personal data are correct and, if necessary, updated, and all reasonable measures have been taken to delete or correct Personal Data that are incorrect from the point of view of the purpose of Personal Data Processing.

3.3.6. Storage Limitation. Personal data is stored in a form that allows identification of Data Subjects only as long as it is necessary to fulfill the purpose for which the personal data is processed. This means that if VITATEKA wants to keep Personal Data longer than it is necessary due to the purpose of collection, VITATEKA will anonymize the data in such a way that the Data Subject is no longer identifiable. In the case of data that VITATEKA has received through a customer or other similar relationship, VITATEKA will store the data for 2 years from the last purchase or until consent is withdrawn.

3.3.7. Reliability and confidentiality. The Processing of Personal Data is carried out in a way that ensures the appropriate security of Personal Data, including protection against unauthorized or illegal Processing and against accidental loss, destruction or damage, using reasonable technical or organizational measures. VITATEKA has internal company guidelines, rules for employees, as well as separate contracts with each authorized processor, which provide for best practices, continuous risk assessment, and appropriate technical and organizational measures in the Processing of Personal Data.

4. COMPOSITION OF PERSONAL DATA

4.1. VITATEKA collects, among other things, the following types of Personal Data:

4.1.1. Personal data published by the data subject to VITATEKA (name, e-mail address, postal address, date of birth, telephone number);

4.1.2. Personal data arising as a result of normal communication between the data subject and VITATEKA;

4.1.3. Personal data clearly disclosed by the data subject (e.g. on social media);

4.1.4. Personal data generated when using services (e.g. when purchasing from a VITATEKA store or e-store);

4.1.5. Personal data generated as a result of visiting and using the website (e.g. time spent on the website);

4.1.6. Personal data sent from third parties;

4.1.7. Personal data created and combined by VITATEKA (correspondence within the customer relationship or order history list).

5. COMPOSITION OF PERSONAL DATA AND PURPOSES AND BASIS OF PROCESSING

5.1. VITATEKA Processes Personal Data exclusively on the basis of consent or law.

5.2. On the basis of consent, VITATEKA processes personal data exactly within the limits, scope and purposes determined by the Data Subject. When it comes to consents, VITATEKA is based on the principle that each consent must be clearly distinguishable from other issues, and in an understandable and easily accessible form, in clear and simple language. Consent can be given in writing, electronically or as a verbal statement. The data subject gives consent voluntarily, specifically, knowingly and unequivocally, for example by marking a box on the Website.

5.3. Legitimate interest means VITATEKA's interest in managing and managing its own company in order to provide the best possible Services on the market. On the basis of the law, VITATEKA processes Personal Data only after careful evaluation, to establish that VITATEKA has a legitimate interest, on the basis of which the Processing of Personal Data is necessary and in accordance with the interests and rights of the Data Subject. In particular, on the basis of legitimate interest, Personal Data may be processed for the following purposes:

5.3.1. To ensure a reliable customer relationship, for example Personal Data Processing, which is strictly necessary to identify the real beneficiaries or to prevent fraud;

5.3.2. Managing and analyzing the customer base in order to improve the availability, selection, and quality of Services and products and to make the best and most personalized offers to the Customer upon consent;

5.3.3. Identifiers and Personal Data collected when using websites, mobile applications and other Services. VITATEKA uses the collected data for web analysis or analysis of mobile and information society services, to ensure operation, to improve, to make statistics and to analyze the behavior and user experience of the Visitor and to provide a better and more personal Service;

5.3.4. Organizing campaigns, including organizing personalized and targeted campaigns, conducting customer and visitor satisfaction surveys and measuring the effectiveness of marketing activities;

5.3.5. Analyzing Customer and Visitor behavior in various Sales Channels, Websites;

5.3.6. Service monitoring VITATEKA may record notifications and orders given both in its premises and via means of communication (e-mail, telephone, etc.), as well as information and other actions that VITATEKA has performed and, if necessary, uses these recordings to prove orders or other actions;

5.3.7. For network, information and cyber security considerations, such as measures to combat piracy and to ensure the security of Websites and to make backup copies and store them;

5.3.8. To prepare, present or defend legal claims.

5.4. In order to fulfill the obligation arising from the law, VITATEKA processes personal data to fulfill the obligations stipulated by the law or to implement the ways of use permitted by the law. For example, there are obligations arising from the law when processing payments or complying with money laundering rules.

5.5. In the event that the Processing of Personal Data takes place for a new purpose than the one for which the Personal Data was originally collected, or is not based on the consent given by the Data Subject, VITATEKA carefully evaluates the permissibility of such new Processing.

6. DISCLOSURE AND/OR TRANSMISSION OF CUSTOMER DATA TO THIRD PARTIES

6.1. VITATEKA cooperates with persons to whom VITATEKA may transmit data related to Data Subjects, including Personal Data, within the framework and for the purpose of cooperation.

6.2. Such third parties can be advertising and marketing partners, companies organizing customer satisfaction surveys, debt collection service providers, default registers, IT partners, persons mediating or providing postal services, institutions and organizations, provided that:

6.2.1. the respective purpose and Processing is lawful;

6.2.2. Processing of personal data takes place in accordance with VITATEKA's instructions and on the basis of a valid contract.

7. SECURITY OF PERSONAL DATA PROCESSING

7.1. VITATEKA stores Personal Data only for the strictly minimum necessary time. Personal data whose retention period has passed will be destroyed using the best practices and in accordance with the procedure established by VITATEKA.

7.2. VITATEKA has established guidelines and procedural rules on how to ensure the security of Personal Data through the use of organizational and technical measures.

7.3. In the event of any incident related to Personal Data, VITATEKA will take all necessary measures to mitigate the consequences and mitigate relevant risks in the future. Among other things, VITATEKA registers all incidents and informs the Data Protection Inspectorate and the Data Subject directly in cases provided for this purpose.

8. PROCESSING OF PERSONAL DATA OF CHILDREN

8.1. VITATEKA Services, including information society services, are not aimed at Children.

8.2. VITATEKA does not knowingly collect information about persons under the age of 13, i.e. Children, and in the event of a conscious activity in this regard, we base it on the wishes of the parent or guardian.

8.3. In the event that VITATEKA learns that it has collected Personal Data from or about a Child, VITATEKA will do its best to stop the Processing of such Personal Data.

9. RIGHTS OF THE DATA SUBJECT

9.1. Rights related to consent:

9.1.1. The data subject has the right to notify VITATEKA at any time of his wish to withdraw his consent to Personal Data Processing.

9.1.2. You can withdraw the consent of the recipient of the newsletter given to VITATEKALE from the link below the newsletter.

9.2. When processing personal data, the Data Subject also has the following rights:

9.2.1. The right to receive information, i.e. the Data Subject's right to receive information about the Personal Data collected about him.

9.2.2. The right to consult the data, which includes, among other things, the Data Subject's right to a copy of the Personal Data being Processed.

9.2.3. The right to correct incorrect Personal Data.

9.2.4. The right to delete data, that is, in certain cases, the Data Subject has the right to demand that the Personal Data be deleted, for example, if the Processing takes place only on the basis of consent.

9.2.5. The right to request restriction of Personal Data Processing. This right arises, among other things, if the Processing of Personal Data is not permitted by law or if the Data Subject disputes the correctness of the Personal Data. The Data Subject has the right to request the limitation of the Processing of Personal Data for a period that allows the controller to verify the correctness of the Personal Data or if the Processing of Personal Data is illegal, but the Data Subject does not request deletion of the Personal Data.

9.2.6. The right to an assessment by the supervisory authority as to whether the Processing of the Personal Data of the Data Subject is lawful.

10. EXERCISE OF RIGHTS AND SUBMISSION OF CLAIMS

10.1. Exercise of rights:

10.1.1. The data subject has the right to contact VITATEKA by e-mail [email protected] in the event of a question, request or complaint related to the Processing of Personal Data.

10.2. Filing complaints:

10.2.1. The data subject has the right to file a complaint with VITATEKA, the Data Protection Inspectorate or the court if the data subject considers that his rights have been violated in the processing of personal data.

10.2.2. The contact details of the Data Protection Board (AKI) can be found on the AKI website at: http://www.aki.ee/et/inspektsioon/kontaktid-nouandetelefon.

11. COOKIES AND OTHER WEB TECHNOLOGIES

11.1. VITATEKA may collect data about the Visitors of Websites and other information society services using Cookies (i.e. small pieces of information stored by the Visitor's browser on the hard drive of the Visitor's computer or other device) or other similar technologies (e.g. IP address, device information, location information) and process this data.

11.2. VITATEKA uses the collected data to enable the provision of the Service according to the Visitor's or Client's habits; ensure the best quality of Service; inform the Visitor and Client about the content and make recommendations; make advertisements more relevant and enhance marketing efforts; facilitate login and data protection. The collected data is also used to count Visitors and record their usage habits.

11.3. VITATEKA uses session, persistent and advertising cookies. The session cookie is automatically deleted after each visit; persistent cookies remain after repeated use of the Website. Websites of VITATEKA partners use third-party cookies. VITATEKA does not control the creation of these cookies, so you can get information about these cookies from third parties.

11.4. Regarding cookies, Visitors agree to their use on the Website, in the settings of the Information Society service or in the web browser.

11.5. Most web browsers allow Cookies. Without fully enabling Cookies, the functions of the Website will not be available to the Visitor. Enabling or disabling cookies and other similar technologies is under the control of the Visitor through their web browser settings, information society service settings and such privacy enhancement platforms.

12. IMPORTANT DOCUMENTS, INSTRUCTIONS, PROCEDURES

12.1. The application of VITATEKA's Privacy Terms is based on the following documents, procedures, and instructions:

12.1.1. Register of processing operations, which contains all the purposes and methods of Personal Data Processing, the types and categories of Personal Data to be processed and the corresponding basis for Processing;

12.1.2. The principles of using VITATEKA's organizational and technical measures, in which the various measures that VITATEKA implements in order to always keep personal data confidential and secure are stated.

12.1.3. All About Cookies (English): Descriptions of cookies and other web technologies used by VITATEKA.

13. CONTACT DETAILS AND INFORMATION

13.1. VITATEKA Important contact details for the data subject:

13.1.1. VITATEKA can be contacted about personal data issues at the e-mail address [email protected]

14. OTHER TERMS

14.1. VITATEKA has the right to change these Privacy Terms unilaterally. VITATEKA will inform the Data Subjects of the change www.vitateka.ee on the homepage. We assume that when you start using the VITATEKA website www.vitateka.ee, you have read and accepted the privacy policy.

14.2. The VITATEKA company transfers the personal data necessary for making payments to the authorized processor Maksekeskus AS.