Privacy policy

PRIVACY POLICY

Smiletex OÜ, registry code 12784544, address Tartu mnt 87e, Tallinn 10112, Estonia ("Smiletex") is committed to protecting its customers' privacy and ensuring lawful, secure data processing. This privacy policy explains how personal data is processed at Smiletex.

1) DEFINITIONS

Data subject – a natural person whose personal data Smiletex processes. Data subjects may include, for example, Smiletex's private customers, website visitors or other persons who contact Smiletex. In this privacy policy the data subject is also referred to as "you" or "the customer".

Personal data – any information about a directly or indirectly identifiable data subject.

Processing of personal data – any automated or non-automated operation or set of operations performed on personal data or sets of personal data, including collecting, storing, using, transferring, deleting, etc.

2) GENERAL PRINCIPLES

When processing personal data, Smiletex follows this privacy policy, Regulation 2016/679 of the European Parliament and of the Council (the General Data Protection Regulation), the Personal Data Protection Act and other relevant data protection legislation, the guidelines of supervisory authorities, as well as best practice and good business custom.

Smiletex ensures the integrity, availability and confidentiality of personal data by applying appropriate organisational, physical and IT measures.

Smiletex only uses processors who guarantee appropriate security measures and process personal data according to Smiletex's instructions and in compliance with legal requirements.

Smiletex employees are, under legal requirements and their employment or similar contracts, obliged to keep personal data learned in the course of their duties confidential. This confidentiality obligation is indefinite and Smiletex employees are liable for breaching it.

3) PURPOSES AND BASES OF PROCESSING PERSONAL DATA

Smiletex collects personal data for clearly defined and legitimate purposes and later processes it in a way consistent with those purposes. Smiletex processes personal data to fulfil legal obligations, to perform a contract concluded with you and to prepare for concluding a contract, on the basis of your consent, and in Smiletex's own legitimate interests.

More specifically, Smiletex processes personal data for the following purposes and on the following bases:

• you send us a suggestion or a note of thanks – with your consent we share your personal data (name) among our employees;
• you file a complaint or an information request – we use your personal data to establish the circumstances of the complaint/request and to respond to it. If you have sent us an inquiry that can only be answered by one of our contractual partners (for example an insurance company, etc.), we forward the letter to the right institution and notify you;
• to send marketing offers and messages, including newsletters, Smiletex uses your name, email address and/or mobile phone number if you have given consent meeting the conditions set out in law;
• to protect Smiletex's infringed or contested rights and to exercise rights in connection with legal claims, proving and defending them in or out of court. Processing takes place on the basis of Smiletex's legitimate interest and to perform the contract concluded with you;
• you apply for a job with us – we rely on the data you have shared and data that can be collected from public sources. By sending us your CV, you consent to being contacted.

4) TRANSFER OF PERSONAL DATA

Smiletex has the right or obligation to transfer personal data identifying the data subject and contact details:

• to companies providing credit management services. Data is transferred only if the customer has an outstanding financial obligation to Smiletex. The right to transfer the data arises from the Law of Obligations Act;
• to companies providing marketing services to Smiletex. Data is transferred only if you have given consent meeting the conditions set out in law;
• to companies and state authorities when the obligation to transfer data arises from law.

5) RETENTION OF PERSONAL DATA

Smiletex processes personal data for as long as necessary to achieve the purposes of processing, for the period prescribed by law, or to protect Smiletex's own rights in resolving a dispute or potential dispute with you.

After the retention period ends, personal data kept on paper is destroyed and electronic personal data is deleted. If you would like more detailed information about the retention periods applied to your stored personal data, please contact us using the details in the "Contact" section.

6) YOUR RIGHTS REGARDING YOUR PERSONAL DATA

Smiletex guarantees data subjects all rights arising from applicable law. When your personal data is processed, you have the following rights:

• the right of access, meaning you have the right to ask at any time whether Smiletex holds personal data about you and to receive information about what personal data Smiletex processes about you;
• the right to rectification, meaning you have the right to ask Smiletex to clarify or correct your personal data if it is insufficient, incomplete or wrong;
• the right to object, meaning you have the right to object to Smiletex's processing of your personal data;
• the right to erasure, meaning you have the right to ask Smiletex to delete your personal data, for example when it is processed on the basis of your consent and you have withdrawn that consent;
• the right to restrict processing, meaning you have the right to require Smiletex to restrict the processing of your personal data, for example when Smiletex no longer needs it for the purposes of processing or you have objected to the processing;
• the right to withdraw consent to the processing of personal data, where the processing is based on your consent;
• the right to data portability, meaning you have the right to receive the data you have submitted to Smiletex electronically, in writing or in a commonly used electronic format, and, where technically possible, to require Smiletex to transfer the data to a third-party service provider;
• the right to lodge a complaint with a supervisory authority, meaning that if you find that your rights regarding the processing of your personal data have been violated, you may lodge a complaint with the Data Protection Inspectorate (address Väike-Ameerika 19, Tallinn 10129, email info@aki.ee).

The rights listed in this section are not absolute. In certain cases Smiletex's legitimate interests or legal obligations may limit your rights.

7) CHANGES TO THE PRIVACY POLICY AND CONTACT

Smiletex has the right to unilaterally change this privacy policy at any time, in accordance with applicable law. The new version of the privacy policy is published on the website managed by Smiletex https://smiletex.ee/privaatsuspoliitika/.

For questions related to the processing of personal data, you can contact Margit Tarrikas by phone at +372 511 9040 or by email at info@smiletex.ee. Smiletex will reply without undue delay, but no later than within one month of receiving your inquiry. If circumstances need to be clarified or checked in more detail before replying, Smiletex may extend the reply deadline, notifying you in advance.

COOKIE POLICY

The purpose of this cookie policy is to explain how Smiletex OÜ, registry code 12784544, address Tartu mnt 87e, Tallinn 10112, Estonia ("Smiletex") uses cookies on its website https://smiletex.ee/ and how Smiletex helps you make informed decisions when using the website by means of cookie technology and web server logs.

1) WHAT ARE COOKIES?

Cookies are small text files stored in the web browser of your computer or other device via the website you visit. Cookies are used to ensure that websites work, to improve the user experience and to collect certain information for website owners. Smiletex's cookies may contain information about your internet preferences, help us adapt websites to your interests to make them more convenient to use, and often contain an anonymous, unique identifier.

2) CONSENT TO THE USE OF COOKIES ON THIS WEBSITE

If you continue using our website, this means you consent to the use of cookies as described in these principles. If you do not agree to the use of cookies, read the following section titled "Disabling cookies".

3) FOR WHAT PURPOSES ARE COOKIES USED?

Strictly necessary cookies

Some cookies are indispensable for using our websites or some of their functions. If you block such functional cookies, you cannot use our websites. These include cookies used to determine whether the user has consented to the cookies used on our website.

These cookies do not collect any information about you that could be used for marketing or to remember where you have been on the internet.

Analytics cookies

We may use analytics cookies together with web server log files to improve the performance of our websites by collecting aggregate information about how many visitors we have, where they come to our site from and how they use our website (e.g. which pages are the most popular).

Google Analytics is a web analytics tool that collects information about website use. Google Analytics cookies are mainly used to analyse whether a visitor is new or returning (the cookie lasts 2 years), which pages are visited and how long visitors stay (the cookie lasts 30 minutes), and where visitors come from (the cookie lasts 6 months). This information is needed to better understand visitor behaviour and thereby improve the user experience. Click here (https://www.google.com/intl/en-GB/policies/privacy/) to read Google's privacy principles.

Advertising cookies

We may use advertising cookies to serve advertisements more relevant to you and your interests, or to limit the number of times you see the same advertisement on a website. Such cookies are also used to help analyse the effectiveness of newsletters and other marketing messages.

4) DISABLING COOKIES

You can set up your devices to allow all cookies, to be notified when cookies are issued, or to never receive cookies.

If you generally do not want to receive cookies or want to disable certain cookies, you should change your browser settings. As every browser is different, consult your preferred browser's Help menu for information on changing cookie preferences. The website http://www.allaboutcookies.org/ provides comprehensive information on how to manage and disable cookies in different browsers.

If you decide to disable cookies, some parts of the website may not work properly.

5) CHANGES TO COOKIE USE AND CONTACT

Smiletex has the right to unilaterally change this cookie policy at any time, in accordance with applicable law. The new version of the cookie policy is published on the website managed by Smiletex https://smiletex.ee/privaatsuspoliitika/.

If you have further questions about how we use cookies, please contact us by phone at +372 511 9040 or by email at info@smiletex.ee.

 

Last updated: 15.10.2023