Principles of Pocketpro.ee personal data processing

1. GENERAL PROVISIONS

1.1 These principles of personal data processing (hereinafter Principles) provide the principles based on which OÜ PocketPro (registry code 16200184, location Kuu 28, Tartu 50104, hereinafter also Pocketpro.ee) processes personal data. Pocketpro.ee processes personal data that Pocketpro.ee receives from the data subject (hereinafter User) upon their consent when registering as a User of the Pocketpro.ee platform (website www.pocketpro.ee or Pocketpro mobile application) and that Pocketpro.ee requests or in another way collects about the User through the use of the platform. The User consents to Pocketpro.ee for the processing of the User's personal data for the purposes and to the extent provided in the principles of personal data processing.

1.2. The general principles of Pocketpro.ee personal data processing are as follows:

1.2.1. The principle of legality and fairness – the processing of personal data takes place only on a lawful and fair basis.

1.2.2. The principle of purpose – personal data are processed only for specified and legitimate purposes and not in a way incompatible with the purposes for which they are processed. Personal data shall be processed for other purposes only with the consent of the data subject or a competent authority.

1.2.3. The principle of minimality – personal data are collected only to the extent necessary to achieve the defined purposes.

1.2.4. The principle of data quality – personal data are correct, up-to-date, complete, and necessary to achieve the set purpose of data processing.

1.2.5. The principle of individual participation – the data subject is informed of the data collected about them; they are given access to the data collected about them and they have the right to request the correction of inaccurate or misleading data.

1.2.6. The principle of security – necessary security measures are taken to protect personal data against unintentional or unauthorized processing, disclosure, or destruction.

2. DATA SUBJECT AND TYPES OF PERSONAL DATA

2.1. The data subjects are Pocketpro.ee Users.

2.2. Pocketpro.ee primarily processes the following personal data:

2.2.1. Identification data, e.g., name, personal identification code, date of birth, identification document details.

2.2.2. Contact details, e.g., address, email, phone number, etc.

2.2.3. Transaction data on the use of the Pocketpro.ee platform and data on concluded agreements (agreements entered into by the data subject, their performance/non-performance, payment history, etc.).

2.2.4. Information about the IP addresses and cookies of Users’ computers. The User can refuse cookies at any time by changing the browser settings of their device and deleting the stored cookies. Cookies are stored for one year.

3. THE PURPOSE OF PROCESSING PERSONAL DATA

3.1. Pocketpro.ee processes personal data only to achieve its legitimate purposes and only to the extent necessary to achieve the said purposes. The activities through which Pocketpro.ee achieves its purposes and during which it processes personal data are:

3.1.1. Providing Pocketpro.ee platform’s services.

3.1.2. Providing user support to Procketpro.ee Users.

3.1.3. Making personal announcements and offers to Users by Pocketpro.ee.

3.1.4. Analyzing the use of the Pocketpro.ee platform and compiling statistics as well as developing and improving the Pocketpro.ee platform and its possible additional services.

3.1.5. Displaying third party offers to the User if the User has previously allowed the installation of cookies on their computer.

3.1.6. Marketing activities of Pocketpro.ee services and services offered through Pocketpro.ee.

3.1.7. Sending Pocketpro.ee newsletters to the User’s email address.

3.2. Pursuant to the law, Pocketpro.ee also processes personal data for the following purposes:

3.2.1. "Fulfillment of accounting, auditing, and similar business obligations.": "Fulfillment of accounting, auditing, and similar business obligations."

3.2.2. Transfer of Users’ personal data to relevant competent authorities based on lawful requests.

4. SOURCES AND GROUNDS FOR OBTAINING PERSONAL DATA

4.1. The source of personal data is the information provided by the data subject, information provided by Pocketpro.ee’s contractual partners, information collected by Pocketpro.ee from external sources, including information received from public and private registers and third parties. When processing personal data, Pocketpro.ee uses, among other things, information provided by other Users who are contractual partners of the Users, information provided by persons related to the contract concluded through Pocketpro.ee, information provided by authorities, electronic databases, and other public sources and search engines.

4.2. The legal basis for the processing of personal data is the Pocketpro.ee user agreement entered into by the data subject. The processing of personal data may also be based on some initiative of the data subject (incl. application, petition, memorandum, request for information) or other appeal to Pocketpro.ee.

5. THIRD PARTIES TO WHOM POCKETPRO.EE MAY TRANSFER PERSONAL DATA

5.1. Pocketpro.ee may transfer personal data to, among others, the following persons:

5.1.1. Authorized processors, incl. persons who are related to the performance of agreements entered into with Pocketpro.ee or the provision of services to Pocketpro.ee (incl. the provider of payment, communication, legal assistance and/or IT services, etc.).

5.1.2. Authorities (including law enforcement agencies, etc.).

5.1.3. Courts, arbitral tribunals, bailiffs, trustees in bankruptcy, notary offices, auditors within the limits of the rights granted to them.

5.1.4. Credit and financial institutions.

5.1.5. "Third parties keeping various registers (e.g., default registers, credit registers, population registers, commercial registers, securities registers, and other registers in which personal data are stored).": "Third parties keeping various registers (e.g., default registers, credit registers, population registers, commercial registers, securities registers, and other registers in which personal data are stored)."

5.2. The transfer of personal data is possible in reference to a legal succession in the case of a legal merger or transfer of an enterprise, when pursuant to law all rights and obligations are deemed to have been transferred to the legal successor.

6. RIGHTS OF THE DATA SUBJECT

6.1. The data subject has the following rights in relation to the processing of personal data concerning them:

6.1.1. Receive information about personal data collected about them.

6.1.2. Request the correction, supplementation, or amendment of their personal data if the personal data is incorrect.

6.1.3. Submit objections regarding the processing of their personal data and/or complaints to the data protection authority (Data Protection Inspectorate, Tatari 39, Tallinn, info@aki.ee) or to a court if they consider that the processing of their personal data is unlawful.

6.2. If possible, Pocketpro.ee will issue data and/or information on personal data in the manner and form requested by the data subject or notify the data subject of the rejection of their application within one month at the latest.

6.3. The User has the right to request the termination of the processing of personal data and the deletion of the collected personal data at any time. Upon termination of the processing of personal data and deletion of the collected personal data, the User's user account will be closed. Personal data is stored until the User's user account is closed or until the processing of personal data is terminated and the collected personal data is requested to be deleted.

6.4. A third party whose personal data has been published by the User during the procurement in the Pocketpro.ee environment also has the same rights as the data subject.

7. RETENTION OF PERSONAL DATA

7.1. Personal data will not be processed longer than necessary. The term of storage of personal data is based on the terms of the Pocketpro.ee user agreement, Pocketpro.ee’s legitimate interest or applicable law.

7.2. Pocketpro.ee stores personal data as follows:

7.2.1. Accounting documents for 7 years from the end of the respective financial year, due to legal requirements.

7.2.2. Personal data arising from contracts for 10 years from the end of the contract.

8. CONTACT DETAILS

Data subjects may contact Pocketpro.ee in connection with the processing of their personal data by Pocketpro.ee at the following contacts: OÜ PocketPro, registry code 16200184, location Kuu 28, Tartu 50104, email: info@pocketpro.ee.