Customer Data Processing Principles
1. These Privacy Terms (hereinafter the Terms) set out the procedure for processing the personal data of the data subject, including personal data processed by Sportos OÜ, the bases, principles, and purposes of personal data processing by Sportos OÜ, the data subject's rights and Sportos OÜ's obligations upon processing personal data and security measures.
2. The chief processor of personal data is Sportos OÜ, registry code 12373976, address Laki 16, Tallinn, Harju county, 10621, e-mail: info@sportos.eu.
3. A data subject is a natural person, including a natural person's representative of a legal person, whose personal data is processed by Sportos OÜ (hereinafter Data Subject).
4. Sportos OÜ has appointed a contact person responsible for personal data protection issues: Kristjan Habakukk, e-mail: info@sportos.eu, phone +372 5655636.
5. Sportos OÜ may authorize other people/institutions (hereinafter Authorized Processor) to process the personal data of the Data Subject, provided that Sportos OÜ has agreed with such Authorized Processor. Therefore, the Authorized Processor is obliged to keep the processed personal data confidential and ensure compliance with legal obligations. The names and contact details of the authorized processors shall be made available to the Data Subject by Sportos OÜ based on the Data Subject's application.
Purpose and legal basis of the processing of personal data
1. Sportos OÜ processes (collects, saves, and stores) personal data for the following purposes:
1. For the fulfillment of the contract concluded with the data subject;
2. To provide goods and services to the data subject;
3. To compile internal sales statistics of Sportos OÜ;
4. to conduct marketing/consumer habits and customer satisfaction surveys;
5. for direct marketing;
6. other operations necessary to fulfill the objectives of the agreement entered into by Sportos OÜ with the Data Subject, including the development and improvement of the quality of the goods and services offered by Sportos OÜ.
2. The bases for the processing of personal data are:
1. Consent of the data subject;
2. laws and other legal acts.
3. Sportos OÜ retains the personal data of the Data Subject until the fulfillment of the obligations arising from the agreement between the Data Subject and Sportos OÜ or the termination of the contractual relationship or until the termination of the data retention obligation of Sportos OÜ arising from law.
Personal data being processed
1. Sportos OÜ processes, the following personal data of the Data Subject:
1. Data subject's data (name, date of birth, personal identification code);
2. Contact details of the data subject (name, address, e-mail, telephone number);
3. Gender, the nationality of the data subject;
4. Club and entrepreneurial affiliation of the data subject;
5. Data subject's preferences regarding competitions and distances;
6. other data of the Data Subject obtained in the course of pre-contractual negotiations and / or performance of the concluded agreement between the Data Subject and Sportos OÜ.
2. The Data Subject gives consent both to the processing of such Personal Data of the Data Subject that Sportos OÜ has received from the Data Subject itself, as well as to such personal data of the Data Subject that Sportos OÜ has received from third parties.
3. The Data Subject is obliged to immediately inform Sportos OÜ of any changes in personal data compared to the personal data submitted by the Data Subject in the agreements concluded between the Data Subject and Sportos OÜ or in the documents submitted to Sportos OÜ.
Storage and retention of personal data
1. Sportos OÜ saves and stores all personal data submitted by the Data Subject under conditions that comply with the principles, requirements, and relevant legislation in these terms and conditions.
2. Sportos OÜ has the right to record all orders employing communication (eg telephone, e-mail), as well as other actions performed by the Data Subject, and if necessary to use these recordings to certify and/or reproduce orders or other actions and other to fulfill the purposes of processing personal data set out in the Terms.
Transfer of data to third parties
1. Sportos OÜ may transfer the personal data of the Data Subject to the following third parties:
1. Cooperation and business partners of Sportos OÜ (including the organizer of a specific competition, the timer of a specific competition, providers of payment solutions, whose payment solutions are used by Sportos OÜ, etc.);
2. Lawyers and other advisers related to the activities of Sportos OÜ;
3. other people to whom Sportos OÜ may/or is obliged to disclose the personal data of the Data Subject to Sportos OÜ to fulfill its obligations arising from law.
2. Sportos OÜ shall not transfer personal data concerning the Data Subject to any third party not specified in the consent unless such right or obligation arises for Sportos OÜ by law.
3. Sportos OÜ requires the person to whom personal data is transferred or disclosed based on the Terms and Conditions to comply with the security and confidentiality rules set by Sportos OÜ.
Rights of the data subject
1. The data subject shall have the right at any time to obtain information about the personal data being processed and their use or to request that they are amended.
2. At the respective request of the Data Subject, Sportos OÜ will notify the Data Subject of the collection and processing of the information in regards to the Data Subject. This will include the purposes of the processing; the composition and sources of personal data; third parties or categories of third parties to whom the transfer of personal data is authorized; third parties to whom he personal data have been transferred; the name of the processor of personal data or his/her representative and the address and other contact details of the processor of personal data. Sportos OÜ is commited to provide the Data Subject with information and to issue the required personal data or to justify the issuance of data or the refusal to provide information within five (5) working days from the receipt of the relevant application.
3. The data subject shall have the right at any time to request the immediate rectification of inaccurate personal data concerning him/her, including the rectification of incomplete personal data.
4. The data subject has the right to receive personal data concerning him/her which he/she has submitted to Sportos OÜ in a structured, publicly available format and machine-readable form, and the right to transfer such data to another controller without Sportos OÜ preventing this.
5. The data subject shall have the right at any time to prohibit the processing of data relating to him/her for research into consumer habits or direct sales and the transfer of data to third parties who wish to use them for research or consumer sales.
6. The data subject has the right to withdraw his/her consent to the processing of personal data at any time. Withdrawal of consent does not affect the lawfulness of the processing carried out based on consent before withdrawal, nor does withdrawal of consent affect the processing of personal data of the Data Subject in so far as the processing of personal data takes place based on law.
7. The data subject has the right to demand the restriction or termination of the processing of his/her data, the termination of the disclosure of or access to personal data, the deletion or closure of collected personal data if the processing of personal data is not permitted by law.
8. The data subject has the right to demand that Sportos OÜ restrict the processing of personal data, if:
1. The data subject contests the accuracy of personal data, for a period that allows Sportos OÜ to verify the accuracy of personal data;
2. the processing of personal data is illegal, but the Data Subject does not request the deletion of personal data, but the restriction of use;
3. Sportos OÜ no longer needs personal data for processing, but they are necessary for the Data Subject to prepare, submit, or protect legal claims.
9. The data subject has the right to demand that Sportos OÜ delete personal data concerning him/her without undue delay and Sportos OÜ is obliged to delete personal data without undue delay, if:
1. personal data are no longer necessary for the purpose for which they were collected or otherwise processed;
2. The data subject withdraws his/her consent to the processing and there's no legal basis for the processing of personal data;
3. personal data have been processed unlawfully;
4. personal data must be deleted to fulfill a legal obligation under Union or Member State law applicable to Sportos OÜ.
10. Sportos OÜ will immediately notify the third parties from whom the personal data was received or to whom the personal data was transferred if it is technically possible and does not entail disproportionately high costs if the Data Subject corrects, deletes, or restricts the processing of personal data.
11. The data subject is obliged to submit all requests and requirements concerning personal data electronically digitally signed at the e-mail address info@sportos.eu or handwritten at Laki 16, Tallinn, Harju County, 10615.
Obligations of Sportos OÜ
Sportos OÜ is obliged to process personal data, including collecting, transmitting and storing personal data, for the purposes provided in these Terms and Conditions and other rules of Sportos OÜ related to personal data processing and the Personal Data Protection Act and Regulation (EU) No. 2016/679 of the European Parliament and Council and other relevant legislation and conditions.
Personal data protection measures
1. In its activities, Sportos OÜ observes the principles of personal data protection and makes every effort to ensure that the processing of personal data, including collection, transmission, and storage of personal data, takes place in a manner that ensures security and confidentiality of personal data according to nature said data, including implementing appropriate technical measures and organizational measures.
2. In the event of a breach of the Data Subject's data that is likely to pose a serious threat to the Data Subject's rights and freedoms, Sportos OÜ obliges to inform the Data Subject without undue delay of the personal data breach, including nature, possible consequences and measures taken. Essentially informing the Data Subject of the contact details of the person with the relevant information.
Protection of data subjects' rights
If the Data Subject finds that Sportos OÜ has violated his/her rights by processing personal data, he/she has the right to apply to Sportos OÜ for termination of the violation.
Also, the data subject has the right to apply to the Data Protection Inspectorate (address: Väike-Ameerika 19, Tallinn 10129, phone: 627 4135, e-mail: info@aki.ee) or a competent court at any time in case of violation of his/her rights.
The data subject has the right to contact Sportos OÜ (registry code 11212277) with questions related to the processing of personal data by phone +372 5655636, e-mail address info@sportos.eu or address Laki 16, Tallinn, Harju county, 10621.
Final provisions
Sportos OÜ has the right to unilaterally amend these Terms and Conditions taking into account the requirements arising from the relevant legislation.