The data controller of personal data is FeltCar OÜ, registry code 14993536, address Ehitajate tee 18/2, Pärnu 80010, Estonia, e-mail: info@feltcar.ee.

This Privacy Policy sets out the procedure for processing the personal data of the data subject, including the personal data processed by FeltCar OÜ, the grounds, principles and purposes of processing personal data by FeltCar OÜ, the rights of the data subject and the obligations of FeltCar OÜ in processing personal data, as well as the security measures for protecting personal data.

FeltCar OÜ may authorise other persons or institutions to process the data subject’s personal data, who are obliged to keep the processed personal data confidential and to ensure compliance with the obligations imposed on the authorised processor arising from legislation. FeltCar OÜ will make the names and contact details of authorised processors available to the data subject upon the data subject’s written request.

This list will be updated within a reasonable time as authorised processors or their data change, but no later than within 30 days of the change in the data.

DEFINITIONS

Data subject is a natural person about whom FeltCar OÜ has information, or information by which a natural person can be identified. Data subjects include, for example, individual customers, showroom visitors, persons submitting inquiries or questions, business partners, and representatives of corporate customers;

Personal data is any information relating to an identified or identifiable data subject, including a customer;

Data Protection Regulation means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC;

Customer data is any information (including information considered personal data) known to FeltCar OÜ about a customer or their representatives;

Customer is any natural or legal person who uses, has used, or has expressed a wish to use the services provided by FeltCar OÜ, or is otherwise connected with the services of FeltCar OÜ;

Third party is any person who is not the data subject, FeltCar OÜ, or an employee of FeltCar OÜ, and who alone or jointly with another person determines the purposes and means of processing personal data;

Agreement is any agreement of whatever content concluded between FeltCar OÜ and the customer;

Privacy Policy is this text, which sets out the principles of personal data processing by FeltCar OÜ;

Processing is any operation performed on the data subject’s personal data (including collection, recording, storage, alteration, organisation, granting access, use, retrieval, disclosure, erasure, etc.), regardless of the means or method used.

PURPOSE AND LEGAL BASIS FOR PROCESSING PERSONAL DATA

FeltCar OÜ processes (including collects, records and stores) personal data for the following purposes:

• to perform an agreement concluded with the data subject;
• to provide services to the data subject;
• to conduct marketing, consumer habits and customer satisfaction research;
• to carry out direct marketing;
• for other purposes of the agreement concluded between FeltCar OÜ and the data subject, including actions necessary for developing the services offered by FeltCar OÜ and improving their quality.

The legal bases for processing personal data are:

• the data subject’s consent;
• laws and other legislation.

FeltCar OÜ retains the data subject’s personal data until the obligations arising from the agreement between the data subject and FeltCar OÜ have been fulfilled, or until the contractual relationship ends, or until FeltCar OÜ’s statutory obligation to retain the data ends.

PERSONAL DATA PROCESSED

FeltCar OÜ processes, among other things, the following personal data of the data subject:

• the data subject’s details (name, identity document number, validity period);
• the data subject’s contact details (name, address, e-mail, phone number);
• details of the vehicle owned by the data subject (make, modification, VIN code, year of manufacture, service history, technical specifications);
• other data of the data subject obtained by FeltCar OÜ in the course of pre-contractual negotiations and/or the performance of a concluded agreement.

The data subject gives consent both for the processing of personal data that FeltCar OÜ has received from the data subject directly, and for the processing of the data subject’s personal data that FeltCar OÜ has received from third parties.

The data subject is obliged to promptly inform FeltCar OÜ of any changes to personal data compared to the personal data provided by the data subject in agreements concluded between the data subject and FeltCar OÜ or in documents submitted to FeltCar OÜ.

RIGHTS OF THE DATA SUBJECT

The data subject has the right, at any time, to obtain information about the personal data being processed and their use, or to request their amendment.

Upon the data subject’s relevant request, FeltCar OÜ undertakes to disclose to the data subject their personal data and information concerning its processing, including the purposes of processing; the composition and sources of the personal data; third parties or categories thereof to whom disclosure of personal data is permitted; third parties to whom the data subject’s personal data have been disclosed; the name of the personal data processor or their representative, and the address and other contact details of the personal data processor. FeltCar OÜ undertakes to provide the information and issue the requested personal data, or to justify a refusal to issue the data or provide the information, within five (5) business days of receiving the relevant request.

The data subject has the right, at any time, to request the prompt correction of inaccurate personal data concerning them, including the completion of incomplete personal data.

The data subject has the right to receive the personal data concerning them that they have provided to FeltCar OÜ in a structured, commonly used and machine-readable format, and to transmit that data to another controller without hindrance from FeltCar OÜ.

The data subject has the right, at any time, to prohibit the processing of data concerning them for the purpose of researching consumer habits or for direct marketing, and the disclosure of the data to third parties wishing to use it for researching consumer habits or for direct marketing.

The data subject has the right, at any time, to withdraw their consent to the processing of personal data. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal, nor does withdrawal of consent affect the processing of the data subject’s personal data to the extent that such processing is carried out on the basis of law.

The data subject has the right to request the restriction or termination of the processing of their personal data, the termination of the disclosure of personal data or access thereto, or the erasure or closure of collected personal data, if the processing of personal data is not permitted under legislation.

The data subject has the right to request that FeltCar OÜ restrict the processing of personal data, including in cases where:

• the data subject disputes the accuracy of the personal data, for a period enabling FeltCar OÜ to verify the accuracy of the personal data;
• the processing of personal data is unlawful, but the data subject does not request erasure of the personal data, but rather a restriction of its use;
• FeltCar OÜ no longer needs the personal data for the purposes of processing, but the data subject needs it for the establishment, exercise or defence of legal claims.

The data subject has the right to request that FeltCar OÜ erase, without undue delay, personal data concerning them, and FeltCar OÜ is obliged to erase personal data without undue delay, including where:

• the personal data are no longer necessary for the purpose for which they were collected or otherwise processed;
• the data subject withdraws the consent on which processing was based and there is no other legal basis for the processing;
• the personal data have been unlawfully processed;
• the personal data must be erased in order to comply with a legal obligation under Union or Member State law applicable to FeltCar OÜ.

Where personal data is corrected, erased, or its processing restricted, FeltCar OÜ undertakes to promptly notify any third parties from whom the personal data was received or to whom it was disclosed, provided this is technically possible and does not involve disproportionate expense.

The data subject must submit all requests and demands concerning personal data electronically, digitally signed, to the e-mail address info@feltcar.ee.

OBLIGATIONS OF FELTCAR OÜ

FeltCar OÜ is obliged to process personal data, including to collect, disclose and retain personal data, in accordance with the purposes, conditions and procedures set out in these terms and in other legislation relating to the processing of personal data, including FeltCar OÜ’s internal rules, the Personal Data Protection Act, Regulation (EU) 2016/679 of the European Parliament and of the Council, and other relevant legislation.

SECURITY

FeltCar OÜ observes the principles of personal data protection in its activities and does everything in its power to ensure that the processing of personal data, including its collection, disclosure and retention, takes place in a manner that ensures the security and confidentiality of personal data in accordance with its nature, including implementing appropriate technical and organisational measures to ensure the secure processing of personal data.

DIRECT MARKETING MESSAGES

The e-mail address and phone number are used to send direct marketing messages if the customer has given the relevant consent. If the customer does not wish to receive direct marketing messages, they should select the relevant link in the footer of the e-mail or contact customer support.

Where personal data is processed for the purposes of direct marketing (profiling), the customer has the right to object at any time to the processing of their personal data for such purposes, including profiling related to direct marketing, both for the original and any further processing, by notifying customer support by e-mail.

PROTECTION OF THE DATA SUBJECT’S RIGHTS

The data subject has the right to contact FeltCar OÜ regarding matters related to the processing of personal data at the e-mail address info@feltcar.ee.

The data subject also has the right, at any time, in the event of a violation of their rights, to contact the Estonian Data Protection Inspectorate (www.aki.ee) or a competent court.