1. General Provisions
1.1. This privacy policy regulates the principles of collection, processing, and retention of personal data. Personal data is collected, processed, and retained by the data controller, PopUp OÜ (hereinafter referred to as the “data processor”).
1.2. An “data subject” in the context of this privacy policy refers to a customer or any other individual whose personal data is processed by the data processor.
1.3. A “customer” in the context of this privacy policy is anyone who purchases goods or services from the data processor’s website.
1.4. The data processor adheres to the principles of data processing established by legislation, including processing personal data lawfully, fairly, and securely. The data processor can confirm that personal data has been processed in accordance with the applicable legislation.
2. Collection, Processing, and Retention of Personal Data
2.1. The personal data collected, processed, and retained by the data processor is gathered electronically, primarily through the website and email.
2.2. By sharing their personal data, the data subject grants the data processor the right to collect, organize, use, and manage personal data for the purposes defined in this privacy policy, which the data subject shares directly or indirectly when purchasing goods or services from the data processor’s website.
2.3. The data subject is responsible for ensuring that the data they provide is accurate, correct, and complete. Providing knowingly false information is considered a violation of this privacy policy. The data subject is obligated to promptly inform the data processor of any changes to the provided data.
2.4. The data processor is not liable for any damage caused to the data subject or third parties due to the submission of incorrect data by the data subject.
3. Processing of Customers’ Personal Data
3.1. The data processor may process the following personal data of the data subject:
3.1.1. First name and last name;
3.1.2. Date of birth;
3.1.3. Phone number;
3.1.4. Email address;
3.1.5. Delivery address;
3.1.6. Bank account number;
3.1.7. Payment card details;
3.2. In addition to the above, the data processor has the right to collect data about the customer that is available in public registers.
3.3. The legal basis for processing personal data is established in Article 6(1) of the General Data Protection Regulation, which states:
a) the data subject has given consent to process their personal data for one or more specific purposes;
b) the processing of personal data is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract;
c) the processing of personal data is necessary for compliance with a legal obligation to which the data controller is subject;
f) the processing of personal data is necessary for the purposes of the legitimate interests pursued by the data controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, in particular when the data subject is a child.
3.4. Processing of personal data according to the purpose of processing:
3.4.1. Purpose of processing – security and safety
Maximum retention period of personal data – according to the deadlines established by law.
3.4.2. Purpose of processing – order processing
Maximum retention period of personal data – 3 years.
3.4.3. Purpose of processing – ensuring the functioning of e-commerce services
Maximum retention period of personal data – 3 years.
3.4.4. Purpose of processing – customer management
Maximum retention period of personal data – 3 years.
3.4.5. Purpose of processing – financial operations, accounting
Maximum retention period of personal data – according to the deadlines established by law.
3.4.6. Purpose of processing – marketing
Maximum retention period of personal data – 3 years.
3.5. The data processor has the right to share customers’ personal data with third parties, which may include authorized data processors, accountants, transport and courier companies, and companies providing transfer services. The data processor is the responsible data controller. The data processor will transmit the personal data necessary for processing payments to the authorized processor Montonio.
3.6. In the processing and retention of the data subject’s personal data, the data processor implements organizational and technical measures that ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.
3.7. The data processor retains the data subject’s data depending on the purpose of processing, but not longer than 3 years.
4. Rights of the Data Subject
4.1. The data subject has the right to access their personal data and to review it.
4.2. The data subject has the right to obtain information regarding the processing of their personal data.
4.3. The data subject has the right to correct or complete inaccurate data.
4.4. If the data processor processes the data subject’s personal data based on the data subject’s consent, the data subject has the right to withdraw that consent at any time.
4.5. The data subject can contact the customer support of the e-store at info@klap.ee to exercise their rights.
4.6. The data subject also has the right to lodge a complaint with the Data Protection Inspectorate for the protection of their rights.
5. Final Provisions
5.1. These data protection conditions are drawn up in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data, as well as repealing Directive 95/46/EC (General Data Protection Regulation), the Estonian Personal Data Protection Act, and the legal acts of the Republic of Estonia and the European Union.
5.2. The data processor has the right to partially or fully change the data protection conditions by informing data subjects of the changes via the website www.klap.ee.