Principles for processing customer data
This document defines the processing of customer data at the disposal of Start Sewing OÜ, its purposes, composition and confidentiality.
Who is a customer?
A person who has entered into a contractual relationship with Start Sewing OÜ.
What is customer data?
Customer data is any information that Start Sewing OÜ has about its customer (e.g. customer name, personal identification number, contact details, transaction details).
What is the processing of customer data?
Processing of customer data is any operation on customer data (including collection, storage, organisation, retention, modification, disclosure, access, retrieval, consultation, use, transmission, cross-use, interconnection, blocking, erasure and destruction of customer data).
Who is the processor of customer data?
The data controller is Start Sewing OÜ (reg. no. 16230044, Räitsaka 17, 10618 Tallinn, Estonia).
The data processors are:
Postal service providers, in order to deliver the ordered goods to the customer; Advertising service providers, including social media service providers, to whom we only transfer the data necessary to inform the customer about new products and promotions and to analyse customer behaviour in the e-shop;
Information technology support companies to ensure the functioning and development of the Start Sewing OÜ e-shop and other IT solutions used.
Composition of the customer data processed:
Start Sewing OÜ may collect the following data:
First name and surname/company name;
Personal identification code/company registration number;
Customers address/company address;
Transaction details (details of purchases made by the customer);
habits, preferences and satisfaction data (e.g. activity, services used, customer satisfaction and complaints);
any customer data not previously mentioned which the customer has provided to Start Sewing OÜ by means of communication (e.g. telephone and computer network) on his or her own initiative, including Start Sewing OÜ’s right to record any instructions given by the customer by means of communication.
Start Sewing OÜ has the right to process customer data not mentioned herein on the basis of the law.
What is the purpose and legal basis for the processing of customer data?
Start Sewing OÜ processes customer data in order to:
1) Perform the contract with the customer based on:
- The performance of the contract or the implementation of pre-contractual measures at the customer’s request;
- In order to perform the contract or to implement the measures taken in relation to the customer’s request or in the performance of a legal obligation;
- Start Sewing OÜ’s legitimate interest.
2) Provide additional services, conduct customer satisfaction surveys, market analyses, and perform statistics based on:
- Customer consent;
- Start Sewing OÜ’s legitimate interest in improving the services and products of Start Sewing OÜ;
- to improve the customer experience and develop new products and services.
3) To defend your infringed or contested rights (e.g. by submitting data to a court) based on:
- Customer consent;
- the performance of a contract or pre-contractual measures taken at the request of the customer;
- in the performance of a legal obligation, or in relation to the performance of a legal obligation;
- Start Sewing OÜ’s legitimate interest in preventing, restricting and investigating misuse or unlawful use of Start Sewing OÜ’s services and products.
4) Comply with legal obligations (e.g. transfer of data to investigative authorities) based on:
- Execution of a contract or implementation of pre-contractual measures at the customer’s request;
- compliance with a legal obligation;
- Start Sewing OÜ’s legitimate interest in sound risk management and corporate governance.
In which cases will Start Sewing OÜ disclose customer data?
Customer data is confidential and will not be disclosed or accessed by third parties without the prior consent of the customer, except as required by law.
Start Sewing OÜ has agreements with mailing companies for the confidential use of the information provided.
Who is the Third Party?
A third party is an individual or legal entity who is neither a customer nor a processor of customer data.
Where is customer data processed?
In general, customer data is processed within the European Union and the European Economic Area (EU/EEA), but in some cases it is transferred to and processed in countries outside the EU/EEA.
The transfer and processing of customer data outside the EU/EEA may take place provided that there is a legal basis, such as the performance of a legal obligation or the customer’s consent, and that appropriate safeguards are in place.
Appropriate safeguards are:
A valid contract containing standard contractual clauses developed by the EU;
there is an adequate level of data protection in the country outside the EU/EEA where the recipient is located, as decided by the European Commission;
The recipient is certified under the Privacy Shield data protection framework (applicable to recipients located in the United States).
Upon request, the customer will receive further information on the transfer of customer data to countries outside the EU/EEA.
How does Start Sewing OÜ use customer data to provide services?
Start Sewing OÜ sends customers Start Sewing OÜ offers. Offers made by partners carefully selected by Start Sewing OÜ will also be forwarded to customers. The partner will not receive customer data unless the customer has expressed a specific interest in the goods or services of the partner.
How does Start Sewing OÜ use profiling to make personalised offers?
Profiling is the automatic processing of customer data used to assess certain personal characteristics of the customer. For example, in order to analyse or predict a person’s economic situation, personal preferences, interests, place of residence. Profile analysis is used for marketing purposes based on the legitimate interest of Start Sewing OÜ, the performance of a contract or the customer’s consent.
Start Sewing OÜ may process customer data to improve the user experience of digital services, such as adapting the views of services to the device used and creating personalised offers to the customer (unless the customer has opted out of direct marketing). Such marketing may be based on which services and how the customer uses them and how the customer navigates the Start Sewing OÜ webapplication.
Based on Start Sewing OÜ’s legitimate interest, Start Sewing OÜ will ensure the use of a convenient e-commerce environment for its private customers through personalised offers and marketing based on profile analysis.
What are the customer rights?
The customer has the following rights in relation to the processing of customer data:
1) Request the rectification of their customer data if it is insufficient, incomplete or incorrect;
1) Object to the processing of their customer data where the use of their customer data is based on legitimate interests, including profiling for direct marketing purposes (e.g. receiving marketing offers or participating in surveys);
3) Request the deletion of your customer data, for example, where it is processed with the customer’s consent and where the customer has withdrawn consent. Such a right does not apply if the customer data that is requested to be deleted is also processed for other legal reasons, such as the performance of a contract;
4) Restrict the processing of your customer data on the basis of an applicable right, for example, at the time when Start Sewing OÜ is assessing whether the customer has the right to have his or her data erased;
5) To obtain information on whether Start Sewing OÜ processes its customer’s data and, if so, to obtain access to the aforementioned data;
6) Receive the customer’s own data, which are processed on the basis of consent or for the performance of a contract, in written form or in a commonly used electronic format and, if technically possible, to transfer these data to another service provider (data portability);
7) Withdraw your consent to the processing of customer data;
8) To lodge a complaint about the use of customer data with the Estonian Data Protection Inspectorate (website: www.aki.ee) if the customer considers that the processing of his/her customer data infringes his/her rights and interests under applicable law.
How can I amend my customer data and request the cessation of processing?
The customer has the right to access his/her customer data by e-mail [email protected] or by telephone (+372) 511 3350. If the customer’s personal data has changed or is otherwise incorrect, the customer must notify us by e-mail at [email protected] or by telephone at (+372) 511 3350.
The customer has the right to request the cessation of the processing of his/her data and/or the deletion of the data collected, if the right to do so arises from the Personal Data Protection Act or other legislation.
For how long will customer data be stored?
Customer data will not be processed for longer than necessary. The period of retention may be based on contracts with the customer, the legitimate interest of Start Sewing OÜ or applicable law (e.g. accounting laws, or statute of limitations, other private law).