Data Processing Policy
1. What is the purpose of this data processing policy?
1.1. This personal data processing policy has been published to inform you about how the company AS Prike (hereinafter Prike) processes your personal data:
1.1.1. when you make a purchase in the Prike E-Shop, including when you create an account in the Prike E-Shop;
1.1.2. when Prike has a statutory obligation to process your personal data;
1.1.3. when you participate in Prike campaigns, events and trainings;
1.1.4. when you interact with Prike’s social media accounts;
1.1.5. when you make an inquiry, submit a complaint or contact Prike for any other reason;
1.1.6. when you visit Prike’s website/E-Shop (cookies);
1.2. According to this data processing policy, the persons whose personal data are processed by Prike may be customers who are legal entities, or customers who are natural persons, hereinafter clients.
2. Information about Prike as the data controller
2.1. The company AS Prike (registry code 10310368, address Peterburi mnt 92g Tallinn, 11415 Estonia, e-mail [email protected]) is the controller in respect of your personal data. The person responsible for the protection of personal data at Prike is Kelly Kuur, who can be contacted via e-mail at [email protected] in any matters covered by this data processing policy.
3. What are personal data and their processing?
3.1. In this data processing policy, personal data means all information that Prike collects about you as a natural person, which can be used for your identification, and which are stored electronically or in any other way.
3.2. Personal data include all types of information on the basis of which you can be directly or indirectly identified, e.g., given name, last name, address, IP address, e-mail address, phone number, your photos, bank card number, etc.
3.3. Personal data also include publicly available information about you that Prike can access when you contact Prike through any social media network or interact with Prike’s social media accounts.
3.4. According to this data processing policy, the processing of personal data means collection, documentation, organization, structuring, storage, adaptation and modification, querying, reading, use, disclosure, reconciliation or combination, restriction, deletion or destruction of your personal data by means of transmission, distribution or otherwise made available.
4. Cases of personal data processing
4.1. Clauses 5-10 below describe the situations where Prike processes your personal data, which personal data it processes, on what basis, for what purposes, and how long Prike stores such personal data.
5. Processing of Personal Data When making a purchase in the Prike E-Shop
Purpose of processing personal data:
5.1. When you purchase goods from the Prike E-Shop as a guest (you purchase goods by not logging in via a user account), Prike processes your personal data for the purpose of delivering the goods to you and issuing an invoice, including for informing you of the status of the order of the goods, and the need to deliver the goods.
5.2. When you create a user account to purchase goods from the E-store, Prike processes your personal data – in addition to the purpose of delivering the goods – also for the purpose of offering you discounts (e.g., on your birthday), informing you about products and events, for which Prike creates an account for you and manages it.
5.3. When you create an account, Prike will send you information about products and events by e-mail, if you give your consent for the same.
Categories of personal data processed:
5.4. In order to deliver goods and issue invoices, Prike processes the following personal data: given name, last name, phone number, e-mail address, address, payment information (bank account number, bank card number), delivery method, order number.
5.5. In order to create and manage a user account, Prike processes, in addition to the above, the following personal data: date of birth, authentication data (e.g., account password), purchase history (previously purchased products, amounts, date(s) of purchase), language settings.
Period for which personal data are stored:
5.6. When purchasing goods from the E-Shop as a guest, Prike stores the personal data necessary for the delivery of goods and the issuing of an invoice for 3 (three) years from the date of purchase.
5.7. To create and manage a user account, personal data are stored for as long as you use the account.
Basis of processing:
5.8. Creating a user account is not mandatory to purchase goods from the Prike E-store. You may also buy goods as a guest. The personal data provided as a guest are not used to create an account for you but are the minimum necessary personal data that Prike needs to deliver the goods to you and issue an invoice. If you do not provide the requested personal data when purchasing goods as a guest, Prike will not be able to sell the goods to you.
5.9. Prike sends you notifications about Prike’s products and events based on your consent, which you may withdraw at any time by contacting Prike at the e-mail address provided in this data processing policy, or by clicking the opt-out button in the weekly newsletter.
6. Processing of personal data: in the case of a statutory obligation
6.1. Prike may require proof of identity to verify that you are at least 18 (eighteen) years of age. Personal data proving your age is requested under the laws of the Republic of Estonia, which prohibit the sale of alcoholic beverages to persons under the age of 18.
6.2. Prike has the right to refuse selling goods to you if you do not provide an identity document.
6.3. Prike does not collect the above-mentioned personal data.
7. Processing of Personal Data When participating in Pike’s campaigns, events and trainings
Purpose of processing personal data:
7.1. Prike processes your personal data when you participate in events organised by Prike with a view to increase visibility of Pirke by promoting Prike and promoting products of Prike’s suppliers.
7.2. Prike processes your personal data when you participate in trainings organised by Prike with a view to increase visibility of Pirke by promoting Prike and presenting products of Prike’s suppliers.
7.3. Prike processes your personal data when you participate in campaigns organised by Prike, to present raffle or other prizes.
Categories of personal data processed:
7.4. When participating in events and trainings, organised by Prike, Prike processes the following personal data: given name, last name, personal ID code, date of birth, phone number, e-mail address, address, your image, all your other personal data and activities that are visible in the event area of photo and video recording: photo, video, audio.
7.5. When participating in Prike campaigns, Prike processes the following personal data: given name, last name, personal ID code, date of birth, phone number, e-mail address, address.
Basis of processing:
7.6. Prike processes your personal data for the purpose of organising training events or awarding the campaign prizes based on your consent. By refusing to consent to the processing of personal data for training or a campaign, Prike will not be able to organise training for you or allow you to participate in the campaign.
7.7. Prike has a legitimate interest to use photos and video recordings from events to market its brand and cover the events that took place (or events in which Prike participated). Prike promises not to harm your reputation and dignity by using such photos and video recordings.
Period for which personal data are stored:
7.8. Personal data obtained by participating in events, trainings or campaigns will be stored for 5 (five) years after the event, training or campaign took place.
8. Processing of Personal Data When using a social media platform
8.1. The personal data you provide to Prike via social media when you use a Prike account (including through notifications, the use of the “Like” button and other such communications) are jointly processed by Prike with the operators of the relevant social network who act as joint controllers of personal data.
8.2. The personal data processing policy of social networks Facebook and Instagram can be found at https://www.facebook.com/privacy/explanation).
9. Processing of Personal Data When contacting Prike in connection with an inquiry, complaint or for any other reason
9.1. You can contact Prike in several ways: by phone (+372 6224 900) or by e-mail ([email protected] or [email protected]) or via social media accounts. Prike will personally receive, review and respond to all messages.
Purpose of processing personal data:
9.2. Prike processes your personal data when you submit an inquiry, complaint or contact Prike for any other reason. Prike processes your personal data in order to analyse based on the content of the request, complaint or other request whether or not it is justified and, where necessary, settle your complaint or respond to the request (including a proposal, remark, question, feedback, offers, etc.).
Categories of personal data processed:
9.3. In order to respond to an inquiry or other request, or to settle a complaint, Prike processes, inter alia, the following personal data of yours: given name, last name, address, phone number, e-mail address, description of the complaint and documents proving the existence of the claim, content of the inquiry.
Basis of processing:
9.4. Without processing the aforementioned personal data, Prike will not be able to settle your complaint or respond to your inquiry or other request.
9.5. The basis for the processing of personal data processed when resolving and responding to an inquiry, complaint or other request is Prike’s legitimate interest.
Period for which personal data are stored:
9.6. All your personal data related to a complaint, inquiry or other request will be stored for no longer than 2 (two) years from the receipt of the complaint, inquiry or other request. If it takes longer to settle a complaint or answer a request, or if there is an ongoing legal dispute related to them, your personal data may be stored longer. In this case, personal data will be stored up to 1 (one) year after the complaint has been settled or the legal dispute has ended. If the complaint is settled by a compromise agreement, your personal data will be stored for 3 (three) years after the conclusion of the respective agreement.
10. Processing of Personal Data When visiting the Prike’s website (cookies)
Purpose of processing personal data:
10.1. Prike processes your personal data when you visit Prike’s website (E-Shop). Prike uses cookies to ensure the functionality of the E-Shop. Cookies are small data files that help Prike monitor and improve the functionality and usability of the website, including by collecting personal data about you.
Categories of personal data processed:
10.2. Prike uses cookies to processes the following personal data of yours: The history of products that you may have viewed on the website, performed activities, selected language settings, account authentication credentials entered on the website.
Period for which personal data are stored:
10.3. Personal data collected with cookies is stored according to the cookie’s storage time, either for the duration of the session or permanently.
10.3.1. Each session cookie is valid only during the browser session, after the session it expires. Each browser session starts when you open your browser and ends when you close it. After your visit to the website has ended, all session cookies are deleted.
10.3.2. Persistent cookies only last for a specified period (which is different for each cookie). Persistent cookies are not deleted when you close the web browser and are stored on your device. These cookies are activated each time you visit a website that created the specific persistent cookie. To delete a persistent cookie, you need to change your browser settings.
Basis of processing:
10.4. Prike collects your personal data using cookies based on your consent. You can delete or block cookies at any time through the settings of your web browser, but this action may disrupt the functionality or features of the Prike E-Shop. More general information about cookies can be found at https://allaboutcookies.org.
11. Disclosure of Data
11.1. Prike may disclose your personal data to employees and members of management bodies of companies belonging to its group and to employees of companies providing services to Prike (including sole proprietors) and to employees of companies supplying goods to Prike (including sole proprietors), if it is reasonably necessary to attain the purposes specified in this data processing policy.
11.2. Service providers to whom Prike may disclose your personal data are, for example, companies providing debt collection services, security services, auditor services, IT services (ADM Interactive OÜ), marketing services (Sendsmaily OÜ) and delivery of goods (Jet Express OÜ, Sendpack Eesti OÜ).
11.3. In addition to the above, Prike may disclose your personal data to third parties:
11.3.1. in cases provided by law;
11.3.2. to protect its rights or interests;
11.3.3. when Prike wants to sell or sells Prike’s enterprise or assets or part of them, in which case Prike may disclose your personal data to the buyer and its advisors.
11.4. Your personal data will not be transferred to third countries or international organisations.
11.5. Prike does not transfer your personal data to third parties, except in the cases specified in this data processing policy.
11.6. The recipients and categories of personal data listed in this data processing policy may change. If you would like to be notified of a change in the recipients of your personal data, please contact Prike at the email address provided in this data processing policy, including the following information in your letter: “I would like to receive information about changes in recipients of my personal data. Given name, last name”.
12. Security of Your Personal Data
12.1. Your personal data is processed in accordance with the requirements set forth in the General Data Protection Regulation, the Personal Data Protection Act of the Republic of Estonia, and other legislation. While processing your personal data, Prike applies organisational and technical measures that ensure the protection of personal data against accidental or illegal destruction, modification, disclosure and other illegal processing.
13. Your Rights
13.1. Clauses 14-17 below contain information about your rights in relation to the processing of personal data by Prike and about the cases in which you can use these rights. If you would like more information about your rights or if you would like to exercise your rights, please contact Prike at the e-mail address provided in this data processing policy.
13.2. Prike will provide information on the measures taken in connection with the request for the use of rights without undue delay and in any case within 1 (one) month from the receipt of the request. Depending on the complexity of the request and the number of requests received, Prike may extend the deadline by 2 (two) months. If such an extension of the term is needed, Prike will inform you about it and the reasons for the extension within 1 (one) month from the receipt of the request.
13.3. Prike has the right to refuse to grant you the rights set out below only in the cases stipulated in law, including the General Data Protection Regulation.
14. Right to Withdraw Consent
14.1. If Prike processes your personal data based on your consent, you may withdraw it at any time by submitting a respective request at the address specified in this data processing policy.
15. The Right to Access Your Personal Data
15.1. Prike wishes you to fully understand how Prike processes your personal data and to ensure that you do not experience any inconvenience as a result. You can contact Prike at any time at the address given in this data processing policy and ask if Prike processes your personal data and how.
15.2. If Prike processes your personal data, you have the right to review them. If you wish to do so, please send a written request to Prike at the address provided in this data processing policy and identify yourself.
15.3. When submitting the inquiries or requests, please follow the principles of fairness and reasonableness.
16. The Right to Request Additional Information
16.1. We hope you understand that it is very difficult to provide an exhaustive overview of the ways in which personal data are processed. Prike tries to provide as clear and comprehensive information as possible about the processing of your personal data and undertakes to update the data processing policy if and when Prike’s personal data processing procedure changes. However, if you have any questions about the use of your personal data, Prike will be happy to answer you or provide you with as much additional information as Prike can disclose.
17. Additional Rights
17.1. Below you will find information about additional rights that you can exercise in accordance with the following procedure by sending a notification of your wish to exercise the right to the address specified in this data processing policy.
17.1.1. You have the right to request Prike to rectify any errors in your personal data held by Prike. In this case, Prike may ask you to confirm the accuracy of the corrected information.
17.1.2. You have the right to ask Prike to erase your personal data:
17.1.2.1. if your personal data are no longer needed for the purpose for which Prike processed them;
17.1.2.2. if you withdraw your consent to the processing of your personal data and Prike has no other legal basis for processing your personal data;
17.1.2.3. if you object to the processing of personal data carried out by Prike based on a legitimate interest, and Prike does not have any legitimate reasons for the processing that outweigh your interests, rights and freedoms, or for the purpose of preparing, presenting or defending Prike’s legal claims;
17.1.2.4. if you object to the processing of personal data carried out by Prike based on your consent;
17.1.2.5. if Prike has processed your personal data unlawfully;
17.1.2.6. if your personal data have to be erased in order to fulfil a legal obligation prescribed by the law of the European Union or the Republic of Estonia applicable to Prike.
17.1.3. You have the right to demand that Prike restricts the processing of your personal data or to object to the processing of your personal data:
17.1.3.1. during the period necessary to verify the accuracy of your personal data when submitting requests related to the accuracy of the data;
17.1.3.2. In the case of unlawful collection, storage or use of your personal data, if you decide not to request data deletion;
17.1.3.3. if Prike no longer needs your personal data, but you need them to prepare, present or defend legal claims;
17.1.3.4. during the period necessary to determine whether Prike has an overriding legal basis for continuing to process your personal data if you exercise your right to object to the processing of your personal data.
17.1.4. You have the right to ask Prike to transfer the data collected based on your consent or for the purpose of performing contracts to another data controller, if Prike has processed the data automatically. If you exercise this right, Prike will provide you with a copy of the data received from you.
17.1.5. You have the right to object to the processing of your personal data in cases where Prike processes personal data to protect its legitimate interests, but Prike does not have an overriding legal basis to continue using your personal data.
18. Complaints
18.1. If you believe that your rights of a data subject have been violated, contact Prike immediately in accordance with the procedure specified in clause 10. Prike promises that upon receiving a complaint, you will be answered within a reasonable time and you will be informed about the course of the complaint procedure and subsequently of its result.
18.2. If the result of the complaint procedure is not satisfactory for you, you can contact the supervisory authority, which is the Data Protection Inspectorate of the Republic of Estonia (https://www.aki.ee/et/inspektsioon-kontaktid/inspektsioonist).
19. Responsibilities
19.1. You are responsible for the preciseness, accuracy and completeness of the data provided to Prike. If the data you provide change, you must notify Prike immediately by e-mail. Prike is not liable under any circumstances for any damage caused to you due to submission to Prike of inaccurate or incomplete personal data, or your failure to notify of changes of submitted personal data.
20. Amendment of Data Processing Policy
20.1. Prike has the right to update or amend this data processing policy at any time. Updated or amended data processing policies will be effective the moment they are published on the website of Prike. Therefore, we recommend that you visit it from time to time and make sure that the current version of Prike’s data processing policy is acceptable to you.
20.2. After updating the data processing policy, Prike will inform you of the changes that Prike considers important by publishing them on its website. By logging into the Prike E-Shop after such notice is published, you agree to the new terms and conditions set forth in the updated version. The date of updating set out below is the date Prike’s data processing policy was last updated.
Updated on 8th October 2023
