Privacy Policy

Definitions

“GDPR” — 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 (General Data Protection Regulation).

User — a natural or legal person using the vininfo.ee website. 

Applicable law — all applicable legal acts of the European Union and all applicable legal acts of the Republic of Estonia, including, but not limited to, national implementing acts of the GDPR.

Services — all services provided to Users via the VINinfo.ee website.

Personal Data — any information relating to an identified or identifiable natural person (data subject).

VINinfo.ee — VIN Solutions OÜ (registration code: 14071883, location: Pärnu mnt 141, 11314 Tallinn, website: VINinfo.ee)

Website — VINinfo.ee, its subdomains, or other websites managed by VINinfo.ee. 

Processing — any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Controller — a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. In these privacy terms, the controller is VINinfo.ee.

General Provisions

These personal data processing terms apply (the “Privacy Policy”) when a User uses, has used, or has expressed a wish to use VINinfo.ee’s Services or when a User uses the VINinfo.ee Website.

This Privacy Policy describes the general principles of personal data processing. Additional terms for processing a User’s personal data may be set out in a contract(s) concluded with the User or in the User’s consent.

If a User has questions about the processing of their personal data or wishes to exercise their rights related to data processing, please contact VINinfo.ee using the contact details provided in the “Contact” section below. 

Personal Data

Purposes and Legal Grounds for Processing

VINinfo.ee processes User’s Personal Data for the following purposes and on the following legal bases:

• To deliver Services and to contact the User in connection with the Services.

• To assist and advise the User if the User has sent a corresponding inquiry. In this case, the legal basis for processing depends on the purpose of the inquiry, but generally it is necessary for the provision of the requested Service or for VINinfo.ee to fulfil a legal obligation (for example, when the inquiry is related to exercising the User’s rights). 

• To fulfil VINinfo.ee’s legal obligations (for example, VINinfo.ee may be obliged to provide competent authorities, upon their request, information that allows identifying those Users who ordered the Service, and to retain accounting documents for the period prescribed by law).

If the processing of Personal Data is based on VINinfo.ee’s legitimate interest, the User has the right to object at any time.

VINinfo.ee will process User’s Personal Data for other purposes only with User’s prior consent. 

Data Collection

When ordering a Service, VINinfo.ee requests the following data about the User, which are necessary for the provision of the Service: email address. 

During the provision of the Service, VINinfo.ee may receive the following data about the User: payment data for the Service (e.g. bank account number from which payment is made); other data obtained in the course of providing the Service. 

If the User sends a request to VINinfo.ee using the form on the Website or via e-mail, VINinfo.ee collects the following data (if provided by the User): the User’s name; the User’s revealed e-mail address; the content of the User’s request or other message; other data provided by the User when submitting the request. 

Data Sharing with Service Providers (Authorized Processors)

VINinfo.ee has the right to use authorized processors for processing User’s Personal Data.

For example, VINinfo.ee uses IT service providers when processing personal data. It may also use other service providers and partners (for example, marketing partners, server providers, payment service providers, etc.). 

When using authorized processors, VINinfo.ee ensures that it enters into a data processing agreement with them, obligating them to process personal data in accordance with applicable law and this Privacy Policy. VINinfo.ee is responsible for the activities of authorized processors in relation to User data processing.

Disclosure of Personal Data to Third Parties

In certain cases, VINinfo.ee may disclose User’s Personal Data to the following third parties: 

• Supervisory, investigative, or law-enforcement authorities when required by law. In such cases, the legal basis is VINinfo.ee’s obligation to comply with applicable law. Where reasonably possible and unless prohibited by applicable law or the authority, VINinfo.ee will inform the User about the disclosure. 

• Legal advisors and auditors, if necessary for them to perform their duties to VINinfo.ee, provided they maintain confidentiality. The disclosure basis may be VINinfo.ee’s legal obligation or legitimate interest (for example, if the User has breached terms or VINinfo.ee needs to protect its rights). In such cases, the User’s interests or rights do not outweigh VINinfo.ee’s legitimate interest.

Data Retention

VINinfo.ee retains User’s Personal Data as long as necessary to fulfil the purposes for which the data were collected, to uphold and protect its rights, or for as long as required by applicable law. 

• Personal Data generated during the use of a Service may be retained up to 10 years after termination of the contract with the User.

• Personal Data related to the performance of the Service, which must be retained for accounting purposes, will be kept at least 7 years after the end of the calendar year in which the transaction occurred.

Data Protection

VINinfo.ee implements necessary security measures to protect clients’ Personal Data. 

Rights of the Data Subject (User)

VINinfo.ee ensures the following rights for Users, as stipulated by applicable law: 

Depending on what is required and allowed by the applicable laws (particularly Chapter III of the GDPR), the User has the right to:

• request access to their personal data held by VINinfo.ee; 

• request correction of their personal data if data are incomplete, inaccurate, or outdated; 

• object to the processing of their personal data; 

• request deletion of their personal data, e.g. when processing is based on consent and the User has withdrawn consent, or if there is no other valid legal basis for processing; 

• request restriction of processing (e.g. if VINinfo.ee no longer needs the data for processing purposes or the User has objected to processing);

• withdraw consent at any time, if processing is based on consent; 

• request portability of their personal data — get the data they have provided to VINinfo.ee in a structured, commonly used, machine-readable format, and, if technically feasible, request that VINinfo.ee transmit these data to another data controller;

• lodge a complaint — if the User believes their rights under data protection laws have been violated, they have the right to file a complaint with the supervisory authority or bring the matter to court. 

These rights are not absolute: in certain cases the interests or rights of other data subjects or the obligations of VINinfo.ee may limit these rights. 

VINinfo.ee may require additional information to confirm the identity of the User requesting exercise of these rights. 

VINinfo.ee will respond to a User request within 1 month and inform the User what measures have been taken. If the request is complex or numerous, the response time may be extended by 2 months. If VINinfo.ee does not act on the User’s request, it will state the reasons and explain the possibility to file a complaint with the supervisory authority or bring a case to court. 

To keep the User’s personal data up to date, the User must inform VINinfo.ee of any changes to their data and update the data in their user account. 

Controller and Contact Information

When using VINinfo.ee, the data controller is VIN Solutions OÜ (registration code: 14071883, location: Turu 2, 51014 Tartu, website: www.vininfo.ee). 

To exercise your rights, get further clarification, or lodge a complaint against VINinfo.ee, please contact VINinfo.ee via the contact details provided on the Contact page. 

Cookies

Cookies are small text files stored by websites, associated with the visited website.

Cookies may be session cookies (allowing to link a User’s activities within the same browser session, i.e. until the browser window is closed or until 4 hours after the last page view) or persistent cookies (stored on the User’s device for a duration defined by the cookie and activated each time the User visits the website from which the cookie was set). 

For the installation of essential cookies, VINinfo.ee does not ask the User’s consent, if the User has expressed a wish or given consent to use a Service that cannot function without such cookies. 

VINinfo.ee uses only essential (strictly necessary) cookies — necessary for navigation on the website and use of its functions. Without these cookies, the User cannot access the services they requested.

Changes to the Privacy Policy

VINinfo.ee reserves the right to modify the terms of the Privacy Policy if necessary. Website visitors are not separately notified of changes. Visitors are obliged to review the Privacy Policy before using the website each time.

Consent to the Privacy Policy

By using the VINinfo.ee website, you agree to the terms of the Privacy Policy.

Terms of Use

Please read the Terms of Use on the Terms page.