The privacy of customers’ personal data is important to VD Estate OÜ (hereinafter legaladdressinestonia.com, we, our, or us).
This Policy describes the rules according to which legaladdressinestonia.com processes the personal data of any person using the website legaladdressinestonia.com and any services offered by legaladdressinestonia.com.
1. General Definitions
Legaladdressinestonia.com Service provider who needs to process Customer’s personal data for service provision. Depending on the service the service providers are the following:
- VD Estate OÜ (registry code 16244907, address Päevalille tn 6-15, Tallinn, Estonia) who provides legal address.
- Private Financial Services OÜ (registry code 12461485, address Tornimäe tn 7-169, Tallinn, Estonia), who provides contact person service, company formation, consultancy, or any other service.
Natural person who is using the legaladdressinestonia.com website or any services provided by legaladdressinestonia.com.
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.
Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal Data processed by legaladdressinestonia.com is described under Section 3.
Any operation or set of functions that are 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.
A person who, alone or jointly with others, determines the purposes and means of processing personal data.
Depending on the service, the Controller of the Customer’s Personal Data is:
VD Estate OÜ if Customer requested legal address service.
Private Financial Services OÜ if Customer requested contact person service, company formation, consultancy or any other service.
A person who Processes Personal Data on behalf of the Controller.
In the course of the provision of Service, legaladdressinestonia.com may act as Processor by Processing Personal Data on behalf of its Customer or Customer’s legal entity. However, this Policy shall not regulate the legaladdressinestonia.com actions as Processor.
Any services provided via the legaladdressinestonia.com website.
2. Policy Applicability
This Policy applies to Personal Data Processing, where legaladdressinestonia.com acts as a Controller. Any personal data Processing conducted on behalf of the Customer or his legal entity is subject to an additional data processing agreement signed between legaladdressinestonia.com and the legal person controlled by the Customer.
3. Personal Data Being Collected
Legaladdressinestonia.com processes the following Personal Data about the Customer:
- 3.1 Personal Details – full name (surname and given name), gender, personal identification code, date of birth, nationality, contact postal address, e-mail address, mobile phone number;
- 3.2 Identification Data – data retrieved from the copy of identity document, such as document number, issue date, expiry date and issuing entity, photo;
- 3.3 Verification Data – data that legaladdressinestonia.com collects to conduct Customer due diligence under applicable anti-money laundering laws. It also includes such data as whether the Customer is politically exposed and whether the Customer is subject to any international financial sanctions.
- 3.4 Background Data – data legaladdressinestonia.com collects and Processes to conduct Customer adverse media checks via open sources;
- 3.5 Payment Data – data concerning payments for legaladdressinestonia.com and state fees, such as account number (IBAN), account holder name, bank name, and transaction details, If the Customer chooses to pay for the Service by credit card or by PayPal, their payment details are not stored by legaladdressinestonia.com and cannot be accessed by us.
- 3.6 Business-related Data – in the course of providing services, we collect and process data concerning the field of activity, the Customer, and business description;
- 3.7 Device Data – information regarding the device on which the Customer is using the legaladdressinestonia.com, including the device’s model, name or any other identifier, and the IP address;
- 3.8 Customer Support Data – communication between legaladdressinestonia.com and the Customer (inquiries submitted via the website, web chat, e-mail, or social media);
- 3.9 Usage Data – data about Customer interaction on the legaladdressinestonia.com website.
4. Sources of Personal Data collection
Most of the Customer’s Personal Data Processed by legaladdressinestonia.com is collected directly from the Customer. However, we may collect Customer’s Personal Data also from third-party sources, such as databases of financial sanctions and people subject to international financial sanctions and databases of politically exposed people. Some of these databases are publicly available, and some are not.
5. Purposes for collecting and Processing Customer’s Personal Data
Personal Data collected by legaladdressinestonia.com is Processed for the purposes established in the law or as described herein, including but limited to the following purposes:
- 5.1 Contractual Purpose – legaladdressinestonia.com needs to Process the Customer’s Personal Data to enter into a service agreement with the Customer and to provide Service to the Customer;
- 5.2 Compliance Purpose – legaladdressinestonia.com needs to Process Customer’s Personal Data in order to perform obligations under applicable laws, such as to comply with anti-money laundering requirements, combat fraud, ensure the fulfillment of international financial sanctions, abide by the lawful inquiries and orders of public authorities with whom legaladdressinestonia.com is obligated to cooperate;
- 5.3 Analytical Purpose – legaladdressinestonia.com needs to Process Customer’s Personal Data to manage, analyze and improve the Service and website;
- 5.4 Marketing Purpose – legaladdressinestonia.com needs to Process Customer’s Personal Data to send relevant promotional information to the Customer about our services and the related offerings by third parties we work with if the Customer has granted explicit consent to use their Personal Data for this purpose;
- 5.5 Personalization Purpose – legaladdressinestonia.com needs to Process Customer’s Personal Data to personalize the Service and the content provided to the Customer;
- 5.6 Communication Purpose – to contact the Customer for administrative purposes such as customer service, address technical or legal issues related to the Service provided, or share updates and notifications about the Service;
We shall not use Customer’s Personal Data for any other purpose incompatible with the purposes outlined above or required, permitted, or authorized by law.
Customer is not subject to statutory obligation which obligates Customer to provide Personal Data described herein to us. However, the collection of certain Personal Data referred to herein may be required under the law and/or inevitably necessary for the provision of service to the Customers, such as data necessary for the verification of the Customer. Failure to provide data may result in adverse consequences, such as legaladdressinestonia.com’s inability to comply with our obligations under the law. The Customer is welcome to ask for clarifications regarding the obligation to submit any specific Personal Data and also about possible consequences arising from the failure to provide the Personal Data.
6. Automated Decision Making
Legaladdressinestonia.com provides services for Customers active in certain fields of activities. Not all fields of activities are supported by us. Legaladdressinestonia.com uses automated decision-making in the pre-contractual Processing to establish whether the Customer is eligible to use our services.
Automated decision-making refers to a decision that is taken solely based on the automated Processing of a Customer’s Personal Data. This means Processing using, for example, software code or an algorithm, which does not require human intervention.
The automated decision-making is necessary for entering into an agreement with us. The automated decision-making is used in order to accept or reject the Customer’s application to enter into a service agreement with us.
7. Legal Grounds for Processing
Legaladdressinestonia.com relies on the following legal grounds when Processing Customer’s Personal Data:
- 7.1 Processing is necessary for the performance or entry into a contract between Customer and legaladdressinestonia.com (GDPR Article 6 (1) (b)), legaladdressinestonia.com is Processing Personal Data for Contractual Purpose under the contract entered into between legaladdressinestonia.com and Customer;
- 7.2 Processing is necessary for compliance with a legal obligation to which legaladdressinestonia.com is subject (GDPR Article 6 (1) (c)). We Process Personal Data for Compliance Purpose under legal obligations to which we are subject to;
- 7.3 Processing is necessary for the purposes of the legitimate interests pursued by us (GDPR Article 6 (1) (f)). We Process Personal Data for Analytical or Personalization purposes under legitimate interest;
- 7.4 Customer has granted consent to the Processing of his Personal Data (GDPR Article 6 (1) (a)). We Process Personal Data for Marketing Purposes under the Customer’s consent.
8. Transfer of the Personal Data
Legaladdressinestonia.com may transfer Customer’s Personal Data to third parties, such as:
- 8.1 legal and regulatory authorities (e.g., commercial register) whom we are obligated to disclose Customer’s Personal Data under the law;
- 8.2 server hosts who host legaladdressinestonia.com servers;
- 8.3 identification service providers who help us verify Customer’s identity and acquire Verification Data;
- 8.4 communication service providers who facilitate e-mails, calls, SMS messages, and other communication between legaladdressinestonia.com and the Customer;
- 8.5 customer support and customer management service providers;
- 8.6 marketing service providers;
- 8.7 legaladdressinestonia.com partner bank that provides banking services to the Customer or to the legal entity controlled by the Customer or any other financial service provider;
- 8.8 legaladdressinestonia.com affiliate. i.e., any company that directly or indirectly controls legaladdressinestonia.com; any company that is directly or indirectly controlled by us; or any company that is controlled, directly or indirectly, by the ultimate parent company of us. Control shall mean owning more than fifty percent of the voting rights in a company or otherwise having the power to govern the financial and the operating policies or to appoint the management of a company;
- 8.9 other parties involved with the provision of legaladdressinestonia.com service (accountants, auditors, lawyers, IT systems suppliers and support, or any other outsourcing providers).
Legaladdressinestonia.com has taken steps to ensure that these data recipients protect the confidentiality and security of Personal Data and to ensure that Personal Data is Processed only for the provision of Service and in compliance with applicable law.
Such third parties may be located in countries outside of the European Economic Area (“EEA”) whose privacy regulations may differ and which are not subject to adequacy decisions of the European Commission. In those countries, the security of the Personal Data (inc. protection against misuse, unauthorized access, disclosure, alteration, or destruction) may not be ensured as it is secured in the European Union due to the lack of adequate data protection level.
When transferring collected Personal Data outside of the EEA, legaladdressinestonia.com shall ensure the application of the appropriate safeguards. If the Customer wishes to receive a copy, please contact us as instructed below.
Legaladdressinestonia.com will take appropriate legal, organizational, and technical measures to protect Personal Data consistent with applicable privacy and data security laws. Security measures shall be applied in order to protect Personal Data from involuntary or unauthorized Processing, disclosure, or destruction.
Upon transferring Personal Data to third parties, we will apply the following safeguards:
- 9.1 legaladdressinestonia.com enters into a data processing agreement with the relevant third party;
- 9.2 legaladdressinestonia.com makes sure that such third party undertakes to implement appropriate technical and organizational measures ensuring the Processing of Customer’s Personal Data in accordance with this Policy and applicable law;
- 9.3 legaladdressinestonia.com ensures that (a) the third party is established in a jurisdiction that the European Commission has recognized as ensuring an adequate level of personal data protection, or (b) the Processing of Customer’s Personal Data is subject to other appropriate safeguards stipulated in the GDPR.
10. Integrity and Retention of the Personal Data
- 10.1 legaladdressinestonia.com will retain Personal Data for the period required or permitted by applicable law, but no longer than it is reasonably necessary in order to achieve the purposes for which the Personal Data was collected.
- 10.2 legaladdressinestonia.com takes reasonable steps to ensure that the Personal Data we Process is reliable for its intended use, accurate, and complete as necessary to carry out the purposes described herein.
11. Customer’s Rights with Regards to the Collection of Personal Data
Customer has the following rights in relation to the Processing of his Personal Data:
- 11.1 Request Information – legaladdressinestonia.com has provided all information that the Customer has the right to receive in this Policy. The valid version of the Policy is available on our website at any time.
- 11.2 Right to Access – Customer has the right to ask us to provide a copy of the Customer’s Personal Data which legaladdressinestonia.com processes.
- 11.3 Right to Rectification – Customer has the right to ask us to rectify Personal Data if the data is incorrect or incomplete.
- 11.4 Right to Erasure – Customer has the right to ask us to erase Personal Data unless we are obliged to continue Processing Customer’s Personal Data under law or a contract between the Customer and legaladdressinestonia.com, or in case we have other lawful grounds for the continued Processing of Personal Data.
- 11.5 Right to Restriction – Customer has the right to ask us to restrict the Processing of his Personal Data in case the data is incorrect or incomplete or if his Personal Data is Processed unlawfully.
- 11.6 Right to Data Portability – Customer has the right to ask us to provide the Customer or, in case it is technically feasible, a third party, his Personal Data, which the Customer has provided to us and which is Processed in accordance with Customer’s consent or a contract between the Customer and legaladdressinestonia.com.
- 11.7 Right to Object – Customer has the right to object to Processing his Personal Data if there is a reason to believe that legaladdressinestonia.com has no lawful grounds for Processing the Personal Data.
- 11.8 Right to Withdraw Consent for the Processing of Personal Data – Customer is entitled to withdraw the consent granted for the Processing of Personal Data at any time. Withdrawal does not affect the lawfulness of the Processing conducted before the withdrawal.
- 11.9 Right to File Complaints – Customer has the right to file complaints regarding the Processing of his Personal Data.
In order to exercise any rights referred herein, the Customer is required to submit a written application to legaladdressinestonia.com (Our contact details can be found under Section 16). We have the right to decline this application by justifying the reasons for the refusal.
According to the article 12(3) of GDPR, we are obligated to respond to the application within 1 month. However, we will do our best to respond to the Customer’s request within 1 week.
12. Cookies and Tracking Technologies
We are using automatically collected information and other information collected within its website through cookies and similar technologies.
Cookies are small text files that a website or its service provider transfers to the Customer’s computer hard drive through his website browser (if the Customer allows) that enable the website’s or service provider’s systems to recognize Customer’s browser and capture and remember certain information. For example, cookies may help a website remember certain preferences the Customer has selected on the website, such as language preferences.
- 12.1 Within the website legaladdressinestonia.com uses the following types of cookies:
- 12.1.1 first-party cookies, which are stored on the Customer’s device by legaladdressinestonia.com. These cookies allow website owners to collect analytics data, remember language settings, and perform other useful functions that provide a good user experience;
- 12.1.2 third-party cookies, which are stored on the Customer’s device by other service providers on the legaladdressinestonia.com website. We may use third-party analytics tools (such as Google Analytics) to help us measure traffic and usage trends for our Service. Web analytic service providers analyze the usage of the legaladdressinestonia.com website and services so that we can improve and amend our website and function thereof.
- 12.2 Cookies are being used to serve the following purposes:
- 12.2.1 to store authentication information and protect Personal Data from third parties;
- 12.2.2 to personalize our Service, help remember Customer’s choices within the website, understand and save Customer’s preferences for future visits;
- 12.2.3 to provide customized advertisements, content, and information;
- 12.2.4 to track Customer’s entries, submissions, and status in any promotional or other activities on the Service;
- 12.2.5 to monitor and analyze the effectiveness of the Service;
- 12.2.6 to compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future.
The Customer can delete or block cookies through his browser settings at any time. However, some cookies might be necessary for the functionality of the legaladdressinestonia.com Services and usage of the website. Therefore, the Customer understands that when blocking or deleting the cookies, some features within the website might not function correctly. For more general information about cookies, please see gdpr.eu/cookies.
13.3 Google Display Network Impression Reporting
Legaladdressinestonia.com, along with third-party vendors, such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies or other third-party identifiers together to compile data regarding Customer interactions with ad impressions and other ad service functions as they relate to our website.
Customers can set preferences for how Google advertises to them using the Google Ad Settings page. Alternatively, the Customer can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add-on.
Legaladdressinestonia.com uses Google Analytics to measure and evaluate access to and traffic on the public area of our website and create user navigation reports for our website administrators.
We take measures to protect the technical information collected by using Google Analytics. The data collected will only be used on a need-to-know basis to resolve technical issues, administer the website and identify visitor preferences.
14. Commercial Communication
If a Customer receives commercial e-mails from us, he may unsubscribe at any time by following the instructions contained within the e-mail or by sending an e-mail to firstname.lastname@example.org.
The Customer can view and modify settings relating to the nature and frequency of promotional communications that they receive from us by accessing the “Settings” section in the restricted area of the website.
The Customer has to be aware that if he opts out of receiving commercial e-mails from us or otherwise modifies the nature or frequency of promotional communications he receives from us, it may take up to five (5) business days for us to Process the request. Additionally, even after they opt-out from receiving commercial messages from us, they will continue to receive administrative notifications from us regarding the Service.
15. Right to Amend this Policy
Legaladdressinestonia.com is entitled to amend this Policy from time to time unilaterally. Upon amending the Policy, we will notify the Customer about the terms by e-mail. If the new terms refer to Processing of Customer’s Personal Data for any new purpose, which requires Customer’s consent, then we will not Process Personal Data for a such new purpose before it has received respective consent.
16. Contact Information
Should the Customers have any questions regarding this Policy or Processing of Personal Data, they are welcome to contact us with requests, inquiries, or any complaints via e-mail: email@example.com.
By accepting this Policy, the Customer confirms that he has familiarized himself with it, understood it, and agreed to its terms. Last updated: 15.09.2022