The objective of the privacy policy of SIA Hepsor is to provide you (data subject) with the information on the legal and actual conditions of your personal data processing, namely, information on the purpose and scope of personal data processing, data protection, as well as other information regarding the processing of your personal data. If you have any questions on your personal data processing, do not hesitate to contact us by using the contact information indicated in this Privacy Policy.

I. Controller and Contact Information Thereof

1.1. Personal data processing controller is AS Hepsor (hereinafter – HEPSOR), Järvevana 7b, Tallinn, 10112, tel.  +372 660 9009, e-mail: info@hepsor.ee.

II. The Purposes and Legal Basis for Personal Data Processing

2.1. The purposes for personal data processing are as follows:
2.1.1. Personnel management;
2.1.2. Marketing, offer, mediation, provision and development of various residential property services;
2.1.3 Implementation of the legitimate interests of HEPSOR and its customers: elimination of unsubstantiated financial risks for the commercial activity; administration of payments; improvement of services and development of new services, including by means of customer satisfaction surveys;
2.1.4. Marketing research;
2.1.5. marketing (analysis, profiling, performance of segmentation and statistics for the reaching of aforementioned objectives).

2.2. The purposes of data processing, indicated in Section 2.1. of the Privacy Policy are indicative in nature and personal data may also be processed for such directly unstated purposes that are closely linked to previously indicated purposes and are required for the purposes of the enforcement of the requirements of regulatory enactments.

2.3. HEPSOR shall process your personal data on the basis of the following legal grounds:
2.3.1. In accordance with clear, free and explicit consent provided by you as a data subject;
2.3.2. Data processing derives from your contractual liabilities or data processing is required on the basis of your request as a data subject, in order to conclude a respective contract;
2.3.3. Data processing is required to perform a legal duty that applies to HEPSOR;
2.3.4. Data processing is required for the enforcement of the legal interests of HEPSOR or a third party.

III. Recipients of Personal Data

3.1. Categories of personal data recipients: data subject, HEPSOR and personnel authorised by them, co-operation partners and processors of HEPSOR, central government and municipal institutions in the cases provided for by the regulatory enactments.

IV. Forwarding of personal data to a third country or an international organisation and adoption of automated decisions

4.1. HEPSOR does not intend to forward personal data to third countries, namely, outside the EU and EEA countries or to international organisations.

4.2. Adoption of automated decisions is not practised at HEPSOR.

V. Storage of Personal Data

5.1. HEPSOR shall store personal data no longer than required for the reaching of the respective objective of personal data processing, as well as to implement the requirements provided for by the regulatory enactments (for instance, the law “On Accounting”). Upon the reaching of the purpose of personal data processing, we will destroy your data.

5.2. Storage of your personal data for a longer period may be performed only in the event, where:
5.2.1. It is required by us to ensure the protection of our rights due to claims, complaints or requests;
5.2.2. A grounded suspicion on illegal activities that require the performance of investigation exist;
5.3.2. Your data are required for the appropriate investigation of a dispute or a complaint.

VI. Rights of the Data Subject

6.1. You are entitled to access your personal data; to request to correct and erase them; to limit processing of the data; you are entitled to transferability of the data; you are entitled to object to the processing of your personal data and not to be a subject of automatic processing (profiling).

6.2. You are entitled to recall the consent to data processing that you have given to us at any moment. The recall of consent does not affect the legality of the processing of personal data that has been performed on the basis of your consent given prior to recalling thereof.

6.3. If you believe that we are processing your data in violation of the requirements of the regulatory enactments that govern personal data protection, we invite you to apply directly to us.

6.4. If you are not satisfied with the answers provided by us and substantiation thereof or if we, in your opinion, fail to perform the required actions, you will be entitled to submit a complaint to a supervising institution.

VII. The Need to Provide Personal Data

7.1. The obtained personal data are used for the provision of the respective services and for the reaching of the purposes determined by HEPSOR to the degree required, in accordance with the requirements of the regulatory enactments. In the event, where personal data are not provided, HEPSOR shall have no legal basis to provide the respective service to the data subject.

COOKIES POLICY

Ltd “Hepsor” (hereinafter – HEPSOR), legal address: Citadeles Street 12, Riga, LV-1010, phone:  +371 67 133 177, e-mail: info@hepsor.ee, hereby undertakes to ensure site visitor (hereinafter – Visitors or you) private information safety and protection of rights while using our Web site www.hepsor.ee (hereinafter– Site) and the content thereof.

This Policy, as well as our Privacy Policy explains the factual and legal circumstances of data processing (data receiver categories, data subject rights, data transfer to third party countries, automated decision-making, including profiling, etc.).

I. GENERAL INFORMATION ABOUT COOKIES

The HEPSOR Site uses cookies. Cookies allow personalizing the Site according to your preferences, improve browsing and the use of our Site.

 What are cookies?

Cookies are small text files that are sent to your computer or mobile device during web site visits and saved by the web site on your computer or mobile device when you open the web site. During every following visit, cookies are sent back to the original homepage or another homepage that recognizes the cookie. Cookies operate as the memory for the specific homepage, allowing it to remember your computer during following visits – cookies can also remember your settings and improve user experience. Get additional information about cookies and managing or deleting them at www.aboutcookies.org.

 II. PURPOSE AND SCOPE OF USING COOKIES

Purpose of using cookies

By using cookies, HEPSOR aims to:

• ensure effective and safe operation of the Site;
• improve Site operation; by monitoring the use of cookies, HEPSOR can improve the Site’s electronic service capacity, improve the existing services, improve functions, and analyse capacity whenever you visit our Site from other sites, devices or equipment;
• recognise recurring Site Visitors (this helps in showing Visitor-appropriate information by personalizing it for individual consumer needs);
• analyse your habits to ensure a comfortable and efficient Site experience that is relevant to your needs and expectations, ensuring, for instance, that you can easily find everything you’re looking for;
• measure the flow of data and information sent to the Site (HEPSOR uses cookies for collecting statistical data on the number of Site user visits);
• develop statistics which allow to understand how our Site is used, which helps to improve its structure and content;
• save user session (after log-in) which allows avoiding the need to log-in to every service sub-site.

Cookies allow saving the following data by the Site:

• log-in data (logged-in device IP address, log-in time);
• browser type;
• Site browsing data (which pages you visited, what kind of information and news interests you).

III. COOKIES USED IN THE SITE

The HEPSOR web site may include the following types of cookies:

1. required (mandatory) cookies which enable using the services available on the web site, such as cookies authentication, which is needed for service authentication within the website;
2. analytical (marketing and statistical) cookies, such as Google Analytics, Google Tag manager, Gemius, Facebook pixel, which enable compiling information about the use of Internet sites; functional cookies allow to remember user settings and personalize user interface, like the chosen language or user location, font size, site view, etc.
3. Content creation platforms, such as YouTube, Vimeo etc., allow us to ensure your audio, video and other content while using these platforms.
   An example for one of such programs, its goal and intended process to ensure the relevant company does not receive information about your activities, is provided below.

Google Analytics

Cookies by the “Google Analytics” program developed by “Google Inc” are installed on the Site. The goal of using “Google Analytics” cookies is to improve the Site content and personalize according to the user’s needs. Find out more about the Terms and Conditions of using the “Google Analytics” service on the web site http://www.google.com/analytics/terms/us.html.

If you don’t want HEPSOR to have access to information about your activities on the Site, you need to activate the Google Analytics Opt-out Browser Add-on (https://support.google.com/analytics/answer/181881). This add-on will contact Google Analytics JavaScript (ga.js) and signal that data on the visit of the relevant Internet site cannot be sent to “Google Analytics”.

IV. COOKIE DECLARATION

HEPSOR uses cookies to personalize content and ads, ensure social media functionality and analyse our data flow. Information about how you use our site is also shared by HEPSOR with its social media, marketing and analysing partners who may combine it with other information provided to them or collected by them when you use their services.

All HEPSOR cookies can only be used with your prior consent. You can consent to the use of cookies by clicking on “I Accept” in the pop-up cookie bar at the bottom of the Site.

Please note that required cookies are essential for using the Site, therefore the use of these cookies does not require user consent. By clicking on “I Do Not Accept” or disabling cookies, the user will not be able to fully and comfortably use all functions provided by the HEPSOR homepage.

You can withdraw your consent at any moment according to the procedure set forth under the following section of this Policy.

V. DISABLING AND BLOCKING COOKIES

You can control and delete cookies as you wish. Learn more here: www.aboutcookies.org. You can delete all cookies on your computer, and most browsers can be set to block downloading cookies onto your computer. However, in that case you will need to manually adjust your settings every time you visit our Site, and there is a chance that some services and functions will not work properly.

Blocking cookie download or deleting cookies deactivated some of the functions on our web sites, especially those where log-in is required. Disabling cookies does not affect the ability to read or view the content on our web sites, except wherever log-in is required.