PRIVACY POLICY
EFFECTIVE NOVEMBER 2024
PREAMBLE
“EXTELA” is grateful that you trust us with your information and wants to show you how seriously we take your trust.
Through this Privacy Policy, we aim to clarify what information you provide access to and how. Our Privacy Policy is designed to ensure transparency in our operations, provide an understanding of what information we collect, why we collect it, how your personal information is used, and what rights you have regarding any information provided.
GENERAL PROVISIONS
1.1 We aim to ensure maximum confidentiality and security for Users at all times while using the Website. In this Policy, "You" and "User" refer to a natural person, legal entity, or any other organization formed in accordance with the legislation of your country of residence, which uses the "EXTELA" Website.
1.2 In this Policy, the terms are used in the following meanings:
data Controller – a natural or legal person who determines the purpose of personal data processing, establishes the composition of such data, and procedures for their processing;
consent of the data subject – the voluntary expression of the will of a natural person (provided they are informed) regarding the permission to process their personal data according to the formulated purpose of their processing;
personal data processing – any action or set of actions such as collection, recording, accumulation, storage, alteration, updating, use, and dissemination (distribution, sale, transmission), depersonalization, destruction of personal data, including using information (automated) systems;
personal data – information or a set of information about a natural person who is identified or can be identified;
data Processor – a natural or legal person authorized to process personal data in accordance with the law or the data Controller`s permission;
data Subject – a natural person whose personal data is being processed.
1.3 We inform you that according to the GDPR (General Data Protection Regulation) and other relevant regulatory acts, the data Controller is the Limited Liability Company "EXTELA" (Tallinn, Lasnamäe linnaosa, Katusepapi tn 6-502, 11412, registration code: 16921400, VAT number: EE102732179).
1.4 This Privacy Policy applies to all users of the "EXTELA" Website and establishes the rules under which your personal data provided by you will be processed by "EXTELA".
1.5 By using the "EXTELA" Website, you automatically and fully agree to this Policy and the "EXTELA" User Agreement.
RELATIONSHIPS COVERED BY THE PRIVACY POLICY
2.1 This Privacy Policy (hereinafter referred to as the "Policy") applies exclusively to personal data processed by "EXTELA" during your use of the Website. The Policy does not extend to any other websites and/or applications or other web materials of third parties, including those linked to by "EXTELA." Any information and personal data you provide to such third parties are processed by them independently based on their approved Privacy Policies.
2.2 "EXTELA" recommends that you carefully review this Policy, as well as any other privacy policies applicable to third-party web materials.
2.3 "EXTELA" is not responsible for the application of the privacy policies of any third parties. "EXTELA" takes all appropriate measures to ensure that the materials linked on the Website have privacy policies that align with our principles and objectives.
2.4 If you have any questions regarding the Privacy Policy, please refer to our contact information provided in Section 10 (Contacts).
INFORMATION RECEIVED FROM USERS
3.1 When you send us a request via email or through the "Contact us" section of this Website, we receive your personal data. Such personal data is stored only for the period necessary to fulfill your request.
3.2 The list of personal data we collect through the Website includes:
your first and last name, phone number, email address;
biographical or demographic data if it is integral to the personal data.
3.3 "EXTELA" may collect other information through your activity on and off the Website, which does not require your personal identification or does not directly relate to you as a user. Such information may include, but is not limited to:
a unique identification number located on your computer, mobile phone, or other device;
Internet Protocol (IP) address and information derived from it, including geolocation data. Geolocation data may be collected using IP address, satellites, cell towers, or Wi-Fi signals. Location information may be used as part of certain features of the Website. By using the Website, you agree to the collection of information about your location;
information about your device, internet protocol signals, browser, device type and version, operating system, screen resolution information, and selected language;
behavioral data, such as websites visited and areas of content, dates, and times of activities;
web search data used to determine location and navigation of internet resources.
3.4 Additionally, we may collect your personal data through other forms on this Website, when entered into the Website's functionality, via electronic correspondence, and through other online tools. "EXTELA" takes measures to ensure that personal data necessary to fulfill a request is collected to the minimum extent sufficient to allow "EXTELA" to promptly process the request. "EXTELA" has the right to request additional information to provide the most appropriate response to your request.
3.5 "EXTELA" also receives your personal data by entering into a contract. When entering into a contract with "EXTELA" and during the term of the contract, "EXTELA" collects and stores your personal data. The parties to the contract may mutually agree to regulate the processing of personal data differently than provided by this Policy.
3.7 "EXTELA" may obtain information about you from publicly available sources, such as trade registers, commercial registers, publicly accessible internet resources, etc.
3.6 The purpose of collecting your personal data through the execution of a contract with "EXTELA" is to enable business relations, including conducting negotiations, providing consultations, and fully exercising rights and obligations as business entities. Providing personal data for this purpose is voluntary. However, if you do not provide such personal data, business relations with "EXTELA" are impossible.
3.8 "EXTELA" does not collect your sensitive personal data. Within this Policy, sensitive personal data is understood as data related to racial or ethnic origin, political opinions, religious or similar beliefs, physical or mental health.
3.9 Providing any personal data is voluntary. By providing "EXTELA" with any personal data, the user consents to its processing.
3.10 The purpose of collecting personal data through the Website is to enable contact with the User to provide personalized consultation and/or send marketing materials.
3.11 To ensure a better user experience while using the Website, "EXTELA" may use third-party services for traffic optimization and distribution. The respective service providers have their own privacy policies that apply to operations performed by them. These providers also use cookies.
COOKIES
4.1 Cookies are small text files that are transferred to your mobile device during your use of the Website after your consent (where required). Cookies help remember your preferences, keep you logged in, allow efficient navigation between pages, and generally improve the functioning of the Website. Some cookies are essential for the functioning of the Website and/or help enhance performance and provide analytical data. Some cookies are used for marketing purposes.
4.2 During your use of the Website, "EXTELA" uses necessary cookies. These cookies are intended for navigation, service provision, and security threat prevention.
4.3 Functional cookies are designed to remember user choices on the Website. Functional cookies help remember each user's settings made while using the available features. If you disable these cookies, certain sections or parts of the Website may not function properly.
4.4 Performance cookies allow "EXTELA" to track visits and traffic sources. These cookies are used to evaluate and improve the performance of the Website. Performance cookies enable "EXTELA" to assess and analyze how users use the Website, which helps determine which pages are the most popular and which are the least. This data can be used to improve the user experience.
4.5 Targeting or advertising cookies allow the display of advertisements tailored to the user. These cookies limit the number of times a specific advertisement is shown to the user and help "EXTELA" measure the effectiveness of marketing campaigns. "EXTELA" may use information obtained through such cookies to offer advertisements that may be of interest to a particular user based on previous online behavior. "EXTELA" has the right to share this information with third parties.
4.6 Users have the ability to view and change their cookie usage settings. Users have the right to accept or decline the use of cookies. Refusing the use of necessary and functional cookies may result in limited access to certain features of the Website. Users have the right to withdraw their consent to the use of cookies at any time.
PROCEDURE FOR PROCESSING AND DISCLOSURE OF INFORMATION
5.1 "EXTELA" guarantees that it does not sell, lease, or otherwise disclose users' personal data to third parties, whether for payment or free of charge, temporarily or permanently, except in cases explicitly provided for by this Policy.
5.2 "EXTELA" reserves the right to engage third parties for the purpose of providing analytical services regarding the use of the Website by users. Such actions may be undertaken to analyze Website usage, to determine whether changes or updates to the Website are functioning properly and are fully perceived by users. Third-party services may also be used for advertising customization purposes.
5.3 Service providers engaged by "EXTELA" may use cookies and other technologies to collect information, including users' IP addresses; web browsers; mobile network information; pages viewed; time spent viewing certain information; completion of test tasks; clicked links and transitions (third parties cannot be provided with information you directly provide, such as your name, email address, mailing address, or phone number).
5.4 As the data controller, "EXTELA" may use information about you solely to achieve the purposes outlined in this Privacy Policy and only in cases where such use is permitted by applicable law.
5.5 Personal data you provide directly may be disclosed as follows:
to service providers, particularly regarding data storage, with which "EXTELA" maintains the operation of the Website;
to business partners, including but not limited to advertising service providers, in accordance with applicable law;
to government bodies or local authorities, law enforcement agencies, if the obligation to transfer information is stipulated by law, or for the purpose of protecting the rights of "EXTELA" or the rights of third parties;
to other third parties, with the User's consent or otherwise if required or permitted by law, including to comply with a court order that has entered into legal force.
5.6 Automatically collected data may be disclosed as follows:
To service providers, particularly companies providing data analysis services;
To business partners, including but not limited to advertising service providers, in accordance with applicable law;
To government bodies or local authorities, law enforcement agencies, if the obligation to transfer information is stipulated by law, or for the purpose of protecting the rights of "EXTELA" or the rights of third parties;
To other third parties, with the User's consent or otherwise if required or permitted by law, including to comply with a court order that has entered into legal force.
5.7 "EXTELA" has the right to disclose information to third parties in a consolidated format, that is not personal data and does not allow identifying individual Users. Information may be collected and presented in summary form for statistical analysis.
USER RIGHTS
6.1 Right to Information. Users have the right to know the sources of the collection, the location of their personal data, the purpose of its processing, and the location or place of residence (location) of the data controller or processor, or to give an appropriate instruction to obtain this information to authorized persons, except in cases established by law.
6.2 Right to Erasure. Users can request the deletion of any information provided directly by them and/or automatically collected during the use of the Website. You can withdraw your consent to the processing of personal data at any time by sending a statement containing the following:
Your name and surname (the person giving consent), address of residence, and date of birth, which are necessary for identification;
Recipient details (EXTELA);
A statement that you no longer wish your personal data to be processed by "EXTELA" for certain purposes;
Your signature.
6.3 You have the right to send a statement signed with an electronic digital signature to the email address: chief@extela.co or a statement signed with your handwritten signature to the postal address: Tallinn, Lasnamäe linnaosa, Katusepapi tn 6-502, 11412.
6.4 Right to Object. Users can request "EXTELA" to stop processing data for direct marketing purposes as well as for other purposes.
6.5 Right to Rectification. Users have the right to correct or update incomplete, incorrect, outdated, or unnecessary personal data.
6.6 Right of Access. Users can request access to personal data held by "EXTELA" or request a copy of such data. To exercise this right, users can contact "EXTELA" by sending a letter to the email address: chief@extela.co.
6.7 Right to Data Minimization. This right obliges "EXTELA" to take measures to ensure that the data collected from the User during the use of the Website is sufficient only to achieve the purpose for which the relevant information was collected.
6.8 Right to Be Informed. "EXTELA" informs Users about the processing of personal data, the purposes of processing, data transfer, storage, and distribution rules. "EXTELA" provides necessary information and contact details for communication. Users have the right to contact "EXTELA" at any time to resolve any issues arising during the use of the
6.9 Right to Non-Discrimination. Users have the right not to be discriminated against for exercising any of their privacy rights.
6.10 Right to Opt-Out of Marketing Communications. Users can opt-out of receiving direct marketing emails from "EXTELA".
6.11 Right to Protection of Personal Data. Users have the right to protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of false information or information that tarnishes the honor, dignity, and business reputation of an individual.
6.12 Right to Legal Remedies. Users can apply legal remedies in case of a violation of personal data protection laws.
6.13 Right to Object to Automated Decisions. Users have the right to protection from automated decision-making that has legal consequences or otherwise significantly affects them.
SECURITY MEASURES
7.1 “EXTELA” takes reasonable measures to protect Users' personal information from unauthorized access, loss, misuse, or alteration by third parties. To implement these measures, Users' personal information is stored in a secure database with strict restrictions and controlled access using encryption.
7.2 Despite the measures taken by “EXTELA” to safeguard personal data collected on and through the Website in a secure operational environment that is not publicly accessible, “EXTELA” cannot guarantee the security of personal data during transmission or storage in respective systems.
7.3 “EXTELA” cannot guarantee that the security measures implemented in accordance with this Policy will prevent third parties from illegally accessing personal data. “EXTELA” cannot ensure that Users' personal data will be protected from loss, misuse, or alteration by third parties.
7.4 In the event of a security breach, the User will be immediately informed about the breach, and necessary measures will be taken to address the issue.
7.5 To protect data, Users should follow basic security principles, such as preventing unauthorized access to personal devices.
DATA STORAGS
8.1 “EXTELA” retains personal data only as long as necessary to achieve the purposes outlined in this Privacy Policy.
8.2 Upon the User's request, “EXTELA” will delete the data within a reasonable timeframe. Outdated and/or unnecessary data for the original processing purpose may be deleted unilaterally by “EXTELA”.
CHANGES TO THE PRIVACY POLICY
9.1 “EXTELA” reserves the right to amend this Privacy Policy at any time without prior consent from Users. The new version of the Policy becomes effective upon its publication. The effective date of the latest version can be found at the top of this Policy.
9.2 In the event of significant changes affecting the ways in which personal data is used and disclosed, a notice will be published.
9.3 “EXTELA” recommends that Users regularly review the Privacy Policy to stay informed about privacy practices. Continued use of the Website after any changes to this Privacy Policy constitutes acceptance of those changes.
CONTACTS
10.1 If you have any questions, complaints, or comments regarding the implementation of this Policy and the use of the Website, you have the right to contact us at the following email address: chief@extela.co / nm@extela.co