Privacy policy
CARSLAND OÜ PRIVACY POLICY
This privacy policy has been drawn up in accordance with Regulation (EU) No 2016/679 of the European Parliament and of the Council 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 (hereinafter the Regulation), the Personal Data Protection Act of the Republic of Estonia, and the legislation of the Republic of Estonia and the European Union. This privacy policy governs the principles concerning the collection, processing and storage of personal data and applies to the customers of Carsland OÜ and to potential customers who have expressed a wish for and/or an interest in the services offered by Carsland OÜ. The controller of personal data is Carsland OÜ (registry code: 16148354; Räpina mnt 13/1, Võru, 65606, Estonia).
By using the services of Carsland OÜ, a customer who is a private individual (hereinafter the Data Subject) consents to the processing of their personal data in accordance with the conditions set out below. Without such processing of personal data, the data subject cannot use Our services. All personal data collected about the Data Subject are necessary for the provision of the services offered by Carsland OÜ, and all personal data submitted by the Data Subject are processed in accordance with the requirements described in the Regulation. Carsland OÜ has the right to amend the privacy policy in part or in full, notifying data subjects of the changes via the website (www.carsland.ee). In accordance with the Regulation, Carsland OÜ protects the personal data and privacy of the Data Subject and applies all reasonable precautions (including administrative, technical and physical measures) to protect the personal data of the Data Subject. Carsland OÜ grants access to the personal data of the Data Subject only to authorised persons. DEFINITIONS Customer – a natural or legal person who uses, has used or has expressed a wish to use the services offered by Carsland OÜ, or who is connected in some other way with the services offered by Carsland OÜ.
Data Subject – a natural person about whom Carsland OÜ holds information and data enabling the person to be identified. Data Subjects are, for example, customers who are natural persons, visitors, persons submitting enquiries and questions/applications, cooperation partners, representatives who are natural persons of customers that are legal persons, and, in the case of the rental service, in addition to the lessee, the data of the user of the rental vehicle.
Personal data – any information about an identified or identifiable data subject.
Processing – any automated or non-automated operation performed on personal data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation and alteration, making enquiries, reading, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, destruction and the like. PROCESSING OF PERSONAL DATA
Carsland OÜ processes the following personal data: 1) Data enabling identification of the Data Subject: name, contact details, including e-mail and telephone number, personal identification code and date of birth, the data subject’s sex and nationality, a copy of an identity document, bank account details. 2) Data concerning the Data Subject’s right of representation:
data on the person’s connection with legal persons (e.g. data submitted by the person or appearing in public registers, the basis of the right of representation or other connections for carrying out transactions and acting on behalf of a legal person); data on authorisations (the personal data of the users of rental vehicles). 3) Data on the vehicle being rented: location data of the vehicle (in the case of rented vehicles); data on insurance events relating to the vehicle; 4) Other data: data relating to the services (including quotations, correspondence, telephone communication, data obtained through communication taking place in any other manner, applications, complaints and the like); other data of the Data Subject obtained in the course of pre-contractual negotiations between the Data Subject and Carsland OÜ and/or in the course of performance of the contract entered into; the Data Subject’s payment account details, including previous payments/debts/payment behaviour; recordings from the video cameras located in the workshop and premises of Carsland OÜ (including images of persons and activities involving the vehicle); data obtained or created in the course of performing other obligations arising from law (for example data arising from enquiries made by investigative bodies, consumer protection authorities, notaries, courts and bailiffs).
PURPOSE OF PROCESSING PERSONAL DATA
The processing of personal data (including collection, recording and storage) is necessary in order to provide You with the services offered by Carsland OÜ, in particular to enable a rental relationship to be established in connection with giving and taking rental vehicles into use, and to offer You better customer service. Carsland OÜ processes personal data in particular in the following situations and for the following purposes: to establish the identity of the data subject and the existence of a right of representation when a customer relationship is created; to enter into a contract with the data subject and to perform the contract entered into; to provide services to the data subject; to perform obligations arising from law (including when responding to enquiries from law enforcement authorities and other authorised persons); to submit claims and conduct legal disputes; for other operations necessary to achieve the purposes of the contract entered into by Carsland OÜ with the Data Subject, including the development and quality improvement of the services offered by Carsland OÜ. PROTECTION AND SECURITY OF PERSONAL DATA
In its activities Carsland OÜ follows the principles of personal data protection and does everything in its power to ensure that the processing of personal data, including the collection, transmission and storage of personal data, takes place in a manner that ensures the security and confidentiality of personal data in accordance with the nature of the personal data, including by applying appropriate technical and organisational measures to ensure the secure processing of personal data. Access to personal data is held by authorised employees of Carsland OÜ who may examine the personal data in order to resolve technical questions relating to the service and to provide customer support. The transfer of personal data to processors (e.g. a payment service provider) takes place on the basis of contracts entered into between Carsland OÜ and the processors. Processors are obliged to ensure appropriate safeguards when processing personal data. STORAGE OF PERSONAL DATA
Pursuant to the legislation of the Republic of Estonia, we are obliged to store certain data as follows: the data of a Data Subject who has signed a rental agreement with Us are stored for up to 7 years, counted from the turn of the year following the date of entry into the contract, pursuant to the obligation arising from § 12 of the Accounting Act of the Republic of Estonia to substantiate source documents and contracts. Where an invoice has been issued to the Data Subject, it is stored in the same manner as set out above. Non-personalised technical data collected by the websites and service environments are stored for an unlimited period. Personal data that the Data Subject has submitted to us via the Carsland.ee website, but where no rental agreement has been entered into with the Data Subject or no invoice has been sent to the Data Subject, are deleted once per calendar year. In such a case we do not delete the data before the rental end date indicated in the booking made by the Data Subject on the website. If the Data Subject wishes the data submitted with a booking, in respect of which no rental agreement has been entered into or no corresponding invoice has been sent, to be deleted earlier, they must submit a corresponding application. After the said terms, all data are deleted and destroyed. We use all reasonable measures to correct or delete incorrect data of the Data Subject. TRANSFER OF COLLECTED DATA
Carsland OÜ transfers the personal data of the Data Subject to third parties where this is required by law, necessary for organising the work of Carsland OÜ or for exercising obligations and/or rights arising from law, or on another lawful basis. Personal data submitted to authorised employees are processed on the bases provided by law and only to the extent necessary. Carsland OÜ may submit the data of the Data Subject to the following third parties: cooperation partners and business partners of Carsland OÜ; legal advisers, financial advisers and insurers connected with the activities of Carsland OÜ; processors for the purpose of organising the work of Carsland OÜ (e.g. administrators of IT systems, the accountant and the like); a new creditor upon assignment of a claim; the provider of the camera security service and the providers of the GPS service in respect of rental vehicles; other persons to whom Carsland OÜ may or is obliged to disclose the personal data of the Data Subject in order to perform obligations arising from law for Carsland OÜ. RIGHTS OF THE DATA SUBJECT
The Data Subject has all the rights arising from the Regulation, the Personal Data Protection Act of the Republic of Estonia and other applicable legislation. The Data Subject has the right to obtain from the data processor the personal data concerning them, to demand the correction of incorrect data, the erasure of personal data, the cessation of the processing of data, and to exercise other rights arising from the relevant legislation. The data processor makes the corresponding changes to the data as quickly as possible. A request of the Data Subject is not satisfied where it conflicts with legislation of the Republic of Estonia or where they have already consented by signature to the storage of their personal data and the data contained in the rental agreement in such form. Nor is a request satisfied where the Data Subject cannot be identified, or where the change is not technically feasible or possible under the law. If You wish to receive a copy of your personal data, for security reasons we can send it by e-mail only in encrypted form, adding You as the recipient of the files using your personal identification code. If You do not have the technical means to open such a file, or if it is not possible to add you as a recipient when encrypting the files on the basis of your personal identification code, you can receive the requested documents in person or by means of a corresponding notarised power of attorney. Documents are issued only at our office during working hours.
Where the processing of personal data takes place on the basis of the customer’s consent, the customer has the right to withdraw the consent by notifying customer support by e-mail. COOKIE POLICY
„Cookies“ are files that are saved automatically to Your computer when you visit a website. Our websites may use cookies. You can disable the saving of cookies in your browser settings, and you can also delete cookies that have already been saved from those settings. Information relating to cookies is not personalised. It is used to measure website traffic. We cooperate with other companies in order to obtain information about website traffic and, on that basis, to raise the level of our service. By using the carsland.ee website, you have read and agreed to the privacy conditions. RESOLUTION OF DISPUTES
Disputes relating to the processing of personal data are resolved through customer support (+372 5089396 ; info@carsland.ee). The supervisory authority is the Estonian Data Protection Inspectorate (info@aki.ee). SUMMARY
If You have questions about the privacy conditions and data processing, or if you wish to access your personal data, to have them deleted (on a lawful basis) or to have the data changed, please contact info@carsland.ee