In case of dispute, the english language version of the Privacy Policy prevails.
OÜ Trinity Capital („Service Provider”) respects your privacy. Service Provider will comply with applicable laws and does not process Client’s personal data and/or personal data of other parties without the permission of the Client or in order to satisfy applicable law, regulation, legal process or enforceable governmental request. Service Provider will process only personal data, when it is necessary for providing our services and collect information to provide better services to all of our Clients.
The Privacy Policy applies to the processing of personal data of Clients of the service („Client”) and personal data of third persons inserted by the Client (in particular data of the Client's end Client). The privacy policy describes the main principles and objectives of personal data processing used by the Service Provider. Clients may be natural persons or representatives of legal persons.
The Service may contain links to third-party websites or services. These websites and services may have their own privacy policy. The service provider is not liable for privacy policies of the third parties', activities related to the processing of personal data by the third parties, and suggests examining carefully each third party's privacy policy.
Privacy Policy is linked to the Terms of Service, published on the website and shares the same terminology with it.
Personal Data means any data about an identified or identifiable natural person, regardless of the form or format of the data.
Service provider collects Client data lawfully through the use of Services.
The Service provider may process Client’s personal data for providing services, and in specific cases provided in this Privacy Policy.
The service provider processes personal data that Client gives to Service provider and information that Service provider gets from the use of our services, including (but not limited to) the following information:
The Service Provider may also collect and process personal data of third parties inserted by the Client (in particular the Client's end-customer) for providing the Service. The Client is responsible for having the consent to transfer the personal data of such third parties to the Service Provider and to allow processing the data by the Service Provider.
Service provider may collect data about using of the user interface elements and service-related activities, for analysing the use of the Service.
The controller for Client data is the Service provider. The Service provider may assign data processing to data processors. Data processors are:
Data processors process data, inter alia:
A data processor may only process data for specific tasks determined by the Service Provider.
Processing personal data is based, in particular, on the customer relationship or upon the consent given by the Client to the Service Provider to process the data published by the Client. By providing personal data during the usage the Service, the Client gives the Service Provider permission to process all inserted data, in the scope and for the purposes described in the Privacy Policy.
The purpose of data collecting and processing is mainly to provide, maintain, protect and improve the Services and to develop new ones. Service provider also uses this information to offer tailored content for Clients – such as giving more relevant ads and provide better content.
The service provider does not save the data provided by the Client in Service provider’s database, but only processes it to the extent necessary for providing the Service.
The service provider may use website visitor statistical data to analyse trends and demographics of visitors. However, service provider does not assign each visitor an individual profile.
The service provider does not sell, rent, trade or give generally Client’s personal data, traffic data and communications content to third parties, without the his/her consent, except
During the business development, Service provider may buy or sell its business units. In case of such transactions, and if the Service provider or substantially all of its assets are going to the possession of a third party, the Client’s personal data is generally considered as a transferable business asset. Service Provider reserves the right to involve the Client’s personal data as an asset transferred to a third party.
The Service provider shall ensure within their means the quality of processed personal data. Service provider may modify the entered data, in extent, that is necessary for the operation of the Service, for example, to replace the entered characters, punctuation marks, or other symbols that might mislead automated program. However, the Client is still responsible for the accuracy of the provided data.
Service provider has implemented the necessary technical and organisational measures to protect personal data from unauthorised and accidental or illegal deletion, modification, disclosure, transmission, or other unlawful forms of processing.
The service provider is however not liable for third-party access to the devices that are under control of the Client, the Internet and its security.
The service provider does not store personal data entered by the Client. Correspondence relating to natural persons is generally stored for up to one year.
To make the Website work properly, Service provider sometimes places small data files called cookies on Client’s device. Most big websites do that too.
The legal basis for the use of cookies is service provider's legitimate interest in ensuring the technical functionality of the website. When cookies are used to remember user choices or for statistical purposes, the legal basis is user consent.
What are cookies?
A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
How do we use cookies?
The Service provider may use cookies and tools similar with cookies, to provide the Service to improve Service quality, and improve the Client experience. Cookies can also be used by third parties, whose services are used by the Service provider.
Service may use cookies for:
The Service provider may also provide information to its social media, advertising and analytical partners on how the Client uses the Website.
The implementation of these cookies is not directly necessary for the operation of the website, but it provides the Client a better browsing experience. Clients can either delete or block cookies, but in this case some of the website features may not function as intended.
Cookies help the Service Provider to provide services. Client agrees that the Service Provider uses cookies, by using the Services.
How to control cookies
Clients can control and/or delete cookies upon a wish – for details, see www.youronlinechoices.com/. Client can delete all cookies that are already on Client’s computer and Client can set most browsers to prevent them from being placed. If one does this, however, Client may have to manually adjust some preferences every time Client visits a site and some services and functionalities may not work.
The Service provider may use Google Analytics, a web analytics service offered by Google, Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"). Google Analytics also uses cookies, files that are saved in the Client's computer to analyse how the Client uses the Services.
The Client information generated by Cookies, during the use of the Service, is usually transmitted to the Google server in the United States and saved there. As the service provider has activated the IP anonymisation, Google shortens the Client's IP address (if the Client is from European Union or from other EEA Member States).
At the Service provider's request, Google will use the information to analyze Client interaction and to draw up reports on the Service website usage.
The Client can set the browser to block all cookies, including cookies associated with our services or to indicate when a cookie is being set by our services. However, it’s important to remember that many of our services may not function properly if your cookies are disabled.
In addition, Client can disable cookies from forwarding the data collected on the website (including IP address) to Google and the transfer of the data to Google's servers for further processing. To provide Clients the ability to prevent their data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on for the Google Analytics JavaScript. If Client want’s to opt-out, one should download and install the add-on for the web browser from: tools.google.com/dlpage/gaoptout?hl=en.
Google Analytics retains user-level and event-level data associated with cookies, user-identifiers (e.g., User-ID) and advertising identifiers (e.g., DoubleClick cookies, Android’s Advertising ID, Apple’s Identifier for Advertisers) 26 months.
Service provider may serve ads by third parties on the website. Advertising keeps the services that you use free of charge.
Google uses the DART cookies to target advertising based on what’s relevant to a Client, to improve reporting on campaign performance, and to avoid showing ads the Client has already seen.
Clients may opt out of the interest-based ads by visiting the Google Ads Settings at:
Additional information on advertising can be found at: www.google.com/policies/technologies/ads/
The service provider may use Google Adsense. Third-party network advertisers, who use Google Adsense, use technology that sends the advertisements and links directly to the Client’s web browser. The Client’s IP-address is forwarded to those advertisers. Third-party advertising networks, also use other technologies (for example, cookies, JavaScript), to measure the effectiveness of the ads and to personalize them.
The Service Provider has no access to or control over these cookies, which are used by third-party advertisers.
Clients should consult with such third-party advertisers for getting more information about their privacy policy and the options of non-disclosure of your information to them in certain cases.
If the Client wants to block cookies, it can be done through Internet browser settings. In some browsers you can set up rules to manage cookies on a site-by-site basis, giving you more fine-grained control over your privacy. What this means is that you can disallow cookies from all sites except those that you trust.
The service provider's website can be integrated with Facebook (1601 S. California Avenue, Palo Alto, CA 94304, USA), plug-ins "Like" and "Share". For an overview of the add-ons, please visit the Facebook site developers.facebook.com/docs/plugins/.
When a Client visits the website, a direct link between Client's browser and the Facebook is created. By using those plug-ins, Facebook obtains information that Client’s IP address has access to the Service provider's webpage. If a Client is logged on and clicks the Facebook "Like" or "Share" buttons, Client can be link the Service provider’s content to Client’s Facebook profile, through which Facebook can reflect the usage of the Services on Client’s Facebook wall. The Service provider cannot obtain any information on transferred data or how Facebook uses Client’s data. More information can be found by visiting Facebook's privacy policy: www.facebook.com/about/privacy/.
If the Client does not want that the visits on the Service website are reflected on Client’s Facebook account, Client must log out of Facebook.
The server that hosts the website may also record requests Client makes to the server, such as the web address the Client opens, the device and browser te Client uses, Client's IP address, date and time of access. This data is used only for technical purposes – that is, to ensure the proper functioning and security of the website and to investigate possible security incidents.
By contacting the service provider, Client may exercise his/her rights:
In some cases Client may have a right to request a restriction on processing his/her personal data or to object to processing of his/her personal data.
Client may exercise his/her rights in line with the requirements of applicable EU and local laws.
If personal data is erased at Client's request, the service provider will only retain such copies of the information that are necessary to protect the service provider's or third party legal interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement Client has entered into with the service provider.
Client may disable cookies by his/her browser settings, or by visiting here:
Service provider may regularly make changes to this Privacy Policy and in the associated information, without informing the Client. To stay informed about possible changes in this Privacy Policy, Client is encouraged to review the Privacy Policy regularly.
If Client thinks his/her privacy rights have been breached, Client may lodge a complaint with an authority of the EU country of his/her habitual residence. Contact information for these authorities can be accessed at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
Learn more about the privacy policy by contacting us at info@arvetehas.ee.
Last updated: 25.04.2018.