We (Best Idea OÜ) collect and process your personal data if you:

• are on our website (www.joulugala.ee);

• are on our social media account in Facebook, Instagram, Twitter, Youtube;

• send us an e-mail;

• buy a ticket to participate in our event;

• participate in our event;

• request access to the event area;

• participate as a volunteer in the organization of an event.

Personal data are legally defined as any data about an identified or identifiable natural person. Data are considered personal data if these enable to establish a direct or indirect link between the data and a natural person.

The processing of personal data is any procedure to be carried out with personal data or sets of personal data.

Protecting your privacy is important to us, thus we would like to provide clarity about our principles of personal data processing and have compiled this Privacy Information for that purpose.

Best Idea OÜ uses your personal data only for the purposes stated in this Privacy Information and we do not disclose your personal data to any natural or legal person, i.e. to third parties, if chapter 8 of this Privacy Information does not stipulate otherwise.

The collection and processing of personal data is carried out in accordance with the Personal Data Protection Act and the General Data Protection Regulation, which ensures that your personal data will not be disclosed to unauthorized persons or in an unauthorized manner.

Best Idea OÜ has the right to unilaterally change the terms set out in the Privacy Information. Updated terms will be published on our website.

1. Personal data collected

In order to achieve the purposes set out in this Privacy Information we need to process some or all of the following personal information. The exact composition of the personal data to be processed depends on the purpose of the processing of personal data and may vary from case to case. We always follow the principle that we process personal data as little as necessary to achieve the purpose:

• contact details (first and last name; personal identification code or date of birth; age; details of the identity document; telephone number; e-mail address; address of residence or place of work; language of communication);
• information on the table at which the participant was staying;
• payment instrument data (bank card number, credit card number, current account number);
• information exchange, including e-mail exchange;
• data related to the visit of the website (e.g. website user's browser and IP address);
• videos, pictures and other media enabling to identify you in the event area;
• personal data lawfully obtained from third parties;
• information collected in the course of fulfilling the legal obligations.

2. Legal basis and purposes of personal data processing

We process your personal data for the purpose of concluding, performing and enforcing the contract in order to:

• manage e-shop orders, deliver goods and contact the winner of the campaign;

• process payments;

• send event tickets to your e-mail address;

• send notifications about the event to your e-mail address, including notifications about changes in traffic arrangements;

• personalize tickets and identify the ticket holder and ensure access to the event area;

• ensure safety and health of the people in and around the event.

We process your personal data for the purpose of fulfilling the obligations arising from the legal acts in order to:

• ensure compliance with accounting and tax obligations;

• comply with the lawful orders of a law enforcement agency or other state authority.

We process your personal data in order to protect the vital interests of the persons in the vicinity of the event area in order to:

• prevent the spread of SARS-CoV-2 to persons staying in and around the event area.

We process your personal data in accordance with our legitimate interests in order to:

• inform persons living in the area of ​​the event or in its immediate vicinity about changes in traffic management;

• compile web usage statistics, analyze the conduct and user experience of website visitors to ensure better service and smooth operation of the website and applications;

• market our event through photos or videos taken from the event;

• compile, file or defend claims.

The legitimate interests of Best Idea OÜ are to ensure the safety of the persons present in the event area; safe movement of people through the event area to their home and workplace; providing a better user experience on our website; marketing our event and ensuring compliance with legal requirements. We collect and process personal data to the minimum necessary to ensure legitimate interests and to ensure that the processing of personal data is proportionate. Additional information regarding the formation and balancing of legitimate interest can be obtained by contacting us by e-mail: info@sakusuurhall.ee.

We may process personal data for other purposes only if you have given your prior consent for that.

3. Cookies

In order for the website to function properly, Best Idea OÜ sometimes stores small data files on the user's device - so-called cookies. A cookie is a small text file that a website stores on a user's computer or mobile device when a user visits our website. This allows the website to remember user actions and preferences (such as username, language, cart content, and other display preferences) for a certain period of time. This way the user does not have to re-enter these each time they return to the site or browse the pages. The cookies used include mandatory cookies that are necessary for the operation of the website. In addition, we use cookies that are not directly necessary for the operation of the website, but which ensure a better browsing experience for the user of the website. Best Idea OÜ uses cookies and cookie-like tools to provide the service, improve the quality of service and user experience. The sites of Best Idea OÜ use cookies:

• to personalize content and ads;

• to provide social media functions; and

• to analyze web traffic.

Cookies may also be used by third parties whose services are used by Best Idea OÜ (e.g. social media platforms in Facebook, Instagram, Twitter, where Best Idea OÜ has an account).

You can refuse cookies at any time by changing the browser settings of the device you are using and by deleting the stored cookies. Instructions on how to opt out of the use of cookies in various commonly used browsers can be found here: https://www.cookielawinfo.com/ways-to-block-cookies-in-different-browsers/

The user should be aware that certain functions can be provided only by using cookies and if the user decides to opt out of cookies, these functions may not be available to the user.

4. Google services

Best Idea OÜ can use Google Analytics, a web analytics service provided by Google, Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"). Google Analytics uses cookies, files stored on the user's computer, to analyze how the user uses the website. The information generated by the cookies about your use of the website is usually transmitted to and stored by Google on servers in the United States. As the service provider has activated IP anonymization, Google shortens the user's IP address (for the European Union or other member states of the European Economic Area). At the request of Best Idea OÜ Google will use the information to analyze the user's activities and prepare reports on what is happening on the website. The user can disable the storage of cookies on the user's computer with the settings of the web browser, but in this case the user will not be able to use all the functions of the website.

In addition the user may refuse the use of cookies to prevent the transmission of the data collected about the use of the website to Google, including the IP address, and the further processing of this data on Google's servers. To do so, the user must download and install the appropriate browser add-on from the following website: tools.google.com/dlpage/gaoptout?hl=en. Google Analytics retains cookie, user (e.g. user IDs) and ad identifiers (e.g. DoubleClick cookies, Android ad id, Apple ad id) for 26 months.

Best Idea OÜ may display advertisements on the website through third parties. Google uses DART cookies to show ads that are relevant to the user and to improve campaign performance reporting and avoid showing ads that the user has already seen. Users can opt out of showing interest-based ads by visiting the Google ads settings page:

• Go to http://www.google.com/settings/ads/anonymous.

• Move "Ads based on your interests" to "OFF"

• Confirm your selection.

Learn more about ads at http://www.google.com/policies/technologies/ads/.

Best Idea OÜ can use Google Adsense. Third-party ad networks using Google Adsense network use technology that sends ads and links directly to a user's web browser. They are given the user's IP address. Third-party ad networks also use other technologies (such as cookies, javascript) to measure and personalize ad performance. Best Idea OÜ does not have access to or control over the cookies used by third party advertisers. The user should consult third-party advertisers for more information about their privacy policies and how not to share information with them in certain cases. If the user wants to block cookies, this can be done through browser settings. More information on how to set cookies can be found on the website of the web browser applied by the user.

5. SmartAD

Best Idea OÜ can use SmartAD advertising network. SmartAD uses serving.bepolite.eu cookies, javascript and browser settings (User Agent String, screen size) to show the user ads that are relevant to the user, to improve the reporting on campaign performance and to prevent the user from already seen ads. If the user wants to block cookies, this can be done through browser settings. More information on how to set cookies can be found on the website of the web browser applied by the user.

6. Facebook

The website of Best Idea OÜ may have integrated Facebook add-ons (1601 S. California Avenue, Palo Alto, CA 94304, USA) "Like" and "Share". For an overview of Facebook add-ons, visit the website at developers.facebook.com/docs/plugins/. When a user visits the website of Best Idea OÜ, a direct connection is established between the user's web browser and Facebook server, using these plug-ins, through which Facebook receives information that the user has access to the Service Provider's website from its IP address. If the user is logged in to Facebook and presses "Like" or "Share" buttons, the user can link the content of the website of Best Idea OÜ to its Facebook profile. Best Idea OÜ does not receive any information about the transferred data or its use from Facebook. For more information, read Facebook's privacy policy: www.facebook.com/about/privacy/. If the user does not want the user's Facebook account to reflect the visit to the site of Best Idea OÜ, the user must log out of Facebook.

7. Direct marketing notices

Your e-mail address and phone number will be used to send direct marketing notices if you have given your relevant consent for that purpose. If you do not wish to receive direct marketing notices, you must select the appropriate link in the footer of the e-mail or contact customer support. If personal data are processed for direct marketing purposes, you have the right to object to the initial and further processing of your personal data, including profiling related to direct marketing, at any time by notifying customer support of it by e-mail. The relevant information should be provided clearly and separately from any other information.

8. Personal data processing

Disclosure and transfer of personal data. We disclose and transfer personal data only in the following cases and if there is a corresponding legal basis, including to processors possessing a valid contract. In providing services and fulfilling the contract Best Idea OÜ may use third parties who participate in the fulfilment of the purposes of processing, including payment service providers, transport companies, healthcare providers. In order to provide the service and ensure its quality, it may be necessary to transfer personal data to the e-mail service provider, IT service provider, server service provider, software and software service provider.

Third parties are required to comply with our Privacy Information. In order to fulfil the obligations arising from law, personal data can be disclosed and transferred to such authorities that have the right to demand the disclosure and transfer of personal data and we have the obligation to disclose and transfer the data. In order to protect our rights we have the right to transfer personal data to legal assistance providers, auditors and debt collection service providers. To ensure safety and security of people during the event Best Idea OÜ cooperates, among others, with Health Board and Police and Border Guard Board, thus we have the right to transfer your personal data to them for this purpose. In order to prevent the spread of SARS-CoV-2 between the persons in and around the event area, we may transfer the personal data of the team members to SYNLAB Eesti OÜ with which we have concluded personal data processing contract.

Security of personal data. Best Idea OÜ uses all reasonable administrative, technical and organizational measures to prevent unjustified or illegal access to or processing of personal data or destruction, accidental loss and disclosure of personal data. If your personal information is shared with third parties, they must also use all reasonable administrative, technical and organizational measures to protect your personal data. Some of the data collected through the use of cookies is transmitted to the United States of America via Google Analytics. The transfer of personal data to the United States of America is guaranteed by the protection of personal data in accordance with the provisions of Article 46 (2) of the General Data Protection Regulation, as the Google’s general terms of service are based on the European Commission's standard data protection clauses.

If there is a breach of personal data that is likely to jeopardize your rights and freedoms, we will immediately notify the Data Protection Inspectorate and you within 72 hours from becoming aware of the breach, unless otherwise provided by applicable law.

Retention of personal data. We retain your personal data for as long as is necessary to fulfil the purposes described in the Privacy Information. Invoices issued to persons who have purchased a ticket, service contracts entered into for the organization of the event and the data contained therein shall be kept for up to seven years from the conclusion of the transaction or termination of the service in accordance with the established accounting requirements. The personal data of the persons who have applied for access to the event area will be stored until the end of the event.

The data of the viewing area in which a particular spectator was present shall be kept for up to two months from the end of the event. The information required on the registration form for team members (incl. teams, competitors, media, guests) will be kept for up to two months from the end of the event. We retain your data, if necessary, to protect our rights, by taking into account the statutory limitation periods which are generally three years in case of civil claims. Upon expiration of the period of retention of personal data, your data will be deleted.

9. Rights of the data subject

Access to personal data. If you have questions or suggestions related to the processing of your personal data, you have the right to request information about the personal data collected about you and their processing, if your identity has been proven. We give you an access to the personal data collected about you, which we process, and the sources of that data. You can contact us by e-mail: info@sakusuurhall.ee.

Correction and deletion of personal data. You have the right to have your personal data corrected, deleted or altered to correct inaccuracies if the personal data is incomplete or incorrect or these are processed unlawfully. You will not be charged for exercising these rights. You have the right to request the deletion of untrue or irrelevant data. You have the right to have your personal data deleted immediately and free of charge if the law does not provide for an obligation to retain personal data. You can contact us by e-mail to submit the above requirements.

Deletion is mainly related to the visibility of the data and involves the possibility that the personal data to be deleted will be stored temporarily. Best Idea OÜ will take all reasonable measures to delete your personal data as completely and extensively as possible. If you exercise your right to delete personal data, your ticket will expire and you will not be entitled to any compensation or refund for the invalidation, regardless of whether the event has already taken place or will take place in the future.

Withdrawal of consent. If the processing of personal data takes place on the basis of your consent, you have the right to withdraw the consent by notifying us by e-mail. Withdrawal of consent shall not affect previous processing operations.

Transfer. You have the right to request that the personal data collected about you will be forwarded to you in a structured form.

Right to refuse and restrict processing. You have the right to object to the processing of your personal data at any time and to require that the processing of your personal data Will be restricted.

10. Contact and protection of rights

If you have any questions regarding the processing of personal data, please contact us as the controller:

Best Idea OÜ (registry code 10955220)

Toompuiestee 37, Tallinn, Harjumaa

tel +372 660 0200

e-mail:  info@sakusuurhall.ee.

You can also contact the Data Protection Inspectorate (info@aki.ee; tel. 627 4135).