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.
- 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: email@example.com.
We may process personal data for other purposes only if you have given your prior consent for that.
• 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).
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.
- Google services
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/.
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.
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: firstname.lastname@example.org.
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
You can also contact the Data Protection Inspectorate (email@example.com; tel. 627 4135).