Privacy Policy for CRM Technology OÜ

At CRM Technology, one of our main priorities is the privacy of our visitors. This Privacy Policy document contains types of information that is collected and recorded by autocrm.fi and how we use it. This Privacy Policy is also intended to inform users about their privacy rights.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.

This Privacy Policy applies only to our online activities and is valid for visitors to our website with regards to the information that they shared and/or collect in autocrm.fi. This policy is not applicable to any information collected offline or via channels other than this website.

This Privacy Policy is based on the requirements of European Union General Data Protection Regulation 2016/679 (“GDPR”) on the protection of individuals in relation to the processing of any information that relates to an identified or identifiable living individual (“Personal Datа”). Autocrm.fi is operated by CRM Technology OÜ, with their registered address at Harju maakond, Viimsi vald, Viimsi alevik, Nelgi põik 2-29, 74001, and registration number 16631487 (referred for the purposes of this Privacy Policy as the “Company” or “Autocrm” or autorcm.fi). The Company is the Personal Data controller within the meaning of the GDPR.

The Company collects Personal Data and uses this Personal Data only for the purposes of offering, providing and/or improving the Services, unless a reasonable assessment is made that this Personal Data shall also be processed for additional purposes. Users will be informed if the Personal Data is processed for additional purposes.

This document contains the following information:

• Personal Data that the Company collects and how it is used;
• Purpose for the collection of Personal Data;
• How IP address and cookies are used;
• Sharing of Personal Data with third parties;
• Transfer of personal information;
• What rights users have;
• Security measures to protect user Personal Data;
• Retention of Personal Data.

1. Definitions

Personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Data subject means a natural or legal person whom the data within the register concerns;

Processing means any operation or set of operations performed with regard to Personal Data, whether or not performed by automated means, such as collection, recording, organisation, storage, adaptation, alteration, retrieval, gathering, use, combination, blocking, erasure or destruction.

2. Consent

By using our website, you hereby consent to our Privacy Policy and agree to its terms.

3. Information we collect

The Company collects users´ Personal Data necessary for the identification and for the performance of the contractual and regulatory obligations of the Company. This information may include any or all of the following:

1. Name, address and personal identification number;
2. Contact information (email, phone number etc)

4. How we use your information

We use the information we collect in various ways, including to:

• Provide, operate, and maintain our services and website;
• Improve, personalize, and expand our website;
• Understand and analyze how you use our website;
• Develop new products, services, features, and functionality;
• Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes;
• Contact users by email, telephone, SMS, or other equivalent forms of electronic communication, regarding updates or information related to the functionalities, products or contracted services, including the security updates;
• Provide users with news, special offers and general information about other goods, services and events which the Company offers now or may offer in the future;
• Manage users´ customer service requests;
• Find and prevent fraud;

5. Cookies and Web Beacons

Like any other website, autocrm.fi uses "cookies". These cookies are used to store information including visitors' preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users' experience by customizing our web page content based on visitors' browser type and/or other information.

6. Google DoubleClick DART Cookie

Google is one of a third-party vendor on our site. It also uses cookies, known as DART cookies, to serve ads to our site visitors based upon their visit to www.website.com and other sites on the internet. However, visitors may choose to decline the use of DART cookies by visiting the Google ad and content network Privacy Policy at the following URL – https://policies.google.com/technologies/ads

7. Our Advertising Partners

Some of advertisers on our site may use cookies and web beacons. Our advertising partners are listed below. Each of our advertising partners has their own Privacy Policy for their policies on user data. For easier access, we hyperlinked to their Privacy Policies below.

• Google https://policies.google.com/technologies/ads

8. Advertising Partners Privacy Policies

You may consult this list to find the Privacy Policy for each of the advertising partners of autocrm.fi.

Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on autocrm.fi, which are sent directly to users' browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.

Note that autocrm.fi has no access to or control over these cookies that are used by third-party advertisers.

9. Third Party Privacy Policies

autocrm.fi's Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites.

10. Categories of third parties receiving Personal Data

In accordance with the requirements of the GDPR, the Company has the right to disclose Personal Data that it processes to the following categories of recipients:

1. To natural persons to whom the Personal Data relates;
2. To Third Parties, individuals, legal entities, public bodies, institutions and agencies, in fulfillment of legal or contractual obligations or on another valid legal basis, such as detection, prevention or other acts of fraud, technical security or security issues;
3. To banks, or similar payment or financial service providers;
4. To persons who maintain equipment and software used for processing user’s Personal Data;
5. To service providers to monitor and analyze the use of the Service and to other service providers;
6. For business transfers including the negotiations, merger, sale of Company’s assets, financing, or acquisition of all or a portion of our business with another company;
7. With other entities such as the Company’s parent companies, licensors and/or affiliates or any other subsidiaries, joint venture partners or other companies that the Company controls or that are under common control;
8. With our business partners to offer User certain products, services or promotions;
9. Users who choose to share personal information or otherwise interact in public may have this information viewed by other Users who may publicly distribute this information;
10. With professional consultants such as auditors, lawyers, tax and financial advisors etc.;
11. For any other purpose with Users consent.

11. Transfer of Personal Data

The Company will take all steps reasonably necessary to ensure that the transferred Personal Data is treated securely and in accordance with this Privacy Policy and no transfer of the Personal Data will take place to an organization or a country unless there are adequate controls in place for the security of Personal Data. The company does not transfer data to non-EU/EEA countries. The Company may disclose data to subcontractors for technical processing.

12. Retention of the Personal Data

The Company will retain the Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. The Company will retain and use the Personal Data collected to the extent necessary to comply with our legal obligations and applicable laws, to resolve disputes, and enforce our policies. Usage Data, including the types of data listed in section 3, is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or the Company is legally obligated to retain this data for longer time periods.

Personal Data for which there is no explicit legal obligation for storage will be deleted after achieving the purposes for which the Personal Data was collected and processed.

13. GDPR Data Protection Rights

We would like to make sure you are fully aware of all of your data protection rights. Users have the following rights with regard to their Personal Data:

1. To receive information about their Personal Data which the Company collects. The Company will provide information and/or access to Personal Data collected or processed if a User requests such information to Company’s support services. We may charge you a small fee for this service;
2. To request that Personal Data be corrected when it is inaccurate or should be supplemented in view of the purposes of processing. For Personal Data that Users can not correct by themselves, a request can be submitted in accordance with the procedure described in this Privacy Policy;
3. To request deletion of Personal Data in the following circumstances: when it is no longer needed for the purposes for which they were collected or processed; if explicit consent was required and withdrawn; if there no longer exists a legal or contractual basis for processing the Personal Data or through a judicial order or a change in the relevant regulations. It is not possible to request the immediate deletion of Personal Data in every circumstance, for example if there is a regulatory obligation to maintain the Personal Data;
4. To request limitation of the processing of Personal Data where the processing may violate applicable regulations but the User only wishes to limit the processing of that Personal Data;
5. To request the transfer of Personal Data. The right to portability applies to Personal Data where the processing is based on the Users explicit consent or contractual obligation and the processing is carried out in an automated manner;
6. To object to the Company about the processing of Personal Data. As per the requirements of the GDPR, the Company will answer within one month, whether it considers the objection justified and within the regulatory requirements;
7. To withdraw consent to the processing of Personal Data if the processing was based solely on the User’s consent;
8. To send a complaint to the competent Personal Data protection authority in case the User believes their rights have been violated. A list of all national and regional Personal Data protection authorities in the EU is available on this website: https://edpb.europa.eu/about-edpb/about-edpb/members_en

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

14. Automated decisions

The Company may make automated decisions about its user. This means that the Company may use technology that can evaluate the users’ personal circumstances and other factors to predict risks or outcomes. This is needed for the efficient running of the Company’s services and to ensure decisions are fair, consistent and based on the right information. Where an automated decision is made about a user, the user has the right to ask that the decision be manually reviewed.

15. Children's Information

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

autocrm.fi does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

16. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, we advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately, after they are posted on this page.

17. Submitting a request

Users may submit requests to the Company based on their rights described in this Privacy Policy by contacting the Company via the email address given in this Privacy Policy. If the relevant information provided is incomplete and / or incorrect, it may not be possible to fulfill the request.

18. Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us.