1. General Provisions

1.1. This Privacy Policy sets out the principles governing the collection, processing and storage of personal data. Personal data is collected, processed and stored by the responsible data controller OY Minlomer (hereinafter referred to as the data controller).

1.2. Data subject for the purposes of the Privacy Policy is a customer or other natural person whose personal data is processed by a data controller.

1.3. Customer for the purposes of the Privacy Policy is anyone who purchases services from the website of a data controller.

1.4. The data controller complies with the data processing principles set out in the legislation, including processing personal data lawfully, fairly and securely. The data controller is able to confirm that the personal data have been processed in accordance with the law.

  1. Collection of personal information

2.1. The personal data that are collected, processed and stored by the data controller are collected electronically, mainly through the website.

2.2. The data subject gives the data controller the right to collect, organize, use and manage his or her personal data that he or she directly or indirectly shares with the data controller when purchasing services from the website, for the purposes specified in the Privacy Policy.

2.3. It is the responsibility of the data subject to ensure that the information they provide is accurate, correct and complete. Knowingly providing false information is considered a violation of the Privacy Policy. The data subject is obliged to immediately notify the data controller without undue delay of any changes to the data provided.

2.4. The data controller shall not be liable for any damage caused by the provision of false information by the data subject to the data subject or to third parties.

  1. Processing, security and storage of customers’ personal data

3.1. The data controller or the authorized processor may, depending on the purpose, process the following personal data of a data subject:

3.1.1. Name and surname;

3.1.2. Country;

3.1.3. Phone number;

3.1.4. Email address;

3.1.5. Payment card details.

3.2. In addition to the above, the data controller is entitled to collect data about the customer that is available in public registers.

3.3. The legal basis for the processing of personal data is Article 6(1) a), b), c) and f) of the General Data Protection Regulation:

3.3.1. a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;

3.3.2. b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

3.3.3. c) processing is necessary for compliance with a legal obligation to which the controller is subject;

3.3.4. f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

3.4. Processing of personal data for the purposes for which it is processed:

3.4.1. Order processing;

3.4.2. Customer service and support;

3.4.3. Finance, accounting;

3.4.4. The IP address of the online store’s user or other network identifiers are processed for the purpose of providing the online store as an information society service and for the purpose of website usage statistics.

3.5. Access to personal data is granted to the employees of the online shop who can access personal data in order to resolve technical issues related to the use of the online shop and to provide customer support services. The relevant personal data is transferred by the service provider to the accountant. Personal data may be transferred to information technology service providers if this is necessary to ensure the functionality of the online store or to ensure data availability. The data controller is the controller of personal data. The data controller transmits the personal data necessary for the execution of payments to the authorized processor PayPal.

3.6. When processing and storing personal data relating to the data subject, the data controller shall implement appropriate physical, organizational and IT security measures to protect personal data against accidental or unlawful destruction, alteration, disclosure or any other unlawful forms of processing.

3.7. The online store’s authorized processors (e.g. data hosting provider, accountant) are obliged to ensure appropriate protection measures when processing personal data.

3.8. Personal data is stored on veebimajutus.ee servers, which are located in the territory of a member state of the European Union or countries that have joined the European Economic Area.

3.9. The data controller stores data subjects’ data depending on the purpose of the processing. A data controller shall keep personal data in a form that permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed unless the data controller has a legal requirement to keep personal data for longer periods (for example, under the Accounting Act).

3.10. The data controller shall securely destroy and/or erase any personal data that are no longer necessary for the purpose for which they were collected or for which the retention period has expired.

  1. Rights of the data subject

4.1. Data subjects have the right to access and inspect their personal data. Personal data can be viewed and corrected on the homepage under My account.

4.2. Data subjects have the right to be informed about the processing of their personal data.

4.3. Where a data controller processes the personal data of a data subject on the basis of the data subject’s consent, the data subject has the right to withdraw his or her consent at any time.

4.4. In order to exercise their rights, data subjects can contact the online store’s customer support at info@memoplays.com.

4.5. Data subjects can file a complaint with the Data Protection Inspectorate to protect their rights.

  1. Final Provisions

5.1. These Data Protection Terms and Conditions have been compiled in accordance with the regulation of the European Parliament and the Council on the protection of natural persons in the processing of personal data and on the free movement of such data, the Personal Data Protection Act of the Republic of Estonia and the relevant legislation of the Republic of Estonia and the European Union.

5.2. The data controller has the right to modify the data protection conditions by notifying the data subjects of the changes on the website and/or via the data controller’s e-mail.

5.3. If you have any questions, concerns or suggestions regarding the processing of your personal data, you can contact the controller using the following details:

OY Minlomer (reg. 14828561)

Ehitajate tee 13-11

12612 Tallinn

Harju County