1. General Provisions
1.1. This privacy policy governs the principles of collecting, processing, and storing personal data. Personal data is collected, processed, and stored by the data controller Thinkie OÜ (hereinafter referred to as the data controller).
1.2. In the context of this privacy policy, the data subject is a customer or any other natural person whose personal data is processed by the data controller.
1.3. In the context of this privacy policy, a customer is anyone who purchases goods or services from the data controller’s website.
1.4. The data controller follows the principles of data processing established by legal acts, including processing personal data lawfully, fairly, and securely. The data controller can confirm that personal data has been processed in accordance with legal requirements.
2. Collection, Processing, and Storage of Personal Data
2.1. The personal data collected, processed, and stored by the data controller is obtained electronically, mainly through the website and email.
2.2. By sharing their personal data, the data subject grants the data controller the right to collect, organize, use, and manage personal data for the purposes defined in the privacy policy, which the data subject directly or indirectly provides when purchasing goods or services through the website.
2.3. The data subject is responsible for ensuring that the data they provide is accurate, correct, and complete. Providing knowingly false information is considered a violation of the privacy policy. The data subject must promptly inform the data controller of any changes to the provided data.
2.4. The data controller is not responsible for any damage caused to the data subject or third parties due to the provision of incorrect data by the data subject.
3. Processing of Customer Personal Data
3.1. The data controller may process the following personal data of the data subject:
3.1.1. First and last name;
3.1.2. Date of birth;
3.1.3. Phone number;
3.1.4. Email address;
3.1.5. Delivery address;
3.1.6. Bank account number;
3.1.7. Payment card details.
3.2. In addition to the above, the data controller has the right to collect information about the customer from public registers.
3.3. The legal basis for processing personal data is Article 6(1)(a), (b), (c), and (f) of the General Data Protection Regulation (GDPR):
a) The data subject has given consent for the processing of their personal data for one or more specific purposes;
b) Processing is necessary for the performance of a contract to which the data subject is a party or for taking pre-contractual measures at the request of the data subject;
c) Processing is necessary for compliance with a legal obligation to which the data controller is subject;
f) Processing is necessary for the legitimate interests pursued by the data controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, especially if the data subject is a child.
3.4. Processing of personal data according to the purpose of processing:
Purpose: Security and safety
Maximum retention period: As defined by law
Purpose: Order processing
Maximum retention period: 1 year
Purpose: Ensuring the functionality of the e-store services
Maximum retention period: 1 year
Purpose: Customer management
Maximum retention period: 1 year
Purpose: Financial activities, accounting
Maximum retention period: As defined by law
Purpose: Marketing
Maximum retention period: 1 year
3.5. The data controller has the right to share customer personal data with third parties such as authorized data processors, accountants, transport and courier companies, and payment service providers. The data controller is responsible for personal data processing. The data controller provides the necessary personal data for payment processing to the authorized processor Maksekeskus AS.
3.6. When processing and storing the personal data of the data subject, the data controller applies organizational and technical measures that ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, or any other unlawful processing.
3.7. The data controller retains the data of data subjects depending on the purpose of processing, but no longer than 3 years.
4. Rights of the Data Subject
4.1. The data subject has the right to access and review their personal data.
4.2. The data subject has the right to receive information about the processing of their personal data.
4.3. The data subject has the right to correct or supplement inaccurate data.
4.4. If the data controller processes the data subject’s personal data based on the data subject’s consent, the data subject has the right to withdraw their consent at any time.
4.5. To exercise their rights, the data subject can contact the e-store customer support at info@thinkie.com.
4.6. The data subject has the right to file a complaint with the Data Protection Inspectorate to protect their rights.
5. Final Provisions
5.1. These data protection terms have been prepared in accordance with Regulation (EU) No. 2016/679 of the European Parliament and of the Council on the protection of natural persons regarding the processing of personal data and the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation), the Personal Data Protection Act of the Republic of Estonia, and other Estonian and European Union legal acts.
5.2. The data controller has the right to amend the data protection terms partially or completely by informing data subjects of the changes via the website https://thinkie.com.