Privacy notice

This Privacy Notice describes how Kaarsilla Kinnisvara OÜ (registration code 10081732, address Ülikooli 2A, 51003 Tartu, Republic of Estonia), its subsidiaries and affiliated companies operating under the “Kaarsilla Kinnisvara” brand ; hereinafter referred to as “we”, Kaarsilla Kinnisvara) process personal data of potential and existing customers, related persons, sales contacts, website visitors and other data subjects (hereinafter referred to as “you”) who come into contact with Kaarsilla Kinnisvara in the course of providing its services. This Privacy Notice applies if you use, have used, or have expressed an intention to use our services, including by visiting our website or providing us with your email address to receive our newsletters, or if you have submitted an application or resume to us for employment.

In the cases described, we act as data controller and are responsible for the processing of your personal data.

Collection of your personal data. We collect your personal information in the following ways:

You provide us with your personal data yourself (e.g. by contacting us by phone, email or website, through social media channels, at our office, by booking with us via our website, at our customer days or other public events we organise or through other online channels, or by uploading your CV on our website);
Your personal information is provided to us by a third party (e.g. a broker or when a third party payment service provider confirms whether or not your payment was successful);

Personal data processed. We process the following personal data of the following data subjects:

When you subscribe to our website newsletter or “Register your interest “, we will process your name and contact details (contact phone and email).
When you register on our website for development projects, we will process your name and contact details (contact phone and email) and your preferences for the commercial space you are interested in (size, price).
For those who register and participate in our customer days, we will process your name and contact details (address, contact phone and email) and your preferences for the commercial space you are interested in (size, price).
In the case of entering into a contract with us (including entering into a booking contract via the website), we process data relating to your name, personal identification number, contact details (address, contact telephone and e-mail) and marital status; we also process data (other than marital status data) relating to your authorised representative.
We process your image (video and photographic material) when you participate in our customer days or other public events organised by us.
When you are on the territory of our development site, we will process your image, all your other personal data and your activities that are visible on the video surveillance area of the territory.

Purpose and legal basis for processing.We process your personal data for the following purposes and on the following legal basis:

To enter into or perform a contract with you; on the basis of our legitimate interest, for example to contact you for marketing purposes, where our previous contact with you suggests that you are interested in such an offer and you have not expressed dissatisfaction or objection to such contact. In such circumstances, we do not consider that your interests and rights outweigh our legitimate interest in marketing our products and services;
To enforce a contract with you, including to identify, prove and pursue claims for breaches of contract or law. In a situation where you are in breach of contract or law, your interests or rights do not outweigh our legitimate interest;
to collect website traffic, usage statistics and other non-personalized technical information about the use of the website for the purpose of improving the website and services;
To contact you to ask for feedback on our services and products with a view to conducting a customer satisfaction survey and you have not expressed dissatisfaction or objected to such contact.
to comply with our legal obligations.

Your personal data may also be processed where it is necessary in a particular case for our or a third party’s legitimate interest, unless such interest overrides your interests or fundamental rights and freedoms for which the personal data must be protected, or where it is necessary to protect your vital interests or the vital interests of another natural person.

We do not process special categories of personal data.

Processing based on consent. We may also process your personal data on the basis of your consent (e.g. sending newsletters for direct marketing purposes). Where the processing is based on consent, you can withdraw your consent at any time by contacting us using the contact details below or by clicking on the “unsubscribe” link at the end of each email. Please note that the withdrawal of consent does not affect the lawfulness of processing based on consent that was carried out prior to the withdrawal of consent.

Authorised processors. We use carefully selected service providers (processors) to process your personal data. By doing so, we remain fully responsible for your personal data.

We use the following categories of processors: data storage service providers, email service providers, customer relationship management service providers, brokerage service providers, construction service providers, marketing service providers, payment service providers, employment service providers.

If you would like more detailed information about our processors (e.g. their names and location), please contact us using the contact details below.

Third parties. We will only share your personal information with third parties where this is set out in this Privacy Notice, where required by applicable law (e.g. where we are required to share personal information with public authorities) or with your consent.

We may share your personal information with auditors and legal advisors of Kaarsilla Real Estate (PS! Is it also shared with other companies related to Kaarsilla or is that not an issue?). The legal basis for such sharing is our respective legal obligation or legitimate interest.

Transfer of personal data outside the European Union. Our processors may process your personal data outside the European Union (including in the United States). We will only transfer your personal data outside the European Union if we have a lawful basis to do so, including to a recipient: i) located in a country that is assessed by the European Commission as providing an adequate level of protection for personal data (this includes organisations certified under Privacy Shield); or ii) under a contract that meets European Union requirements for the transfer of personal data to processors located outside the European Union.

If you would like more detailed information about the transfer of your personal data outside the European Union (e.g. the names of the recipients and the legal basis for the transfer), please contact us using the contact details below.

Security. We implement technical and organisational security measures to protect your personal data, taking into account (i) the state of the art, (ii) the cost of implementation, (iii) the nature, scope, context and purposes of the processing, and (iv) the risks to you. Such security measures include, inter alia, access management, staff training, two-factor authentication, data encryption.

Data retention. We will retain your personal information for as long as necessary for the purposes for which it was collected, for as long as necessary to protect our interests or as required by applicable law.

Once you have signed a contract with us, we will store your personal data as follows:

in accordance with Estonian accounting and tax laws, we keep information related to accounting records for 7 years from the end of the relevant financial year;
in accordance with the limitation periods set out in Estonian law, we retain personal data relating to contractual claims for a maximum of 10 years from the date on which the claim becomes enforceable.

If you have registered as an interested party in one of our products, we will keep your personal data for 5 years from the day we last contacted you.

If you have taken part in one of our customer days and you have not signed any contract with us, your personal data will be stored for 5 years from the date of the relevant customer day. Photographic and video material captured by us will be retained for 5 years from the date on which the material was captured.

Your rights. You have all the rights of a data subject with respect to your personal data to the extent required by applicable data protection laws. These rights include:

requesting access to your personal data;
obtain a copy of your personal data;
correcting inaccurate or incomplete personal data;
deletion of personal data;
restrictions on the processing of personal data;
the transfer of personal data;
objecting to the processing of personal data based on legitimate interest and processed for direct marketing purposes.

To exercise your rights, please contact us using the contact details below.

If you think your rights have been infringed, you have the right to lodge a complaint with the Data Protection Inspectorate or take legal action.

Change your privacy notice. If our practice with regard to the processing of personal data changes, or if we need to amend the Privacy Notice as a result of applicable data protection legislation, other legislation, case law or guidelines or practices issued by competent authorities, we have the right to unilaterally amend the Privacy Notice at any time. In such event, we will notify you by email in reasonable advance of the effective date of the changes.

Applicable law. As we are a company registered in the Republic of Estonia, the law of the Republic of Estonia applies to the processing of your personal data.

Contact details. If you have any questions regarding the processing of your personal data or if you wish to exercise your rights as a data subject, please contact us using the following contact details:

Ülikooli 2A, Tartu 51003

e-mail address info@kaarsilla.ee