PRIVACY POLICY

Projector OÜ (Projector) care about your privacy and the protection of your personal data.

This privacy policy (the “Policy”) explains how Projector (contact information below) collects and uses information when you use any of the services located on our website at www.projector.ee (the “Website”) or if you use any other services (the “Services”) that we provide to you.

By using or interacting with the Website or our Services, you, as a user of our website or as our client, (“User”, “Client” or “you”) agree to the provisions of this Policy and confirm that you have read and understood all of the provisions stated in the Policy.

We process Personal Data under this Privacy Policy and in accordance with applicable legislation, including the General Data Protection Regulation (2016/679) (the “GDPR”) and the applicable national data protection laws in Estonia, Latvia and Lithuania (“Data Protection Law”).

We are committed to ensuring the privacy and confidentiality of the information pertaining to our clients, potential clients, their affiliates and affiliated individuals, and to adhering to the policy set out below in congruence with our professional responsibilities and the applicable Data Protection Laws.
We are the controller of the Personal Data that falls under the scope of this Policy.

1. The scope of the Policy
This Policy describes how we process Personal Data in connection with:
• all matters related to our clients, former clients and potential clients;
• newsletters and marketing information;
• recruitment processes;
• the cookies that are used on our Website;
• all of our statutory obligations with respect to the GDPR, any relevant Data Protection Law, and any other laws and regulations that may be applicable).

2. Purposes, means and retention terms of data processing
a) News, publications and events: We may use the information that you have provided (name, title, position, your e-mail address, any provided phone numbers, your address and other information) to send you news about the latest developments at the Projector, the scope of services that we provide to you, as well as information about any upcoming events that may be of interest to you, including educational seminars. We will use your Personal Data for this purpose until you inform us that you no longer wish to receive such information from us.
b) Cookies: We use cookies to obtain information about your use of our Website. Cookies allow us to provide you with a more streamlined and accessible experience when using the Website. Third-party cookies help us to improve the relevancy of the advertisements we run in different channels. The information generally does not comprise any data that would allow us to individually identify you as a natural person.
c) Recruitment: We may use Website and other contact channels that are listed on the Website to collect information about your employment or internship application. We will utilize the Personal Data that has been included in the documents that you have provided to us in your application. We will retain the data that we have obtained via our recruitment processes for as long as necessary to evaluate the application and in accordance with all relevant laws and regulations. Furthermore, we may ask for your consent to retain your Personal Data for some time after we have evaluated your application.

3. The legal basis for processing your Personal Data
We process your Personal Data on the basis of:
• your consent;
• legal agreement between us that establishes a basis for data processing;
• legal obligations to which we are subject; and / or
• our legitimate interest to ensure the quality of our services.
We limit the processing of your Personal Data to the scope of purpose for which the data was collected. Access to your Personal Data will be restricted to personnel who are required to process the Personal Data to fulfil their professional responsibilities and their duties to you as the Client. Your Personal Data is not stored or processed longer than is necessary with respect to the data processing purposes that we have listed above.

We have taken the appropriate technical and organizational measures to ensure the secure processing of your Personal Data. Your data will be processed in such a manner to ensure confidentiality and data integrity.

4. The transfer of your Personal Data to third parties
We do use the services of certain third parties to ensure the functionality of our services and the Website. We are required to transfer your Personal to these third-party service providers, so that these third parties would be able to provide us with their services. These third-party services providers are to be considered data processors. The Personal Data that will be transferred to these third-service providers will be limited to the minimum that is required to ensure the provision of third-party services.

We have ensured that all third-party service providers to whom we transfer your Personal Data will follow our instructions with respect to how they process your Personal Data. The transfer of your Personal Data is regulated by the data processing agreements or data processing terms that exist between us and third-party service providers. Any third-party service providers – as the data processors, must ensure that they process your Personal Data with the same level of care and diligence as we do and are legally liable to you and to us if the data processors act contrary to those warranties. Furthermore, these third-party service providers are required to implement technical and organizational measures to ensure an equal level of data protection to the one that we bring to our data processing efforts.

5. Your rights as a data subject
We have obligation to ensure that your Personal Data is kept accurate and up to date. We kindly ask you to assist us to comply with this obligation by ensuring that you inform us of any changes that have to be made to any of your Personal Data that we are processing.
You may, at any time, exercise the following rights with respect to our processing of your Personal Data:
a) Right to access: You have the right to request access to any data that can be considered your Personal Data. This includes e.g. the right to be informed on whether we process your Personal data, what Personal Data categories are being processed by us, and the purpose of our data processing.
b) Right to rectification: You have the right to request that we correct any of your Personal Data if you believe that it is inaccurate or incomplete.
c) Right to object: You are entitled to object to certain processing of Personal Data, including for example, the processing of your Personal Data for marketing purposes or when we otherwise base our processing of you on a legitimate interest.
d) Right to erasure: You may also request that your Personal Data be erased if the Personal Data is no longer necessary for the purposes for which it was collected, or if you consider that the processing is unlawful, or if you consider that the Personal Data has to be erased to enable us to comply with a legal requirement.
e) Right to data portability: If your Personal Data have is being automatically processed with your consent or on the basis of a mutual contractual relationship, you may request that we provide you that Personal Data in a structured, commonly used and machine-readable format. Moreover, you may also request that the Personal Data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible.
f) Right to withdraw your consent: In cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time.
g) Opt-out from marketing: We will also give you the opportunity to opt out of our communication with you whenever we send you information about the Firm, the events that we organize or any other information that we believe may be of interest to you. Additionally, you can also opt out at any time by contacting us.

If you have complaints on how we process your Personal Data, or you would simply like to know more about our data processing activities, feel free to contact us at any time by using the information noted in the last section of this Policy.

You do have the right to lodge a complaint with a Data Protection Authority (“DPA”) if you think that your Personal Data is being processed incorrectly or your data subject rights have been violated by us. You can lodge a complaint by contacting the DPA that is local to your jurisdiction i.e. the location of the alleged violation of your data subject rights or the inappropriate processing or your data, or the place you live and work.
This is the list of DPAs that are relevant to the scope of this Policy:
• The Estonian Data Protection Inspectorate in Estonia: http://www.aki.ee/en
• The Data State Inspectorate in Latvia: http://www.dvi.gov.lv/en/
• The State Data Protection Inspectorate in Lithuania: https://www.ada.lt/go.php/lit/Eng

6. The location of the processing of your data
We store and process Personal Data within the European Union.

By submitting your Personal Data to us or by consenting to the processing of your Personal Data you agree to the processing of your data, including data storage. We will take all reasonably necessary precautions to ensure that your data is treated securely and in accordance with the applicable Data Protection Laws. We will not store any of your Personal Data longer than necessary to fulfil the purposes set out in this Policy. For example, we may transfer your Personal Data based on:
• an adequacy decision by the European Commission;
• standard data protection clauses elaborated by the European Commission;
• standard data protection clauses elaborated by a DPA;
• using other possible safeguards and derogations where it is allowed by the applicable laws.
As with all of your Personal Data, you may request that we inform you on the details of the processing of your Personal Data on the basis of Article 15 of the GDPR. You may, as with the exercise of any your rights as a data subject, do so by contacting us via the information that has been provided at the end of this Policy.

7. Contacts
Feel free to contact us with regards to any questions, inquiries, requests or complaints with respect to the processing of your Personal Data at: info@projector.ee

8. Changes to the Policy
We may make any changes to this Policy as we see fit. If the Policy has been changed in any way, then the newest edition of this Policy will be published on our website. We encourage you to check whether any changes have been made to the Policy from time to time.