Privacy Policy
Privacy and Cookie Policy
Privacy Policy
1. General terms and conditions
1.1. This document (hereinafter referred to as the Privacy Policy) explains how CH Konsultatsioonid OÜ, registered location Soola 8, 51013 Tartu, Estonia, registration number 11229059 (hereinafter referred to as CHK), uses personal data and ensures the lawful processing, confidentiality and security thereof.
1.2. CHK is responsible for meeting its obligations and for ensuring the security and fair processing of personal data by its employees and on its systems.
1.3. CHK processes personal data according to the principles set out in the General Data Protection Regulation, the Personal Data Protection Act and other relevant legislation, the guidelines of the Data Protection Inspectorate and this Privacy Policy.
1.4. Processing of personal data at CHK is based on the following principles:
1.4.1. Lawfulness, fairness and transparency
1.4.2. Purpose limitation – CHK processes personal data for specifically defined, legitimate purposes. These purposes are described in section 3 of this Privacy Policy (‘What does CHK use personal data for?’).
1.4.3. Data minimisation – CHK only processes personal data as necessary to achieve the purpose for which they are being processed.
1.4.4. Accuracy – CHK takes appropriate measures to ensure the accuracy of the data processed, while inaccurate and redundant data are rectified or deleted as soon as possible.
1.4.5. Storage limitation – CHK will only retain personal data for as long as necessary for the purpose for which it is processed or for compliance with a legal obligation.
1.4.6. Integrity and confidentiality – CHK has put in place physical, organisational and technological security measures to ensure the lawful processing and protection of personal data.
1.5. CHK reserves the right to unilaterally modify this Privacy Policy at any time by notifying of this online at www.chk.ee/privaatsuspoliitika/.
2. Definitions
2.1. Personal Data – any information relating to an identified or identifiable natural person. An identifiable natural person 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.
2.2. Special Categories of Personal Data – personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data used to uniquely identify a natural person, health data or data concerning the sexual life and sexual orientation of a natural person.
2.3. Service – services provided by CHK to the customer. CHK provides the following services (which you can read about on the CHK website www.chk.ee):
2.3.1. Accounting services
2.3.2. Business and tax consultation
2.3.3. Brokering of business software
2.3.4. Brokering of insurance
2.3.5. Contact person service within the meaning of Section 631 of the Commercial Code.
2.4. Data Subject – a natural person whose personal data CHK processes. For the purposes of this Privacy Policy, data subjects are in particular CHK’s business partners and persons whose personal data CHK obtains in the course of the provision of services to business partners, as well as the close associates of such persons, CHK’s employees and their close associates, and job applicants.
2.5. Processing of Personal Data – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
2.6. Personal Data Breach – a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed.
2.7. Controller – the natural or legal person, public authority or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
2.8. Processor – a natural or legal person, public authority or other body which processes personal data on behalf of the controller. CHK acts as a Controller or Processor in different processing operations.
2.9. Recipient – a natural or legal person, public authority or other body to which the personal data are disclosed, whether a third party or not. Recipients of personal data within the meaning of this Privacy Policy are, in particular, Processors and public authorities, the duty to transfer or disclose personal data to whom arises from law.
3. What Personal Data does CHK process?
3.1. CHK processes the following Personal Data when providing the Service:
3.1.1. First name and surname of the Data Subject
3.1.2. The date of birth and personal identification number of the Data Subject
3.1.3. The telephone number and e-mail address of the Data Subject
3.1.4. The address of the Data Subject
3.1.5. The bank account number of the Data Subject
3.1.6. Information about the Data Subject’s income, its origins and amount
3.1.7. The Data Subject’s place of work, salary data and sick leave data
3.1.8. The qualifications, education and hobbies and a photograph of the Data Subject
3.1.9. Information on the identity document (type of document, issuer, validity and Personal Data and photograph on the document)
3.1.10. Information on the status of the person (“Is the person a politically exposed person or a close colleague or family member of such a person?”)
3.1.11. Cookies, IP address and browser details
4. Why does CHK process Personal Data (purpose of processing)?
4.1. CHK processes the Personal Data of Data Subjects only for the purposes of providing the Service, improving the quality of the Service and fulfilling its legal obligations.
4.2. CHK collects from the Data Subject only the Personal Data necessary for the purposes set out in section 4.1.
4.3. If the Data Subject wishes to use the Services offered by CHK, the Data Subject must provide CHK with all of the requested Personal Data. In the event of failure to provide the data, CHK will be unable to provide the Service to the Data Subject.
4.4. CHK may collect Personal Data other than those necessary for the provision of the Service with the separate consent of the Data Subject for the specific processing.
5. From where does CHK obtain Personal Data?
5.1. CHK obtains Personal Data from the Data Subject or the Customer by taking statements directly or by e-mail when transmitting data and from documents, invoices, etc. submitted by the Customer.
5.2. CHK obtains Personal Data from website visitors from the web browser used by the Data Subject.
5.3. When the Data Subject themselves enters the data on the CHK contact form at https://chk.ee/kontakt
5.4. When the Data Subject themselves enters data on the CHK job application contact form at https://chk.ee/tule-toole
5.5. From public sources and databases
5.6. From national information systems to which CHK has access due to the specific nature of the Service it provides
5.7. From identity documents
6. Legal basis for the processing of personal data
6.1. CHK obtains Personal Data from the Data Subject or the Customer by taking statements directly or by e-mail when transmitting data and from documents, invoices, etc. submitted by the Customer.
6.2. CHK obtains Personal Data from website visitors from the web browser used by the Data Subject.
6.3. When the Data Subject themselves enters the data on the CHK contact form at https://chk.ee/kontakt
6.4. When the Data Subject themselves enters data on the CHK job application contact form at https://chk.ee/tule-toole
6.5. From public sources and databases
6.6. From national information systems to which CHK has access due to the specific nature of the Service it provides
6.7. From identity documents
7. To whom does CHK transfer/disclose Personal Data?
7.1. CHK transfers or discloses Data Subjects’ Personal Data to Recipients only if this is necessary for the provision of the Service to the Customer, for the performance of contractual obligations or if the transfer or disclosure is required by law.
7.2. CHK does not transfer Data Subjects’ Personal Data to third countries or international organisations.
8. How long does CHK retain Personal Data?
8.1. CHK retains Personal Data for as long as necessary for the purposes for which the Personal Data is Processed (see also clause 4 of this Privacy Policy) or for the fulfilment of legal requirements. If the time limit for the retention of Personal Data under the Personal Data Retention Act has expired and the Personal Data is no longer necessary for the purposes for which the Personal Data was Processed, CHK returns to the Customer all originals of the documents provided by the Customer and deletes the Personal Data in a manner that does not allow for subsequent recovery. If the Customer does not accept the originals of the documents returned by CHK, CHK may destroy the documents.
8.2. Personal Data contained in accounting source documents, registers, contracts, accounting statements and other business documents are retained for seven (7) years from the end of the financial year in which the document was recorded in the accounts.
8.3. CHK retains employment contracts and the Personal Data contained therein for 10 (ten) years from the end of employment. The CVs of unsuccessful applicants are retained for one (1) year from the date of their rejection.
8.4. Data processed to comply with requirements for the prevention of money laundering and terrorist financing are retained for five (5) years after the performance of the transaction or legal obligation or the termination of the business relationship.
9. The Data Subject has the right to:
9.1. access their Personal Data and obtain printouts and copies thereof;
9.2. request information about the categories of Personal Data being Processed and the purposes of such processing;
9.3. request the rectification of their Personal Data if the data are incorrect or inaccurate;
9.4. request the deletion of their Personal Data if processing is no longer necessary;
9.5. request the restriction of the processing of their Personal Data if the Data Subject has submitted a request for rectification or erasure of the Personal Data or contested the accuracy of the Personal Data being Processed;
9.6. object to the processing of Personal Data in the public interest or that of CHK (including for direct marketing purposes).
9.7. Where the processing of Personal Data is based on the Data Subject’s consent or the performance of a contract or in preparation for entry into a contract with the Data Subject and the Personal Data are Processed by automated means, the Data Subject may receive the Personal Data they have provided to CHK in a structured, commonly used format in a machine-readable form and to transmit such data to another Controller.
9.8. In the event that the Data Subject has consented to the processing of their Personal Data, the Data Subject has the right to withdraw their consent at any time. Withdrawal of consent does not render unlawful any processing already carried out on the basis of consent;
9.9. file a complaint or a request for information to the Data Protection Officer by e-mailing andmekaitse@chk.ee ;
9.10. file a complaint with the Data Protection Inspectorate (www.aki.ee, Väike-Ameerika 19, 10129 Tallinn) if the Data Subject considers that the processing of their Personal Data is unlawful.
10. Conditions for complying with a Data Subject’s request for information
10.1. CHK will comply with the Data Subject’s request for information or take the action requested by the Data Subject without delay, but no later than within 30 (thirty) calendar days of receipt of the request. If CHK considers that the request for information is not legitimate, CHK will notify the Data Subject thereof without delay, but no later than within 30 (thirty) calendar days. In cases where it is difficult to comply with the Data Subject’s request for information, the aforementioned deadline may be extended to a maximum period of 60 (sixty) calendar days.
10.2. CHK will comply with the Data Subject’s legitimate request for information free of charge. In cases where the Data Subject’s requests are manifestly unreasonable or excessive, in particular because of their repetitive nature, CHK may charge a reasonable fee or refuse to provide the requested information or take the requested action.
10.3. CHK will comply with the Data Subject’s request for information:
10.3.1. at the CHK office, by providing the Data Subject with a copy or printout of a document containing their Personal Data;
10.3.2. by sending the Personal Data electronically to the Data Subject’s e-mail address. CHK only transfers Personal Data electronically at the request of the Data Subject or their legal representative. If the Personal Data to be transmitted contain Special Categories of Personal Data, the Personal Data are transmitted by e-mail only in encrypted form.
10.4. CHK has the right to ask the person making a request for information or another request to provide proof of identity.
10.5. If the request for information is made by a legal representative of the Data Subject, CHK has the right to require from them proof of their right of representation.
Cookie Policy
What is a cookie?
A cookie is a small file (less than 1 kB) consisting of numbers and letters that is stored by your web browser (e.g. Chrome, Firefox or Safari) on your computer device (including smartphones). Only the cookies that our website requests are stored by the browser when you visit our website.
What are cookies used for?
The purpose of a cookie is to remember your activities and preferences. This information allows us to provide you with a pleasant experience when visiting and browsing our website, to inform you about content, to make recommendations and to personalise advertising. Without cookies, we would not be able to offer you all of the features of our website.
Cookies allow us to recognise you as a repeat visitor to our website and facilitate the collection of website traffic statistics. The collection of website traffic statistics helps us to improve and enhance the navigation experience of visitors to our website.
What cookies does our website use?
The CH Konsultatsioonid website www.chk.ee uses the following cookies:
1. Session cookies – We use session cookies to maintain the functionality of the website. The use of session cookies helps the website administrator to aggregate your activities on the website. The collection of cookies starts when you open a browser window, and cookies are deleted when you leave the browser.
2. Persistent cookies – We use these cookies to analyse your behaviour in order to improve our website. These cookies provide us with information about e.g. the number of visitors to the website, the pages they visit and the total time spent on the website. All the information collected by cookies is aggregated with similar information collected from other users and is therefore anonymous. We do not identify individual visitors.
3. Advertising cookies – Cookies used by other websites to show you personalised advertising. CH Konsultatsioonid does not control the collection, creation and use of these cookies. More information about them can be obtained from third parties.
| Name of cookie | Description/type | Moment of creation | Expiry |
| _fbp | This cookie is used by Facebook to show the customer advertisements that are relevant and interesting to them and therefore more valuable to publishers and third-party advertisers. | When entering the website | 3 months |
| _ga | This is a Google Analytics cookie that collects web traffic statistics to improve the visitor experience. It is used to distinguish users. | When entering the website | 2 years |
| _gat | This cookie is used by Google Analytics to evaluate the objectives of a user’s visit, to generate reports on site activity for the site administrator and to improve the visitor experience. It is used to improve response speed. | When entering the website | 1 minute |
| _gid | This cookie is used by Google Analytics to evaluate the objectives of a user’s visit, to generate reports on site activity for the site administrator and to improve the visitor experience. It is used to distinguish users. | When entering the website | 24 hours |
Can I opt out of cookies?
You agree to the use of cookies on the CH Konsultatsioonid website, in the Information Society service settings or in your web browser.
You can configure your browser to refuse some or all cookies.
Please note that if you disable the use of all cookies on your browser, this may limit the functionality of our website and other websites you visit.
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