PRIVACY POLICY AND PRINCIPLES FOR THE USE OF COOKIES

The principles below explain how OÜ Favorte (hereinafter Favorte or us) uses and protects your personal data that reaches us, in particular when advertising, offering and selling products and services or otherwise entering into contractual relations with us, applying for employment or using our websites (incl. www.favorte.ee).

Therefore, the following terms apply to you, for example, if you are our customer (e.g. you have bought our products or services) or a potential customer (e.g. you have negotiated a contract with us or subscribed to our newsletter list or otherwise consented to the processing of your personal data for marketing purposes), you are our cooperation partner or have entered into a contractual relationship with us in any other way (for example, you have entered into a sales or service agreement, agency agreement or other contract with us), as well as if you have visited our website or applied for a job.

Favorte processes personal data as a controller for the provision of services to clients, including making offers for the sale and lease of real estate property, renting and sale of real estate property, the conclusion and execution of reservation contracts, sales contracts, and lease contracts, for the provision of administrative services, for the execution of construction work, for the development of building projects and for the provision of other related services. As an authorized processor, Favorte processes personal information of the real estate bureau clients for submitting real estate sales and rental offers.

We process personal data in accordance with the terms and conditions set out below and in accordance with applicable law, including the General Data Protection Regulation (GDPR). Among other things, we respect your fundamental rights and the principles of transparency and legality.

1. General principles of personal data processing

Newsletters and other marketing information

With your consent, we may send you various promotional and informational texts for marketing purposes, including regular newsletters, promotional announcements, and information about customer events. We will use your personal information for this purpose until you request that we no longer send you information.

For this purpose, we generally process your personal data with your name and e-mail address, less often a telephone number or a postal address – depending on what personal data you have disclosed to us.

On the same legal basis and for the same purpose, we may also transfer your personal data to our cooperation partners, who we use in the development, advertising and sale of our products and services (especially real estate projects) (including relevant real estate companies and brokerage services).

We will only publish the names of lottery winners for marketing purposes with your consent.

Personal data of customers and potential customers

We process personal data (including, for example, name, personal identification code, e-mail address, telephone number, postal address) disclosed to us in the course of communicating with customers and potential customers, primarily for the purpose of establishing and maintaining customer relationships. We have a legitimate interest in answering inquiries, ensuring customer satisfaction and providing our own products and services. In addition, we process such data for the purpose of fulfilling our contractual obligations and protecting our rights.

For the above purposes, we may process your personal data, inter alia, if you have disclosed your personal data to us via the contact form on our website or by communicating with us by e-mail. For example, if you have asked us for information about a specific project or a price offer – so that we can send you the requested information, offer, etc. and prepare, conclude, execute and, if necessary, protect our rights in case of a negotiated contract.

For example, in the case of booking and sales contracts, we process your name, personal identification code, e-mail address, telephone number, current account number, financial and other information as necessary to prepare, enter into and perform the contract (and also for protecting rights). Until the conclusion of the contract, we process the relevant information for the purpose of concluding the contract (establishing a customer relationship) and protecting the rights, from the conclusion of the contract for the purpose of fulfilling the contract and protecting the rights. We process personal data for as long as it is necessary for the above purposes.

On the same legal basis and for the same purpose, we may also transfer your personal data to our partners, who we use to negotiate, prepare, conclude and enforce contracts and protect rights (e.g. brokerage service providers, notaries, legal service providers, etc).

Personal data of cooperation partners

We process the personal data of our cooperation partners, their employees and representatives, including, for example, the name, position, e-mail address, telephone number, date of birth or personal identification code, etc. of the contractual partner, their employee or representative, which are necessary for the performance of the contract, and, where appropriate, for the protection of rights.

For the same purposes, we may also transfer personal data to our other cooperation partners who we use to perform the contract and, if necessary, to protect rights (e.g. construction companies, legal service providers, etc.).

Personal data of job candidates

When applying for a job with us, we process the personal data of the candidates, which is necessary for conducting a competition for the job, for the purpose of determining the suitability for the position, as well as for preparing and negotiating contracts with the candidates selected by us.

Such information may include, but is not limited to, name, date of birth or personal identification code, postal address, e-mail address, telephone number, information on work experience (job, period of employment, position, responsibilities, achievements, etc.), information on education (educational institution, period of study, acquired education or qualification, etc), information on the existence or acquisition of training, diplomas, certificates, information on language skills and levels, information on other skills (e.g. driving or other competences), as well as other information provided by the candidate in the CV, letter of motivation (if provided) or other application documents. Also information on the position requested by the candidate, the salary, the recommender’s of the candidates and the content of the recommendations, where applicable, the content of the interview with the candidate and the information published there, and any other information the candidate discloses to us.

The legal basis for the processing of personal data of job candidates is our legitimate interest and/or your consent. In the case of a selected candidate, also the need to prepare and negotiate a contract between the parties.

Video surveillance

Video surveillance may be used on properties and territories owned and/or managed by us. You will be notified of the use of video surveillance by a notice sign installed at the entrance. This label also shows more specific facts (concerning specific video surveillance).

We can use video surveillance, among other things, on real estate leased by us (incl. buildings and areas) as well as on real estate for sale based on a legitimate interest. In particular to increase security and protect property and other rights. Where a video recording needs to be submitted or transmitted to law enforcement authorities, the legal basis for complying with such a requirement is the fulfilment of a legal obligation.

Video surveillance is generally stationary, digital, with audio recording and magnification. Video recordings can be watched again. Video surveillance is 24 hours a day.

Access to video recordings and surveillance systems is limited to authorized persons and is also technically and physically restricted/impeded.

2. General principles for the use of cookies

Favorte website www.favorte.ee and also websites created separately for Favorte real estate development projects use cookies (also known as HTTP cookie).

A cookie is a small text file that is sent by a web server to your web browser and stored on your computer’s hard drive. The cookie remembers your actions and preferences and allows providing you the best user experience when browsing our website.

The following cookies are used on these websites.

Temporary or session cookies are temporarily stored on the visitor’s computer while the website is being used, and the computer deletes them after closing the web browser. These cookies are necessary to ensure the performance and functionality of the website, and they are also used, for example, to remember the language choice of the website. It is not possible to refuse the use of session cookies necessary to ensure the performance of the website

Persistent cookies are stored on the user’s computer after closing the web browser. Persistent cookies use first-party cookies and third-party cookies

We use author’s or first-party cookies so that the website can use them to store information that will be reused the next time you visit the site. First-party cookies are stored for up to 24 months.

We use third-party cookies for advertising and marketing purposes, and they have been created by various service providers to help us improve our web services (e.g. Google, Facebook, etc.). The purpose of these cookies is to send behavioural advertising to website visitors for marketing purposes.

From third-party cookies, we also use statistical cookies from various service providers (e.g. Google Analytics, etc.) to understand the behaviour of website users, including where users come to our website, which subpage they visit the most, how many users visited the website in a certain period of time, what time they visit the website, etc. With the help of statistical cookies we can measure, evaluate and improve the performance of our websites.

Third-party cookies are usually stored on the user’s device after the user’s consent for a period of a few months to a few years, until the deadline set by the third-party service provider.

We use the data collected through cookies only within the organization, third parties do not have the opportunity to access the collected data.

Prohibition of the use of cookies. By visiting the website, the user of the website can decide whether and to what extent the user allows the use of cookies. It is not possible to refuse cookies necessary for the operation of the site. The website user can additionally change the browser settings or delete cookies in their browser settings.

For more information on how to set (including disable/delete) cookie preferences in the most popular web browsers, see

Google Chrome

Firefox

Internet Explorer

You can change the browser settings of the device you are using to make the necessary settings.

3. Time limits for the storage of personal data

In the case of contractual relations, we process (incl. retention) personal data for as long as it is necessary for the performance of rights and obligations arising from the contract and for the protection of rights. We use reasonable steps to ensure that outdated personal information is updated as necessary and that personal information that is no longer needed is deleted.

If personal data has been deleted at your request or you have withdrawn your consent to the processing, we will only retain such data and to the extent necessary to fulfil our obligations, protect our or third parties’ legitimate interests and rights, comply with public authority or law enforcement orders, resolve legal disputes, etc.

We process (incl. retain) the personal data of candidates who do not reach an employment contract for as long as it is necessary to complete the application process (usually until the conclusion of contracts with the selected persons and informing the other candidates). With the consent of such job candidate, we will process (incl. retain) his or her personal data for an additional period of up to 1 year from the receipt of the data (e.g. if he or she agrees to be contacted in the future when a suitable position becomes available, etc.).

Video recordings are generally stored for 6 months, but we may make exceptions depending on technical solutions capabilities as well as the need to comply with legal obligations or the need to prosecute or protect rights.

4. To which third parties do we transfer your personal data?

Outside our association, third parties have access to your personal data only in limited cases.

Transfer of personal data to subsidiaries

Due to a legitimate interest, we may share personal information with our subsidiaries established for the development of various real estate properties (all located in the European Union) to enable the provision of products and services. To a limited extent, we also share information within the Group when it is needed to make management decisions or use cross-group data systems.

Transfer of personal data to persons providing services to us

We order services from third parties, including, for example, accounting, IT, video surveillance system administration, legal services, business software services, etc. This list is expanding and changing over time, as we may from time to time order services in new areas as well as change service providers or order services from more cooperation partners, etc. In certain cases, we provide personal information to such partners to enable them to provide the service ordered.

We make sure that the aforementioned cooperation partners also respect your right to data protection. As a rule, we have regulated it through contractual obligations, in some cases the obligation of confidentiality for service providers also arises from legislation (e.g. auditors, lawyers, etc.).

Public authorities and law enforcement agencies

We pass on your personal data to public authorities (including, for example, the Tax and Customs Board) and law enforcement agencies if we have a legal obligation to do so.

5. Place of data processing

The place where your data is processed is in the European Union. We do not process (including retain or transfer) your personal data outside the European Union or to countries that have not previously been the subject of a Commission decision on adequacy under Article 25 (6) of Directive 95/46/EC or Article 45 (1) of the successor GDPR.

6. Your rights regarding the processing of personal data

Right to withdraw consent

If you have given us consent to the processing of your personal data, you have the right to withdraw your consent at any time by writing to us at favorte@favorte.ee. Withdrawal of consent shall not affect the lawfulness of the processing under consent before withdrawal. Nor does it affect the processing of data for which we have any other legal basis for processing (e.g. when we process your personal data in order to fulfil a contract with you).

Right to obtain information

You have the right to receive information on whether and what kind of personal data we process, as well as for what purpose we process the data. You have the right to request access to your personal data.

If you want to receive relevant information or get acquainted with the personal data collected about you, please contact us at favorte@favorte.ee.

Right to rectification

You have the right to request the correction of incorrect or incomplete personal data concerning you. You can submit a corresponding request by contacting favorte@favorte.ee.

Right of erasure of data

You have the right to request the erasure of personal data concerning you if the personal data are no longer necessary for the purposes for which they were collected or otherwise processed, if you have withdrawn your consent to processing or if your processing of personal data does not comply with applicable law. You can make a request if we do not have a legal basis to process your respective personal data.

Right to restrict processing

In certain cases, you have the right to request a restriction on the use of your personal data. You can make such a request if it is necessary to find out, for example, the legality of the use or the accuracy of the data.

Right to data transfer

You have the right to obtain a copy of your personal data from the controller, to transfer this data to another controller or to require the controller to transfer the data directly to another controller, if technically feasible. You can make such a request if the data is structured, in a publicly available format and in machine-readable form, and the processing must be automated and based on your consent or contract.

Right to raise objections

You have the right to object, if there are good reasons, to the use of your data in the performance of a task in the public interest or in the processing of an undertaking on the basis of a legitimate interest. Objection to direct marketing or profiling is your absolute right, in which case the processing of the data must be stopped.

7. Contact information

The controller of your personal data is Osaühing Favorte, registry code 10040012.

If you have any questions, requests or complaints regarding the above policy and principles, please contact us at favorte@favorte.ee.

If you find that the processing of your personal data does not comply with the requirements of the General Data Protection Regulation, you have the right to apply to the Data Protection Inspectorate or a court to protect your rights and interests. However, we reaffirm that we look forward to contacting us first.

8. Possible changes

We reserve the right to change and update all of the above terms and conditions (including in connection both personal data and the use of cookies) without prior notice to ensure that the terms and conditions are in line with our actual needs and preferences and that they comply with law and current practice.