1.1. Data subject is a natural person about whom OÜ My Apartments (hereinafter My Apartments) has information or information by which a natural person can be identified. Data subjects are, for example, natural persons who are Clients, Lessees, Partners and Employees about whom My Apartments has Personal data.
1.3. Personal data means any information relating to an identified or identifiable natural person.
1.4. Processing of personal data means any operation performed on Personal data of a Data subject. For example, Personal data collection, recording, structuring, storage, alteration and disclosure, making available, retrieval and extraction, use, transmission, cross-use, alignment, blocking, deletion or destruction or a set of aforementioned operations, regardless of the manner in which the operations are carried out or the means used.
1.5. Client is any natural or legal person who intends to or has entered into an agreement with My Apartments for temporary use or Lease of the premises located at Sakala 11, or has requested to use or is using other services provided by My Apartments in relation to the foregoing.
1.6. Agreement is an Accommodation agreement or Lease contract concluded between OÜ My Apartments and the Client.
1.7. The Website of My Apartments is www.myapartments.ee
1.8. Visitor is a person who uses the website of My Apartments.
1.9. Services are all services provided by My Apartments, mainly services related to temporary accommodation or lease of dwelling.
1.10. Cookies are data files that are sometimes stored on the computer of a Visitor of a Website.
2. General provisions
2.1. OÜ My Apartments is a legal entity My Apartments, registry code 12807647, registered address Sakala 11, Tallinn 10141.
2.2. My Apartments may process Personal data as:
- 2.2.1. a controller, determining the purposes and means of the Processing of Personal data;
- 2.2.2. a recipient to whom Personal data are transferred.
3.1. My Apartments shall always consider the interests, rights and freedoms of Data subjects when processing Personal data.
3.2. The objective of My Apartments is to responsibly Process Personal data, which shall be based on the best practices with a view to always being ready to demonstrate compliance of the processing of Personal data with the established objectives.
3.3. All processes, instructions, operations and activities of My Apartments that are related to the processing of Personal data are based on the following principles:
- 3.3.1. Lawfulness. In the case of processing of Personal data, there is a legal basis for such activity, which is a contract concluded between the parties by which the Data subject consents to the processing of their Personal data;
- 3.3.2. Transparency. The processing of Personal data is transparent to the Data subject.
- 3.3.3. Purpose limitation. Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- 3.3.4. Accuracy. Personal data are accurate and, where necessary, kept up to date; also, every reasonable step has been taken to ensure that Personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified.
- 3.3.5. Storage limitation. Personal data are kept in a form which permits identification of Data subjects for no longer than is necessary for the purposes for which the Personal data are processed.
- 3.3.6. Integrity and confidentiality. Personal data are processed in a manner that ensures appropriate security of the Personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. My Apartments has internal regulations, guidelines for employees, as well as separate agreements with each processor which provide for best practices, continuous risk assessment and appropriate technical and organisational measures for the Processing of Personal data.
4. Categories of Personal data
4.1. My Apartments collects the following types of Personal data, among others:
- 4.1.1. Personal data disclosed to My Apartments by the Data subject (name, e-mail address, postal address, telephone number, birthday, personal identification code, etc.);
- 4.1.2. Personal data generated as a result of regular communication between the Data subject and My Apartments;
- 4.1.3. Personal data generated as a result of visiting and using the Website (e.g. time spent on the Website);
- 4.1.4. Personal data created and combined by My Apartments (correspondence related to the customer relationship or order history).
5. Categories and purposes and bases for the Processing of Personal data
5.1. My Apartments Processes Personal data exclusively on the basis of consent or law.
5.2. My Apartments shall only process Personal data on the basis of consent strictly within the limits, to the extent and for purposes set out in this policy. The Data subject hereby consents voluntarily, specifically, knowingly and unequivocally to the Processing of their Personal data by concluding a contract with My Apartments.
5.3. Legitimate interest means the interest of My Apartments in the management and administration of its business in order to provide the best possible services on the market. My Apartments shall only Process Personal data on the basis of law after a careful assessment has been carried out to establish that My Apartments has a legitimate interest that requires the Processing of Personal data and such processing is in conformity with the interests and rights of the Data subject. In particular, Personal data may be processed on the basis of a legitimate interest for the following purposes:
- 5.3.1. providing to the Client a service in the best manner and with high quality;
- 5.3.2. managing and analysing the Client base to improve the availability, assortment and quality of services;
- 5.3.3. identifiers and personal information collected during the use of Websites, mobile applications and other Services, whereby My Apartments uses such data for web or mobile and information society service analysis, ensuring its operation, improvement, compiling statistics, providing better and more individual Services;
- 5.3.4. protection of the rights of My Apartments with respect to the Client, which My Apartments may use to protect its legal rights;
- 5.3.5. fulfilment of its obligations under the applicable law;
5.4. My Apartments Processes Personal data to fulfil its obligations arising from law or apply the uses permitted by law. For example, legal obligations apply when processing payments or complying with money laundering prevention requirements.
5.5. If Personal data are processed for a new purpose than that for which the Personal data were originally collected or are not processed on the basis of the consent of the Data subject, My Apartments shall carefully assess the admissibility of such new Processing.
6. Disclosure and/or transfer of Personal data to third parties
6.1. My Apartments co-operates with persons to whom My Apartments may during and for the purposes of co-operation transfer data related to Data subjects, including Personal data.
6.2. Such third parties may be persons whose services My Apartments uses to provide accommodation services, advertising and marketing partners, customer satisfaction survey companies, debt collection service providers, credit status registers, IT partners, persons mediating or providing postal services, institutions and organisations, provided that:
- 6.2.1. the respective purpose and Processing are lawful;
- 6.2.2. Personal data are processed in accordance with instructions provided by My Apartments and on the basis of a valid agreement.
7. Security of the Processing of Personal data
7.1. My Apartments shall retain Personal data only for the minimum time period required. Personal data that are expired shall be destroyed using best practices and in accordance with the procedures established by My Apartments.
7.2. My Apartments has established regulations and rules of procedure on how to ensure the security of Personal data through the use of both organisational and technical measures.
7.3. In the event of any incidents related to Personal data, My Apartments shall take all necessary measures to mitigate the consequences and relevant risks in the future. Among other things, My Apartments shall register all incidents and, in the cases prescribed, notify the Estonian Data Protection Inspectorate and the Data subject directly.
7.4. The use of collected Personal data: the collected Personal data help us to inform customers about My Apartments product news and campaigns.
7.5. Your rights regarding the processing of Personal data: you have the right to receive information about the processing of your Personal data in the extent established in the Personal Data Protection Act and other legal acts. You have the right to demand that your Personal data are no longer processed or for said data to be rectified, blocked, erased or transferred.
8. Rights of the Data subject
8.1. The Data subject has the following rights in relation to the Processing of Personal data:
- 8.1.1. right to receive information about Personal data which have been collected concerning them;
- 8.1.2. right of access to data, including the right to obtain a copy of the Personal data undergoing processing;
- 8.1.3. right to obtain rectification of inaccurate Personal data;
- 8.1.4. right to erasure or in specific cases, the Data subject shall have the right to demand erasure of Personal data, for example, if the processing takes place only on the basis of consent;
- 8.1.5. right to demand restriction of Processing of Personal data – this right arises, among other things, if the Processing of Personal data is not permitted by law or if the Data subject disputes the accuracy of the Personal data, whereby the Data subject has the right to demand that the Processing of Personal data be limited for a period enabling the controller to verify the accuracy of the Personal data or if the Processing is unlawful but the Data subject opposes the erasure of the Personal data;
- 8.1.6. the right to an assessment by a supervisory authority as to whether the Processing of the Personal data of the Data subject is lawful.
9. Exercise of rights and submission of complaints
9.1. Exercise of rights:
- 9.1.1. the Data subject has the right to contact My Apartments via e-mail firstname.lastname@example.org in case of a question, request or complaint regarding the Processing of Personal data.
9.2. Submission of complaints:
- 9.2.1. the Data subject has the right to file a complaint with My Apartments, the Estonian Data Protection Inspectorate or court if the Data subject finds that their rights have been violated during the Processing of Personal data;
- 9.2.2. the contact details of the Estonian Data Protection Inspectorate are available on their website at https://www.aki.ee/et/teenused-poordumisvormid/nouandetelefon.
10. Cookies and other web technologies
10.1. My Apartments may collect and process data about Visitors of websites and other information society services by using Cookies (i.e. small pieces of information stored by the Visitor’s web browser on their computer or other device’s hard drive) or other similar technologies (e.g. IP-address, device information, location).
10.2. My Apartments uses the collected data to tailor their services to the preferences of a Visitor or Client, ensure the best service quality, inform the Visitor and Client about their content and make recommendations, personalise advertisements and improve marketing efforts, facilitate login and protection of data. The collected data will also be used to count Visitors and record their usage habits.
10.3. With regard to Cookies, Visitors agree to their use on the Website, in the settings of the Information society services or in their web browser.
10.4. Most web browsers allow Cookies. Without fully enabling Cookies, the functions of the Website will not be available to the Visitor. The Visitor can enable or disable Cookies and other similar technologies via their web browser settings, information society service settings and privacy enhancing platforms.
11. Contact details and information
11.1. Contact details relevant to the Data subject of My Apartments:
- 11.1.1. in matters regarding the Processing of Personal data, My Apartments can be contacted via e-mail email@example.com.
12. Other terms