Privacy and Cookies Policy

Index

1. Introduction

1.1 Purpose of the Privacy Policy

At Victuria we are committed to protecting the privacy and personal data of our users. This Privacy Policy describes how we collect, use, store and protect your personal data when you visit our website and use our services.

1.2 Definition of Key Terms

Personal Data: Any information relating to an identified or identifiable natural person, such as name, address, email, telephone number, etc.
Data Processing: Any operation performed on personal data, such as collection, storage, use, disclosure, deletion, etc.
Data Controller: The entity that determines the purposes and means of processing personal data.
Data Processor: The entity that processes personal data on behalf of the data controller.

2. Data Controller

2.1 Information about the Data Controller

Company: Victuria OÜ
Registration code: 14866967
VAT Number: EE102218648
Sepapaja 6, 15551, Tallinn, Estonia.
Email: [email protected]

2.2 Contact Information

If you have any questions about this Privacy Policy or how we handle your personal data, you may contact us using the contact information provided above.

3. Personal Data Collected

3.2 Data Collection Methods

We collect personal data through various methods, including:

Contact Form: When users complete contact forms on our website.
Registration Process: When users register to create an account or subscribe to our services.
Transactions: When users make purchases or contract our services.
Web Browsing: Through the use of cookies and other tracking technologies as users navigate our website.
Direct Communications: Through emails, phone calls or any other form of direct communication with our users.

4. Purpose of Data Processing

4.1 Description of Specific Purposes

We collect and process your personal data for the following purposes:

Provision of Services: To manage and provide the services you have requested from us, such as web design, maintenance and hosting.
Payment Management: To process payments for our services, including invoice management and fraud prevention.
Communication: To communicate with you, answer your questions and provide you with technical support.
Marketing: To send you information about our products and services, promotions, and news that may be of interest to you, provided that we have your consent to do so.
Website Improvement: To analyze the use of our website and improve our services and user experience.
Legal Compliance: To comply with our legal obligations, such as retaining data for tax and accounting purposes.

4.2 Legal Basis for Data Processing

We process your personal data on the following legal bases:

Performance of a Contract: Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
Consent: You have given your consent to the processing of your personal data for one or more specific purposes.
Legitimate Interests: Processing is necessary for the purposes of the legitimate interests pursued by us, provided such interests do not override your fundamental rights and freedoms.
Compliance with Legal Obligations: Processing is necessary to comply with a legal obligation to which we are subject.

5. Consent

5.1 Obtaining Consent

Consent Process: We request your clear and specific consent for the processing of your personal data when you register on our website, complete a contact form or subscribe to our services.
Free and Voluntary Consent: Consent is given freely and voluntarily, without any coercion, and may be withdrawn at any time.

5.2 Withdrawal of Consent

Right to Withdraw Consent: You have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent prior to its withdrawal.
Procedure for Withdrawing Consent: To withdraw your consent, you may contact us at [email protected]. Once we receive your withdrawal of consent, we will stop processing your personal data for the purposes specified.

5.3 Rights Related to Consent

User Rights: You have additional rights related to consent, including the right to access, rectify, and delete your personal data. These rights are described in more detail in the “User Rights” section.

6. Use of Collected Data

6.1 How Personal Data is Used

Provision of Services: We use your personal data to manage your account and provide the requested services.
Customer Relationship Management: We use your data to communicate with you, respond to your inquiries, and provide you with technical support.
Marketing and Promotions: With your consent, we use your data to send you newsletters, promotions and other marketing communications.
Website and Service Improvement: We analyze website navigation and usage data to improve our services and user experience.
Legal Compliance: We use your data to comply with our legal and regulatory obligations.

6.2 Automated Processing and Profiling

Automated Processing: In some cases, we use automated processing to analyze data and make decisions related to the use of our website and services.
Profiling: We may create profiles based on your interactions with our website and services to provide you with a more personalized and relevant experience. You have the right to object to profiling by contacting us at [email protected].

7. Data Sharing and Disclosure

7.1 Third Parties With Whom We Share Data

We share your personal data with third parties only in the following circumstances:

Service Providers: We share data with service providers who help us operate our website, provide our services, and process payments. These providers are contractually obligated to protect your personal data and use it only as instructed by us.
Business Partners: We share data with business partners when necessary to provide the services you have requested or to enable the integration of third-party services.
Legal Authorities: We disclose personal data to government and regulatory authorities when we are legally required to do so, for example, in response to a court order or to comply with applicable laws.
Business Transfer: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the buyer.

7.2 International Data Transfers

Location of Third Parties: Some of the third parties with whom we share your personal data may be located outside the European Economic Area (EEA).
Appropriate Safeguards: When we transfer your personal data outside the EEA, we ensure that appropriate safeguards are in place to protect your data, such as standard contractual clauses approved by the European Commission or adequacy decisions.

8. Data Conservation

8.1 Data Retention Periods

Retention Duration: We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
Retention Criteria: The criteria used to determine our retention periods include the length of our relationship with you, legal retention requirements, and our business needs to operate and improve our services.

8.2 Data Deletion

Deletion Procedure: Once personal data is no longer necessary for the purposes for which it was collected, we delete it securely and in accordance with our internal policies and applicable laws.

9. User Rights

9.1 Rights of Access, Rectification and Deletion of Data

Right of Access: You have the right to request access to the personal data we hold about you. You can request a copy of your personal data by contacting us at [email protected].
Right to Rectification: You have the right to request the correction of any inaccurate or incomplete personal data.
Right to Deletion: You have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, among other circumstances.

9.2 Right to Data Portability

Portability Request: You have the right to receive your personal data in a structured, commonly used and machine-readable format, and to transmit that data to another data controller without hindrance from us, when the processing is based on your consent or a contract, and is carried out by automated means.

9.3 Right to Limitation of Processing

Request for Restriction: You have the right to request that we restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data while we verify the accuracy of the data, or where the processing is unlawful and you oppose the deletion of the data and request instead that we restrict its use.

9.4 Right to Object to Processing

Objection to Processing: You have the right to object to the processing of your personal data where such processing is based on our legitimate interests. We will stop processing the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

9.5 Right to File a Complaint

Complaints to the Supervisory Authority: You have the right to lodge a complaint with the competent supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of your personal data infringes the GDPR.

9.6 Exercise of Rights

How to Exercise Your Rights: To exercise any of your rights, you may contact us at [email protected]. We will respond to your request in accordance with applicable laws.

10. Security Measures

10.1 Description of the Security Measures Implemented

Technical Measures: We implement a variety of technical security measures to protect your personal data against unauthorized access, alteration, disclosure or destruction. These measures include, but are not limited to, encryption, firewalls, and intrusion detection systems.
Organizational Measures: We limit access to your personal data to those employees, contractors and agents who need to know it in order to operate, develop or improve our services. These individuals are subject to confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

11. Cookies and Similar Technologies

11.1 Use of Cookies on the Website

Definition of Cookies: Cookies are small text files that are stored on your device when you visit a website. We use cookies to improve your browsing experience and to collect information about how you use our website.
Types of Cookies Used:
Essential Cookies: These cookies are necessary for the website to function properly and cannot be disabled in our systems.
Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our website.
Functionality Cookies: These cookies enable the website to provide enhanced functionality and personalization.
Advertising Cookies: These cookies may be set through our site by our advertising partners to build a profile of your interests and show you relevant adverts on other sites.

11.2 How to Manage Cookie Preferences

Browser Settings: You can set your browser to block or alert you about these cookies, but some parts of the website may not work properly.
Cookie Consent Tools: On our website, we provide tools for users to manage their cookie preferences. You can change your preferences at any time by accessing the cookie settings available on our website.

12. Links to Third Party Websites

12.1 Policy Regarding External Links

Links to Other Sites: Our website may contain links to other websites that are not operated by us. We have no control over the content and privacy practices of these sites, and cannot accept responsibility for their respective policies.
Review Recommendation: We recommend that you review the privacy policy of every website you visit before providing any personal data.

12.2 Responsibility for Third Party Content

Disclaimer: We are not responsible for the content, privacy policies, or practices of third party websites. The inclusion of any link does not imply our approval or endorsement of the linked website.

13. Privacy Policy Updates

13.1 Policy Update Process

Modification of the Policy: We reserve the right to update or modify this Privacy Policy at any time. Any significant changes in the way we treat your personal data will be notified to you by a prominent notice on our website or via email.
Effective Date: The date this policy was last modified will be indicated at the top of the document. We encourage you to periodically review this page to stay informed of any changes.

13.2 Notification of Changes to Users

Notification of Changes: If we make material changes to our privacy policy, we will notify you by email (sent to the email address specified in your account) or by means of a notice on our home page prior to the change becoming effective.

14. Contact Information

14.1 How to Contact Us for Privacy-Related Issues

Contact Address: If you have any questions about this Privacy Policy or our data protection practices, you can contact us at the email: [email protected]

14.2 Procedure for Exercising Data Protection Rights

Rights Request: To exercise your data protection rights (such as access, rectification, deletion, etc.), please email us at [email protected] with your specific request and the information necessary to verify your identity.
Responding to Requests: We will respond to your requests in accordance with applicable law and within the timeframes set forth in the GDPR.