1. General
1.1. The Data Use Policy (the ‘Policy’) applies to https://kingitus.teamspirit.ee and any person who joins the Loyalty Programme of https://kingitus.teamspirit.ee.
1.2. The Policy determines how https://kingitus.teamspirit.ee may use Client Data in connection with the provision of offers to the Client and provide information on important issues related to the use of the Data.
1.3. The Policy is an integral part of the Loyalty Programme. https://kingitus.teamspirit.ee refers to the Policy when entering into a Loyalty Programme Agreement with a Client and allows the Client to examine the Policy. The Policy is a part of the Agreement and https://kingitus.teamspirit.ee has the right to assume that the Client is aware of the Policy.
2. Definitions
2.1. Client – any person who joins the Loyalty Programme of https://kingitus.teamspirit.ee.
2.2. Data – personal data of the Client or other data related to the Client that has become known to https://kingitus.teamspirit.ee in connection with joining the loyalty programme.
2.3. Anonymous data – information that is not attributable to a specific Client because the information identifying the Client has been removed from the data.
3. https://kingitus.teamspirit.ee Data Protection Policy
3.1. https://kingitus.teamspirit.ee uses the Data in the manner set out in the Policy and only for the purpose for which https://kingitus.teamspirit.ee collected the Data and to the extent necessary to fulfil this purpose. https://kingitus.teamspirit.ee shall use the Data in accordance with the Personal Data Protection Act and other Acts (hereinafter: Legislation) and good business practices.
3.2. https://kingitus.teamspirit.ee considers the Client’s privacy and the protection of the Data to be very important, using the organisational, physical, and information technology security measures necessary to ensure the integrity, availability, and confidentiality of the Data. These measures include the protection of staff, information, IT infrastructure, internal and public networks, as well as office buildings and technical equipment. The aim of security activities is to implement an appropriate level of information protection, mitigate risks, and prevent threats.
3.3. The employees of https://kingitus.teamspirit.ee are subject to data confidentiality and protection requirements and are responsible for compliance with these obligations.The authorised data processors at https://kingitus.teamspirit.ee are obliged to ensure compliance with the same rules with regard to their employees and are responsible for compliance with the requirements for the use of the Data.
4. Data collection
4.1. https://kingitus.teamspirit.ee offers Clients a Loyalty Programme and offers related to the programme.The composition of the Data collected by https://kingitus.teamspirit.ee about the Client therefore depends on which specific parts of the Loyalty Programme are used, which Data need to be used to provide them, to what extent the Client transmits Data to https://kingitus.teamspirit.ee for this purpose, and what consents the Client gives to https://kingitus.teamspirit.ee for the processing of Data.
4.2. https://kingitus.teamspirit.ee collects Data in the following ways:
4.3. https://kingitus.teamspirit.ee receives Data from the Client when the Client joins the Loyalty Programme, subscribes to the newsletter, etc.
4.4. Data is generated by the Client’s use of the Loyalty Programme and is necessary for the performance of the loyalty programme; the basis for processing Data is the Client’s consent.
5. Use of Data to ensure the provision of the Loyalty Programme
5.1. To identify the Client.
5.2. To provide the Client with the benefits of the Loyalty Programme or carry out activities necessary for the sale of goods (including the sale and delivery of the Services and/or goods and the provision of information on the Services and goods to the Client).
5.3. To better serve Clients, measure user activity or customer satisfaction, and develop Services and business activities.
6. Use of Data for marketing purposes
6.1. The use of Data for marketing purposes means that https://kingitus.teamspirit.ee uses Data:
6.1.1. For the marketing analysis of the Client’s Loyalty Programme and other usage preferences, with the aim of identifying the Client’s usage needs and compiling personal offers on the basis thereof (hereinafter: Marketing Use of Data) and.
6.1.2. To send personal offers to the Client by electronic means (e.g. e-mail, SMS or MMS).
6.2. The Client has given, or can give, consent to https://kingitus.teamspirit.ee to use the Data for marketing purposes and to receive personal offers (hereinafter: ‘Consent’) by joining the loyalty programme and filling in the Client’s Form or by making a declaration of intent confirming the Client’s Consent in any other way (e.g. confirmation by e-mail, etc.).
6.3. Consent is subject to the terms and conditions for the use of Data set out in the Policy. https://kingitus.teamspirit.ee refers to the Principles when obtaining the Client’s Consent, and the Client can review the Policy. The Client has the right not to give Consent or to withdraw Consent later by notifying https://kingitus.teamspirit.ee by e-mail. Consent is valid until it is withdrawn or until the expiry of the agreement(s) entered into with the Client.
6.4. With the Client’s Consent, https://kingitus.teamspirit.ee uses the data for marketing purposes as follows:
6.4.1. To identify the Client’s expectations, preferences, and needs.
6.4.2. To develop personal direct marketing, promotional and campaign offers for the Client to purchase goods.
6.4.3. To send the Client personal direct marketing, promotional and campaign offers about the goods electronically.
6.4.4. To forward data to companies belonging to the same group as https://kingitus.teamspirit.ee for the purpose of making special offers to the Client jointly or reciprocally.
6.5. https://kingitus.teamspirit.ee may use the following Data and information for marketing purposes on the basis of Consent:
6.5.1. Client’s name, date of birth, personal identification code, language of communication, preferred contact details (e.g. e-mail, regular mail, etc.), postal address, e-mail address, mobile phone number, phone number, and location data.
6.5.2. Information on the Client’s segment.
6.5.3. Information concerning the purchase of goods (e.g. area of goods, price class, delivery information, etc.).
6.5.4. Data disclosed about the Client in public databases or on the Internet (e.g. information about the Client’s interests, work or studies, etc.).
7. Sending personal offers by electronic means
7.1. The Client has the right at any time, regardless of the Client’s Consent to the marketing use of their Data (see clause 6.2), to prohibit the sending of offers to them by electronic means (e.g. e-mail, SMS or MMS) by sending a corresponding e-mail to the contact details provided below.
8. Use of data by data processors
8.1. The data controller is Fifaa AS (https://kingitus.teamspirit.ee), registry code 10222434, address Pärnu mnt 144, 11317 Tallinn.
8.2. Based on legislation, https://kingitus.teamspirit.ee may also grant data processors the right to use the Data. Data processors are the partners of https://kingitus.teamspirit.ee, who are engaged, for example, in the electronic transmission of marketing offers. The data processor has the right to use the Data only for the performance of specific operations requested by https://kingitus.teamspirit.ee and on the basis of a confidentiality agreement concluded with https://kingitus.teamspirit.ee for this purpose. For example, Sendsmaily OÜ uses the Client’s name and e-mail address to send marketing offers and newsletters to the Client on the basis of such agreement.
8.3. The data processors of personal data are AS Maksekeskus, Sendsmaily OÜ and Outvio OÜ.
8.4. The list and contact details of the data processors of https://kingitus.teamspirit.ee are available on the homepage.
9. Client’s rights in relation to the use of Data
9.1. In relation to the processing of their Data, the Client has the right to:
9.1.1. Receive information from https://kingitus.teamspirit.ee about their Data and the use of the Data in accordance with the procedure and to the extent provided by legislation.
9.1.2. Request https://kingitus.teamspirit.ee to terminate the use of the Data in the cases provided by legislation and to rectify, block, and delete the Data.
9.1.3. Consent or object to the use of their Data for direct marketing or promotion purposes as set out in the Policy.
9.1.4. Contact the Data Protection Inspectorate and the court if their rights are violated.
9.1.5. To claim compensation for direct proprietary damage caused as a result of the violation of their rights on the bases and pursuant to the procedure provided for in the Law of Obligations Act.
10. How to contact https://kingitus.teamspirit.ee
10.1. The Client can contact https://kingitus.teamspirit.ee via e-mail, in matters concerning the Policy or the processing of the Client’s Data, at info@fifaa.ee.