1. General Provisions
1.1. This privacy policy regulates the principles of collecting, processing, and storing personal data. Personal data is collected, processed, and stored by the data controller, 92 Layers OÜ (hereinafter referred to as the data controller).
1.2. In the context of this privacy policy, a data subject is a client or any other natural person whose personal data is processed by the data controller.
1.3. In the context of this privacy policy, a client is anyone who purchases goods or services from the data controller’s website.
1.4. The data controller follows the principles of data processing established by legislation, including processing personal data legally, fairly, and securely. The data controller can confirm that personal data has been processed in accordance with the provisions set out in legislation.
2. Collection, Processing, and Storage of Personal Data
2.1. Personal data collected, processed, and stored by the data controller is primarily collected electronically, mainly via the website and email.
2.2. By sharing their personal data, the data subject grants the data controller the right to collect, organise, use, and manage the personal data shared directly or indirectly by the data subject when purchasing goods or services on the website, for the purposes defined in the privacy policy.
2.3. The data subject is responsible for ensuring that the data they provide is accurate, correct, and complete. Knowingly providing false data is considered a breach of the privacy policy. The data subject is obliged to notify the data controller immediately of any changes to the data provided.
2.4. The data controller is not responsible for any damage caused to the data subject or third parties due to the provision of false data by the data subject.
3. Processing of Client Personal Data
3.1. The data controller may process the following personal data of the data subject:
3.1.1. First and last name;
3.1.2. Date of birth;
3.1.3. Telephone number;
3.1.4. Email address;
3.1.5. Delivery address;
3.1.6. Billing address;
3.1.7. Bank account number;
3.1.8. Payment card details.
3.2. In addition to the above, the data controller has the right to collect data about the client from public registers.
3.3. The legal basis for processing personal data is set out in Article 6(1)(a), (b), (c), and (f) of the General Data Protection Regulation (GDPR):
a) The data subject has given consent to the processing of their personal data for one or more specific purposes;
b) Processing of personal data is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;
c) Processing of personal data is necessary for compliance with a legal obligation to which the data controller is subject;
f) Processing of personal data is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, especially where the data subject is a child.
3.4. Processing of personal data according to the purpose of processing:
3.4.1. Processing purpose – security and safety
Maximum retention period – according to statutory deadlines
3.4.2. Processing purpose – order processing
Maximum retention period – 3 months
3.4.3. Processing purpose – ensuring the operation of e-shop services
Maximum retention period – 1 year
3.4.4. Processing purpose – customer management
Maximum retention period – 5 years
3.4.5. Processing purpose – financial activities, accounting
Maximum retention period – according to statutory deadlines
3.4.6. Processing purpose – marketing
Maximum retention period – 1 year
3.5. The data controller has the right to share clients’ personal data with third parties, such as authorised data processors, accountants, transport and courier companies, and payment service providers. The data controller is the responsible processor of personal data. The data controller will transfer personal data necessary for processing payments to the authorised processor, Maksekeskus AS.
3.6. When processing and storing the personal data of data subjects, the data controller implements organisational and technical measures to protect personal data from accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.
3.7. The data controller retains data subjects’ data depending on the purpose of processing, but no longer than 5 years.
4. Rights of the Data Subject
4.1. The data subject has the right to access and review their personal data.
4.2. The data subject has the right to obtain information regarding the processing of their personal data.
4.3. The data subject has the right to supplement or correct inaccurate data.
4.4. If the data controller processes the data subject’s personal data based on the data subject’s consent, the data subject has the right to withdraw their consent at any time.
4.5. The data subject can exercise their rights by contacting e-shop customer support at hello@92layers.com.
4.6. The data subject also has the right to file a complaint with the Data Protection Inspectorate to protect their rights.
5. Final Provisions
5.1. These data protection terms have been prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation), the Personal Data Protection Act of the Republic of Estonia, and the legislation of the Republic of Estonia and the European Union.
5.2. The data controller has the right to partially or fully amend the data protection terms by notifying the data subjects of the changes via the website 92layers.ee.