Kodasema Privacy Policy
Introduction
(A) We are Kodasema OÜ and we respect your privacy. We process as little of your personal data as possible, and when we do it, we do it either with your consent, on the basis of our legitimate interests, or in order to comply with a legal obligation to which we are subject.
(B) In this Privacy Policy, you’ll find important information about what personal data we process, and how and why we do it; which rights you have as a data subject; and how you can exercise these rights or find more information.
(C) This Privacy Policy also gives you information about what are cookies, how we use them and how you can control them.
The Policy:
Who we are and how to reach us
We are Kodasema OÜ, an Estonian private limited company with registry code 12494697 and registered address at Lauteri 5, 10114 Tallinn, Estonia.
If you need more information about how we process and protect your personal data, write to privacy@kodasema.com. We shall respond to such requests as soon as possible and in any case within one month of the receipt of your request.
What, how and why we process
Processing with your consent
If you subscribe to our newsletters, we’ll ask your email address. This address will only be used for emailing the newsletters to you. You may unsubscribe at any time by following the instructions at the end of each newsletter, and when you do, we’ll remove your email address from our database.
If you request our price list or other product information, we’ll ask your email address, and, optionally, your name. Since the prices of our products and services may differ from region to region, we may also ask the location where you’d like your KODA to be installed (note that this is not necessarily your home location, so, strictly speaking, that’s not personal data). We may also ask about the KODA model and number of KODAs that you are interested in. We’ll use this data to send you relevant information about price changes or new products and services becoming available in your desired location, and we’ll keep it until you tell us to forget about you.
Processing for the purpose of preparation or performance of a contract, or to comply with a legal obligation
When you place an order for our products or services or make a payment to us, we’ll process your personal data recorded on the order form or payment notification. We’ll keep this information as long as necessary for the preparation or performance of the contract (including any possible warranty or other post-sales obligations). We’ll also use this data from time to time to remind you of product maintenance schedules or provide other relevant non-commercial information to you.
We’ll also retain our transaction records for as long as the applicable accounting laws and regulations require us to do.
Processing on the basis of our legitimate interest
As a private company willing to stay in business and make profit, it is our legitimate interest to market our products and services. So if you have done business with us in the past, we may use, from time to time, your contact information obtained from your order forms, to send you information about relevant new products and services becoming available in the location where your KODA has been installed. You may opt out of such communications at any time, and when you do, we’ll no longer use any of this data for such purposes.
In addition, we may use data from cookies and trackers for our marketing efforts.
Please note that if we use legitimate interest, we have assessed yours and our interest. You have the right to view the assessment if the processing is commenced in connection to you. If you need more information about such processing contact us at privacy@kodasema.com.
Please note we use social media platforms, communication infrastructures and storage spaces which are governed by the privacy policies of their respective service providers. Various third party channels also process your personal information in accordance with the privacy policies of those platforms.
We process personal data clearly disclosed by the data subject on our social media e.g., on YouTube.
We process personal data created from regular communications us and the data subject e.g., via Skype.
Cookies
What are cookies?
Cookies are small pieces of data that a website and stores on your computer or mobile device when you visit the site. There are several kinds of cookies: first-party cookies are set and read by the website you’re visiting; third-party cookies are set and can be read by external services used by the website; session cookies shall be deleted when you exit your web browser; persistent cookies shall be retained for future use.
Some cookies are necessary for the website to function as intended (e.g. online shops use them to keep track of the products in your virtual shopping basket); other cookies allow the websites to remember your preferences (such as your preferred content language) so that you don’t have to keep re-entering them when browsing around the site; to gather statistics about website usage (e.g. track down the paths how users navigate through the site), or to allow advertising service providers to show the ads expected to best match each user’s interests.
While the use of cookies allows websites to improve the user experience, the same technology, when used maliciously or incompetently, may put the users’ privacy at risk. The European privacy laws state that website operators can only place cookies (other than strictly necessary functionality cookies) on users’ computers or mobile devices only with the users’ consent.
How do we use cookies?
| name | purpose | type and duration |
| CONSENT | storing the user’s cookie consent | first-party, persistent, 1 year |
| pll_language | storing the user’s language preference | first-party, persistent, 1 year |
| _ga* | analysing site usage so that we could improve its performance | first-party, persistent, between 1 minute and 2 years |
No cookies are stored on your device until you accept the cookies.
How you can control cookies?
Most modern browsers allow you to delete the cookies already on your device, and to prevent websites from placing new cookies. You can also manage your cookie preferences on per-site basis.
For more details about how to do that, consult your browser’s user guide or visit https://aboutcookies.org.
Your rights and how to exercise them
If you are a natural person residing in the European Economic Area, then your rights as a data subject are provided for in the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (GDPR). If you are a resident of some other country, you may have additional or different rights.
Under the GDPR, you have the rights to request from us access to and rectification or erasure of your personal data or restriction of processing your data or to object to processing your data, as well as the right to data portability. To exercise these rights, contact us as set forth above.
Under the GDPR, you also have the right to lodge a complaint with a supervisory authority, that is the Estonian Data Protection Inspectorate. Further information and contact details are available from https://aki.ee.