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Privacy Policy
We are very pleased about your interest in our company. Data protection is of a particularly high priority for the management of Kewee OÜ. The use of the website of Kewee OÜ is generally possible without providing any personal data. However, if a data subject wishes to use special services of our company via our website, the processing of personal data may become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, email address, or telephone number of a data subject, shall always be in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations applicable to Kewee OÜ. By means of this privacy policy, our company wishes to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed of their rights by means of this privacy policy.
As the data controller, Kewee OÜ has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. However, internet-based data transmissions may in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.
1. Definitions
The privacy policy of Kewee OÜ is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
We use the following terms, among others, in this privacy policy:
a) Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
b) Data subject
A data subject is any identified or identifiable natural person whose personal data is processed by the data controller.
c) Processing
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.
f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Data controller
The data controller is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Data processor
A data processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the data controller.
i) Recipient
A recipient is a natural or legal person, public authority, agency, or other body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
j) Third party
A third party is a natural or legal person, public authority, agency, or body other than the data subject, data controller, data processor, and persons who, under the direct authority of the data controller or data processor, are authorised to process personal data.
k) Consent
Consent of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and address of the data controller
The data controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in Member States of the European Union, and other provisions of a data protection nature is:
Kewee OÜ
Tartu mnt 67/1-13b
10115 Talinn
Estonia
Email: info@kewee.co
3. Cookies
The website of Kewee OÜ uses cookies. Cookies are text files that are stored on a computer system via an internet browser.
Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This allows visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognised and identified using the unique cookie ID.
Through the use of cookies, Kewee OÜ can provide users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimised in the interest of the user. Cookies allow us, as previously mentioned, to recognise users of our website. The purpose of this recognition is to make it easier for users to utilise our website. For example, a user of a website that uses cookies does not have to re-enter their access credentials each time they visit the website, because this is handled by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping cart in an online store. The online store remembers the items that a customer has placed in the virtual shopping cart via a cookie.
The data subject may prevent the setting of cookies through our website at any time by means of a corresponding setting in the internet browser used, and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set may be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.
4. Collection of general data and information
The website of Kewee OÜ collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-pages accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using this general data and information, Kewee OÜ does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website and the advertising for it, (3) ensure the continued functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber-attack. Therefore, Kewee OÜ analyses this anonymously collected data and information statistically, with the aim of increasing data protection and data security in our company, in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files is stored separately from all personal data provided by a data subject.
5. Registration on our website
The data subject has the possibility to register on the website of the data controller by providing personal data. Which personal data is transmitted to the data controller is determined by the respective input form used for the registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the data controller and for its own purposes. The data controller may arrange for the transfer to one or more data processors, for example a parcel service provider, who will also use the personal data exclusively for internal purposes attributable to the data controller.
By registering on the website of the data controller, the IP address assigned by the Internet service provider (ISP) of the data subject, the date, and the time of registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate crimes that have been committed. In this respect, the storage of this data is necessary to protect the data controller. This data is not passed on to third parties unless there is a legal obligation to do so or the transfer serves the purpose of criminal prosecution.
The registration of the data subject, with the voluntary provision of personal data, serves the data controller to offer the data subject content or services that, due to the nature of the matter, can only be offered to registered users. Registered persons are free to modify the personal data provided during registration at any time or to have it completely deleted from the data stock of the data controller.
The data controller shall, at any time, provide information upon request to each data subject as to what personal data is stored about them. Furthermore, the data controller shall rectify or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations to the contrary. All employees of the data controller are available to the data subject in this context as contact persons.
6. Subscription to our newsletter
On the website of Kewee OÜ, users are given the opportunity to subscribe to the newsletter of our company. Which personal data is transmitted to the data controller when ordering the newsletter is determined by the input form used for this purpose.
Kewee OÜ informs its customers and business partners at regular intervals by means of a newsletter about company offers. The newsletter of our company can generally only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter. A confirmation email will be sent to the email address registered by a data subject for the first time for newsletter delivery, for legal reasons, using the double opt-in procedure. This confirmation email is used to verify whether the owner of the email address, as the data subject, has authorised the receipt of the newsletter.
When subscribing to the newsletter, we also store the IP address assigned by the Internet service provider (ISP) of the computer system used by the data subject at the time of subscription, as well as the date and time of subscription. The collection of this data is necessary in order to be able to trace the (possible) misuse of the email address of a data subject at a later date, and therefore serves the purpose of the legal protection of the data controller.
The personal data collected as part of a registration for the newsletter will be used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter may be informed by email, insofar as this is necessary for the operation of the newsletter service or a registration in question, as could be the case in the event of changes to the newsletter offer or changes in the technical circumstances. The personal data collected as part of the newsletter service will not be passed on to third parties. The subscription to our newsletter may be cancelled by the data subject at any time. The consent to the storage of personal data, which the data subject has given for the newsletter, may be revoked at any time. For the purpose of revoking consent, a corresponding link is provided in each newsletter. Furthermore, it is also possible to unsubscribe from the newsletter at any time directly on the website of the data controller or to communicate this to the data controller in another way.
7. Newsletter tracking
The newsletters of Kewee OÜ contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in emails sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns to be carried out. Based on the embedded tracking pixel, Kewee OÜ can detect whether and when an email was opened by a data subject and which links in the email were called up by the data subject.
Such personal data collected through the tracking pixels contained in the newsletters is stored and analysed by the data controller in order to optimise the newsletter delivery and to better adapt the content of future newsletters to the interests of the data subject. This personal data will not be passed on to third parties. Data subjects are entitled at any time to revoke the respective separate consent given via the double opt-in procedure. After a revocation, this personal data will be deleted by the data controller. Kewee OÜ automatically regards an unsubscription from the receipt of the newsletter as a revocation.
8. Contact possibility via the website
The website of Kewee OÜ contains information that enables quick electronic contact with our company, as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address), due to legal requirements. If a data subject contacts the data controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller is stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
9. Subscription to comments in the blog on the website
The comments made in the blog of Kewee OÜ may generally be subscribed to by third parties. In particular, there is the possibility that a commentator subscribes to the comments following their comment on a particular blog post.
If a data subject decides to subscribe to comments, the data controller will send an automatic confirmation email to verify, using the double opt-in procedure, that the owner of the specified email address has actually opted for this option. The option to subscribe to comments can be terminated at any time.
10. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is provided for by the European legislator or other legislators in laws or regulations to which the data controller is subject.
If the storage purpose is no longer applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with legal requirements.
11. Rights of the data subject
a) Right to confirmation
Each data subject shall have the right, granted by the European legislator, to obtain from the data controller confirmation as to whether or not personal data concerning him or her is being processed. If a data subject wishes to exercise this right of confirmation, he or she may, at any time, contact any employee of the data controller.
b) Right of access
Each data subject affected by the processing of personal data shall have the right, granted by the European legislator, to obtain from the data controller, free of charge, information about the personal data stored about him or her, and a copy of this information, at any time.
c) Right to rectification
Each data subject affected by the processing of personal data shall have the right, granted by the European legislator, to obtain the rectification of inaccurate personal data concerning him or her without undue delay.
d) Right to erasure (right to be forgotten)
Each data subject affected by the processing of personal data shall have the right, granted by the European legislator, to obtain from the data controller the erasure of personal data concerning him or her without undue delay, where one of the legal grounds applies and insofar as the processing is not necessary.
e) Right to restriction of processing
Each data subject affected by the processing of personal data shall have the right, granted by the European legislator, to obtain from the data controller restriction of processing where one of the legal conditions is met.
f) Right to data portability
Each data subject affected by the processing of personal data shall have the right, granted by the European legislator, to receive the personal data concerning him or her, which was provided to a data controller, in a structured, commonly used, and machine-readable format.
g) Right to object
Each data subject affected by the processing of personal data shall have the right, granted by the European legislator, to object, on grounds relating to his or her particular situation, at any time, to the processing of personal data concerning him or her.
h) Automated individual decision-making, including profiling
Each data subject affected by the processing of personal data shall have the right, granted by the European legislator, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
i) Right to withdraw consent under data protection law
Each data subject affected by the processing of personal data shall have the right, granted by the European legislator, to withdraw consent to the processing of personal data at any time.
12. Data protection for applications and the application procedure
The data controller collects and processes the personal data of applicants for the purpose of handling the application procedure. The processing may also be carried out electronically. This is particularly the case if an applicant submits the corresponding application documents to the data controller by electronic means, for example by email or via a web form on the website. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the data controller, the application documents shall be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the data controller are opposed to such deletion.
13. Privacy provisions on the use and application of Facebook
The data controller has integrated components of Facebook on this website. Facebook is a social network.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. The controller responsible for the processing of personal data, if a data subject lives outside of the USA or Canada, is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
The data policy published by Facebook, which is available at https://de-de.facebook.com/about/privacy/, provides information about the collection, processing, and use of personal data by Facebook.
14. Privacy provisions on the use and application of Google AdSense
The data controller has integrated Google AdSense on this website. Google AdSense is an online service that enables the placement of advertising on third-party sites.
The operating company of the Google AdSense component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
15. Privacy provisions on the use and application of Google Analytics (with anonymisation function)
The data controller has integrated the Google Analytics component (with anonymisation function) on this website. Google Analytics is a web analytics service.
The operating company of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
Further information and the applicable privacy provisions of Google may be retrieved under https://www.google.de/intl/de/policies/privacy/ and under http://www.google.com/analytics/terms/de.html.
16. Privacy provisions on the use and application of Google Remarketing
The data controller has integrated Google Remarketing services on this website. Google Remarketing is a feature of Google AdWords that allows a company to display advertising to internet users who have previously visited the company's website.
The operating company of the Google Remarketing services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
17. Privacy provisions on the use and application of Google AdWords
The data controller has integrated Google AdWords on this website. Google AdWords is an internet advertising service that allows advertisers to place ads both in Google's search engine results and in the Google advertising network.
The operating company of the Google AdWords services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
18. Privacy provisions on the use and application of Instagram
The data controller has integrated components of the Instagram service on this website. Instagram is a service that qualifies as an audiovisual platform, allowing users to share photos and videos, as well as disseminate such data in other social networks.
The operating company of the Instagram services is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland.
19. Privacy provisions on the use and application of LinkedIn
The data controller has integrated components of the LinkedIn Corporation on this website. LinkedIn is an internet-based social network that enables users to connect with existing business contacts and to make new business contacts.
The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, USA.
20. Privacy provisions on the use and application of Twitter
The data controller has integrated components of Twitter on this website. Twitter is a multilingual, publicly accessible microblogging service.
The operating company of Twitter is Twitter International Company, One Cumberland Place, Fenian Street Dublin 2, D02 AX07, Ireland.
21. Privacy provisions on the use and application of YouTube
The data controller has integrated components of YouTube on this website. YouTube is an internet video portal that enables video publishers to upload video clips free of charge and other users to view, rate, and comment on them, also free of charge.
The operating company of YouTube is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
22. Payment method: Privacy provisions for PayPal as a payment method
The data controller has integrated components of PayPal on this website. PayPal is an online payment service provider.
The European operating company of PayPal is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg.
The applicable privacy provisions of PayPal may be retrieved under https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
23. Payment method: Privacy provisions for Sofort (instant bank transfer) as a payment method
The data controller has integrated components of Sofort (instant bank transfer) on this website. Sofort is a payment service that enables cashless payment of products and services on the internet.
The operating company of Sofort is Klarna Bank AB, Sveavägen 46, 111 34 Stockholm, Sweden.
24. Legal basis for the processing
Art. 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, the processing is based on Art. 6(1)(b) GDPR.
25. Legitimate interests in the processing pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities in favour of the well-being of all our employees and our shareholders.
26. Period for which the personal data will be stored
The criterion for the duration of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, provided that it is no longer necessary for the fulfilment or initiation of a contract.
27. Legal or contractual requirements for the provision of personal data
We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary for a data subject to provide us with personal data that must subsequently be processed by us in order to conclude a contract.
28. Existence of automated decision-making
As a responsible company, we do not use automated decision-making or profiling.
Developed by the Legal Tech specialists at Willing & Able, who also developed the system for data-protection-compliant electronic time recording. The texts of the privacy policy generator were created and published by Prof. Dr. h.c. Heiko Jonny Maniero and attorney Christian Solmecke.


