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Privacy Policy

We are very pleased that you are interested in our company. Data protection is of a particularly high priority for the management of Kewee OÜ. The use of the websites of Kewee OÜ is generally possible without any indication of personal data. However, if a data subject wishes to use special services of our company via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection provisions applicable to Kewee OÜ. By means of this privacy policy, our company would like to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed by means of this privacy policy of the rights to which they are entitled.

As the controller, Kewee OÜ has implemented numerous technical and organisational measures to ensure the most complete protection possible of the personal data processed via this website. Nevertheless, 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 is intended to 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.

In this privacy policy, we use, among others, the following terms:

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

Data subject is any identified or identifiable natural person whose personal data is processed by the controller.

c) Processing

Processing is any operation or set of operations which is performed on 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 is any form of automated processing of personal data consisting of the use of such 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 ensuring that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing 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) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another 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 are not regarded as recipients.

j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent

Consent is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

2. Name and Address of the Controller

The controller for the purposes of the General Data Protection Regulation, other data protection laws applicable in the 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

E-mail: info@kewee.co

3. Cookies

The websites of Kewee OÜ use cookies. Cookies are text files that are placed and 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 string of characters by which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This enables the 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 via the unique cookie ID.

Through the use of cookies, Kewee OÜ can provide the users of this website with more user-friendly services that would not be possible without the setting of cookies.

By means of a cookie, the information and offers on our website can be optimised with the user in mind. Cookies allow us, as already mentioned, to recognise the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website, because this is taken over by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping cart in the online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart via a cookie.

The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting of the internet browser used and can thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can 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 referrer), (4) the sub-websites that are 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) other similar data and information that serve to avert danger 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 in order to (1) deliver the contents of our website correctly, (2) optimise the contents of our website as well as the advertising for it, (3) ensure the long-term 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. This anonymously collected data and information is therefore evaluated by Kewee OÜ on the one hand statistically and further with the aim of increasing data protection and data security in our company, in order ultimately to 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 option of registering on the website of the controller by providing personal data. Which personal data is transmitted to the controller in the process results from the respective input mask used for the registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the data to be passed on to one or more processors, for example a parcel service provider, who likewise uses the personal data exclusively for internal use attributable to the controller.

Through registration on the website of the controller, the IP address assigned by the internet service provider (ISP) of the data subject, as well as the date and time of registration, are also stored. The storage of this data takes place against the background that only in this way can the misuse of our services be prevented, and this data, if necessary, makes it possible to clear up offences committed. In this respect, the storage of this data is necessary to secure the controller. This data is generally not passed on to third parties unless there is a legal obligation to pass it on or the disclosure serves criminal prosecution.

The registration of the data subject with the voluntary provision of personal data serves the controller in offering the data subject contents or services that, due to the nature of the matter, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time, or to have it completely deleted from the controller's data records.

The controller shall at any time, upon request, provide every data subject with information about the personal data stored about the data subject. Furthermore, the controller shall correct or erase personal data at the request or indication of the data subject, insofar as no statutory retention obligations stand in the way. All employees of the controller are available to the data subject in this context as contact persons.

6. Subscription to our newsletter

On the Kewee OÜ website, users are given the option to subscribe to our company's newsletter. Which personal data is transmitted to the controller when subscribing to the newsletter is determined by the input mask used for this purpose.

Kewee OÜ informs its customers and business partners at regular intervals by means of a newsletter about the company's offers. Our company's newsletter can, in principle, 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 mailing. For legal reasons, a confirmation email is sent using the double opt-in procedure to the email address first entered by a data subject for the newsletter mailing. This confirmation email serves to verify whether the owner of the email address, as the data subject, has authorized receipt of the newsletter.

When registering for 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 registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of a data subject's email address at a later point in time and therefore serves as legal protection for the controller.

The personal data collected as part of a newsletter registration is used exclusively to send our newsletter. Furthermore, subscribers to the newsletter may be informed by email if this is necessary for the operation of the newsletter service or a related registration, as could be the case in the event of changes to the newsletter offering or changes to the technical conditions. The personal data collected as part of the newsletter service is not passed on to third parties. The subscription to our newsletter can be cancelled by the data subject at any time. The consent to the storage of personal data that the data subject has given us for the newsletter mailing can be revoked at any time. For the purpose of revoking consent, a corresponding link can be found in every newsletter. It is also possible to unsubscribe from the newsletter mailing at any time directly on the controller's website or to notify the controller of this 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 in order 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 recognize whether and when an email was opened by a data subject and which links contained in the email were accessed by the data subject.

Such personal data collected via the tracking pixels contained in the newsletters is stored and evaluated by the controller in order to optimize the newsletter mailing and to better adapt the content of future newsletters to the interests of the data subject. This personal data is not passed on to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given for this purpose via the double opt-in procedure. Following a revocation, this personal data will be deleted by the controller. Kewee OÜ automatically interprets unsubscribing from the newsletter as a revocation.

8. Contact option via the website

Due to legal regulations, the Kewee OÜ website contains information that enables quick electronic contact with our company as well as direct communication with us, which also includes a general address for so-called electronic mail (email address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is stored automatically. Such personal data transmitted on a voluntary basis by a data subject to the controller is stored for the purposes of processing or of contacting the data subject. This personal data is not passed on to third parties.

9. Subscription to comments in the blog on the website

Comments posted on the Kewee OÜ blog can, in principle, be subscribed to by third parties. In particular, it is possible for a commenter to subscribe to the comments following their own comment on a specific blog post.

If a data subject opts to subscribe to comments, the controller sends an automatic confirmation email in order to verify, using the double opt-in procedure, whether the owner of the specified email address has actually chosen this option. The option to subscribe to comments can be terminated at any time.

10. Routine erasure and blocking of personal data

The controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, or insofar as this has been provided for by the European legislator of directives and regulations or another legislator in laws or regulations to which the controller is subject.

If the purpose of storage no longer applies, or if a storage period prescribed by the European legislator of directives and regulations or another competent legislator expires, the personal data is routinely blocked or erased in accordance with the legal regulations.

11. Rights of the data subject

a) Right to confirmation

Every data subject has the right, granted by the European legislator of directives and regulations, to obtain from the controller confirmation as to whether or not personal data concerning them are being processed. If a data subject wishes to avail themselves of this right of confirmation, they may, at any time, contact an employee of the controller.

b) Right of access

Every person affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to obtain at any time from the controller free information about the personal data stored concerning them and a copy of this information.

c) Right to rectification

Every person affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to obtain without undue delay the rectification of inaccurate personal data concerning them.

d) Right to erasure (right to be forgotten)

Every person affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to obtain from the controller the erasure of personal data concerning them without undue delay, where one of the legal grounds applies and insofar as the processing is not necessary.

e) Right to restriction of processing

Every person affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to obtain from the controller restriction of processing where one of the legal conditions applies.

f) Right to data portability

Every person affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format.

g) Right to object

Every person affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them.

h) Automated individual decision-making, including profiling

Every person affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, not to be subject to a decision based solely on automated processing which produces legal effects concerning them or similarly significantly affects them.

i) Right to withdraw consent under data protection law

Every person affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to withdraw consent to the processing of personal data at any time.

12. Data protection in applications and the application process

The controller collects and processes the personal data of applicants for the purpose of handling the application process. The processing may also be carried out by electronic means. This is the case in particular where an applicant submits the relevant application documents by electronic means, for example by email or via a web form available on the website, to the controller. If the controller concludes an employment contract with an applicant, the transmitted data are stored for the purpose of handling the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents are automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the controller oppose such deletion.

13. Data protection provisions on the application and use of Facebook

The controller has integrated components of the company 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. If a data subject lives outside the USA or Canada, the controller for the processing of personal data 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. Data protection provisions on the application and use of Google AdSense

The 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. Data protection provisions on the application and use of Google Analytics (with anonymization function)

The controller has integrated the Google Analytics component (with anonymization 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 data protection provisions of Google may be retrieved at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html.

16. Data protection provisions on the application and use of Google Remarketing

The controller has integrated Google Remarketing services on this website. Google Remarketing is a feature of Google AdWords that enables 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. Data protection provisions on the application and use of Google AdWords

The 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 within 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. Data protection provisions on the application and use of Instagram

The controller has integrated components of the Instagram service on this website. Instagram is a service that can be classified as an audiovisual platform and enables users to share photos and videos and also to redistribute such data on 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. Data protection provisions on the deployment and use of LinkedIn

The 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 as well as to establish new business contacts.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, USA.

20. Data protection provisions on the deployment and use of Twitter

The controller has integrated components of Twitter on this website. Twitter is a multilingual, publicly accessible microblogging service.

Operating company of Twitter International Company, One Cumberland Place, Fenian Street Dublin 2, D02 AX07, Ireland.

21. Data protection provisions on the deployment and use of YouTube

The controller has integrated components of YouTube on this website. YouTube is an Internet video portal that enables video publishers to post video clips free of charge and other users to view, rate and comment on them, likewise free of charge.

The operating company of YouTube is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

22. Payment method: Data protection provisions on PayPal as a payment method

The 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.

PayPal's applicable data protection provisions can be accessed at https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

23. Payment method: Data protection provisions on Sofortüberweisung as a payment method

The controller has integrated components of Sofortüberweisung on this website. Sofortüberweisung is a payment service that enables cashless payment for products and services on the Internet.

The operating company of Sofortüberweisung is Klarna Bank AB, Sveavägen 46, 111 34 Stockholm, Sweden.

24. Legal basis for the processing

Art. 6 I lit. a DS-GVO serves our company 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 I lit. b DS-GVO.

25. Legitimate interests in the processing pursued by the controller or a third party

If the processing of personal data is based on Article 6 I lit. f DS-GVO, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and our shareholders.

26. Duration for which the personal data are stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. After the period expires, the corresponding data are routinely erased, provided they are no longer required for the performance or initiation of a contract.

27. Statutory or contractual requirements to provide the personal data

We inform you that the provision of personal data is in part required by law (e.g. tax regulations) or may also arise from contractual provisions (e.g. information about the contracting party). At times, in order to conclude a contract, it may be necessary for a data subject to provide us with personal data that must subsequently be processed by us.

28. Existence of automated decision-making

As a responsible company, we refrain from automated decision-making or profiling.

Developed by the legal tech specialists at Willing & Able, who also developed the system for data-protection-conscious electronic working-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.