In case of dispute, the Estonian language version of the Privacy Policy prevails.

1. General Provisions

OÜ Trinity Capital ("Service Provider") respects your privacy. Service Provider will comply with applicable laws and does not process User’s personal data and/or personal data of other parties without the permission of the User or in order to satisfy applicable law, regulation, legal process or enforceable governmental request. Service Provider will process only personal data, when it is necessary for providing our services and collect information to provide better services to all of our users.

This Privacy Policy applies to all our Services and explains the main principles and reasons for processing User’s personal data. Users can be natural persons or representatives of other natural or legal persons.

The Service may contain links to third-party websites or services. These websites and services may have their own privacy policy. The service provider is not liable for privacy policies of the third parties', activities related to the processing of personal data by the third parties, and suggests examining carefully each third party's privacy policy.

2. Personal data we collect and sources of data

Personal Data means any data about an identified or identifiable natural person, regardless of the form or format of the data.

Service provider collects User data lawfully through the use of Services. The Service provider may process User’s personal data for providing services, and in specific cases provided in this Privacy Policy.

The service provider processes personal data that User gives to Service provider and information that Service provider gets from the use of our services, including (but not limited to) the following information:

electronic identification (e.g. IP addresses, cookies);
correspondence between the service provider and the User;
for personalizing content and ads;
for providing social media functions and analyzing traffic;
statistical demographic data (e.g., age, gender, interests).

Service provider may collect data about using of the user interface elements and service-related activities, for analysing the use of the Service.

3. Data Controller and Data Processor

The controller for user data is the Service provider. The Service provider may assign data processing to data processors. Data processors are:

Google Inc.
Facebook
smartAD OÜ

Data processors process data, inter alia:

for the purpose of providing a service;
for marketing purposes, except when the User has decided otherwise or later to withdraw the corresponding consent, informing it in a format that can be reproduced in writing;
comply with legal obligations (e.g. forwarding data to the public authority)

A data processor may only process data for specific tasks determined by the Service Provider.

4. The purpose of personal data processing

Processing personal data is based on User consent. By using the Services and submitting personal data, the User authorizes the processing of all personal data to the extent and for the purposes described in the Privacy Policy.

The purpose of data collecting and processing is mainly to provide, maintain, protect and improve the Services and to develop new ones. Service provider also uses this information to offer tailored content for Users – such as giving more relevant ads and provide better content.

The service provider does not save the data provided by the User in Service provider’s database, but only processes it to the extent necessary for the provision of the service.

5. Profiling

The service provider may use website visitor statistical data to analyse trends and demographics of visitors. However, service provider does not assign each visitor an individual profile.

6. Sharing personal data with third parties

The service provider does not sell, rent, trade or give generally User’s personal data, traffic data and communications content to third parties, without the his/her consent, except

in order to satisfy applicable law, regulation, legal process or enforceable governmental request, or
in order to protect against harm to the rights, property or safety of Service provider, Users or the public, as required or permitted by law, and
in cases provided in the Privacy Policy.

During the business development, Service provider may buy or sell its business units. In case of such transactions, and if the Service provider or substantially all of its assets are going to the possession of a third party, the User’s personal data is generally considered as a transferable business asset. Service Provider reserves the right to involve the User’s personal data as an asset transferred to a third party.

7. Data Quality

The Service provider shall ensure within their means the quality of processed personal data. Service provider may modify the entered data, in extent, that is necessary for the operation of the Service, for example, to replace the entered characters, punctuation marks, or other symbols that might mislead automated program. However, the User is still responsible for the accuracy of the provided data.

8. Information Security

Service provider has implemented the necessary technical and organisational measures to protect personal data from unauthorised and accidental or illegal deletion, modification, disclosure, transmission, or other unlawful forms of processing.

The service provider is however not liable for third-party access to the devices that are under control of the User, the Internet and its security.

9. Personal Data storage

The service provider does not store personal data entered by the user. Correspondence relating to natural persons is generally stored for up to one year.

10. Cookies

To make the Website work properly, Service provider sometimes places small data files called cookies on User’s device. Most big websites do that too.

The legal basis for the use of cookies is service provider's legitimate interest in ensuring the technical functionality of the website. When cookies are used to remember user choices or for statistical purposes, the legal basis is user consent.

What are cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

How do we use cookies?

The Service provider may use cookies and tools similar with cookies, to provide the Service to improve Service quality, and improve the User experience. Cookies can also be used by third parties, whose services are used by the Service provider.

Service may use cookies for:

personalizing content and ads;
provision of the social media functions;
analyzing Web traffic.

The Service provider may also provide information to its social media, advertising and analytical partners on how the User uses the Website.

The implementation of these cookies is not directly necessary for the operation of the website, but it provides the User a better browsing experience. Users can either delete or block cookies, but in this case some of the website features may not function as intended.

Cookies help the Service Provider to provide services. User agrees that the Service Provider uses cookies, by using the Services.

How to control cookies

Users can control and/or delete cookies upon a wish – for details, see www.youronlinechoices.com/. User can delete all cookies that are already on User’s computer and User can set most browsers to prevent them from being placed. If one does this, however, User may have to manually adjust some preferences every time User visits a site and some services and functionalities may not work.

11. Google Analytics

The Service provider may use Google Analytics, a web analytics service offered by Google, Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"). Google Analytics also uses cookies, files that are saved in the user's computer to analyse how the user uses the Services.

The user information generated by Cookies, during the use of the Service, is usually transmitted to the Google server in the United States and saved there. As the service provider has activated the IP anonymisation, Google shortens the User's IP address (if the User is from European Union or from other EEA Member States).

At the Service provider's request, Google will use the information to analyze User interaction and to draw up reports on the Service website usage.

The user can set the browser to block all cookies, including cookies associated with our services or to indicate when a cookie is being set by our services. However, it’s important to remember that many of our services may not function properly if your cookies are disabled.

In addition, user can disable cookies from forwarding the data collected on the website (including IP address) to Google and the transfer of the data to Google's servers for further processing. To provide Users the ability to prevent their data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on for the Google Analytics JavaScript. If user want’s to opt-out, one should download and install the add-on for the web browser from: tools.google.com/dlpage/gaoptout?hl=en.

Google Analytics retains user-level and event-level data associated with cookies, user-identifiers (e.g., User-ID) and advertising identifiers (e.g., DoubleClick cookies, Android’s Advertising ID, Apple’s Identifier for Advertisers) 26 months.

12. Interest-based advertising (DoubleClick DART cookie)

Service provider may serve ads by third parties on the website. Advertising keeps the services that you use free of charge.

Google uses the DART cookies to target advertising based on what’s relevant to a user, to improve reporting on campaign performance, and to avoid showing ads the user has already seen.

Users may opt out of the interest-based ads by visiting the Google Ads Settings at:

Go to Ads Settings at www.google.com/settings/ads/anonymous.
Next to "Ads based on your interests", click the switch if it's in the ON position.
In the dialog that opens, click the SWITCH OFF link to confirm your selection.

Additional information on advertising can be found at: www.google.com/policies/technologies/ads/

13. Google Adsense and third-party advertising networks

The service provider may use Google Adsense. Third-party network advertisers, who use Google Adsense, use technology that sends the advertisements and links directly to the user’s web browser. The User’s IP-address is forwarded to those advertisers. Third-party advertising networks, also use other technologies (for example, cookies, JavaScript), to measure the effectiveness of the ads and to personalize them.

The Service Provider has no access to or control over these cookies, which are used by third-party advertisers.

Users should consult with such third-party advertisers for getting more information about their privacy policy and the options of non-disclosure of your information to them in certain cases.

If the user wants to block cookies, it can be done through Internet browser settings. In some browsers you can set up rules to manage cookies on a site-by-site basis, giving you more fine-grained control over your privacy. What this means is that you can disallow cookies from all sites except those that you trust.

14. Facebook

The service provider's website can be integrated with Facebook (1601 S. California Avenue, Palo Alto, CA 94304, USA), plug-ins "Like" and "Share". For an overview of the add-ons, please visit the Facebook site developers.facebook.com/docs/plugins/.

When a user visits the website, a direct link between User's browser and the Facebook is created. By using those plug-ins, Facebook obtains information that User’s IP address has access to the Service provider's webpage. If a User is logged on and clicks the Facebook "Like" or "Share" buttons, User can be link the Service provider’s content to User’s Facebook profile, through which Facebook can reflect the usage of the Services on User’s Facebook wall. The Service provider cannot obtain any information on transferred data or how Facebook uses User’s data. More information can be found by visiting Facebook's privacy policy: www.facebook.com/about/privacy/.

If the user does not want that the visits on the Service website are reflected on User’s Facebook account, User must log out of Facebook.

15. Logs

The server that hosts the website may also record requests user makes to the server, such as the web address the user opens, the device and browser te user uses, user's IP address, date and time of access. This data is used only for technical purposes – that is, to ensure the proper functioning and security of the website and to investigate possible security incidents.

16. User rights and how to exercise them

By contacting the service provider, user may exercise his/her rights:

to require access to his/her personal data;
to require rectification of his/her personal data;
to require erasure of his/her personal data;
to withdraw consent to processing of his/her personal data, where applicable.

In some cases user may have a right to request a restriction on processing his/her personal data or to object to processing of his/her personal data.

User may exercise his/her rights in line with the requirements of applicable EU and local laws.

If personal data is erased at user's request, the service provider will only retain such copies of the information that are necessary to protect the service provider's or third party legal interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement user has entered into with the service provider.

User may disable cookies by his/her browser settings, or by visiting here:

17. Changes in Privacy Policy

Service provider may regularly make changes to this Privacy Policy and in the associated information, without informing the user. To stay informed about possible changes in this Privacy Policy, user is encouraged to review the Privacy Policy regularly.

18. Right to lodge a complaint

If user thinks his/her privacy rights have been breached, user may lodge a complaint with an authority of the EU country of his/her habitual residence. Contact information for these authorities can be accessed at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

19. Data controller and Contacts

Service provider is the data controller of the personal data. Learn more about the privacy policy by contacting us here.

Last updated: 25.04.2018.

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