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.
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.
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.
- 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
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.
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
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.
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.
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.
- 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.
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 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.
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 has no access to or control over these cookies, which are used by third-party advertisers.
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.
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/.
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.
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:
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
Last updated: 25.04.2018.