1. SCOPE OF POLICY
1.1. Beerhands Land OÜ (“We”, “Us” and “Our”) is committed to protecting and respecting your privacy. This privacy policy (“Privacy Policy”) sets out the basis on which any personal data We collect from you, or that you provide to Us, will be processed by Us. Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it.
1.2. This Privacy Policy applies to your use of the Beerhandsland platform (“Platform”) and any of the services accessible through the Platform (“Services”).
1.3. Please also bear in mind that this Privacy Policy applies only if We collect personal data from you, i.e., if you upload a picture or give Us your e-mail address (or provide Us any other personal data). If We do not collect your personal data, then We do not process your personal data and therefore this Privacy Policy does not apply.
1.4. This Privacy Policy is effective as of the date set forth above. We have the right to unilaterally make amendments to this Privacy Policy. In such case the amended Privacy Policy shall be uploaded, and you will be notified of that once you launch the Platform again.
2. DATA CONTROLLER AND CONTACT INFORMATION
2.1. For the purpose of clarity, the data controller is Beerhands Land OÜ registered at A. Laikmaa tn 15 / Rävala pst 4, Tallinn, Harju County, 10143, Estonia (registry code: 16537363).
2.2. If you have any questions, requests or suggestions about processing your personal data, feel free to write an email at info@beerhands.land.
3. WHY AND WHAT CATEGORIES OF PERSONAL DATA IS PROCESSED
3.1. We collect and process your personal data for the following purposes:
a) providing the Services to you via the Platform, which mainly means posting content and sharing your location;
b) communicating and providing customer support to you in relation to providing you the Services (which also includes communicating with you as a potential user before providing any Services, if you have so requested);
c) improving the Platform;
d) providing you information about updates to the Platform;
e) enforcing and defending Our legal rights;
f) complying with legal or regulatory obligations or requests;
3.2. We may collect and process the following personal data:
a) information you give Us (“Submitted Information”): this is information you give Us about you by filling in forms on the Platform, by corresponding with Us (for example, by e-mail), and when you report a problem with the Platform or the Services. If you contact us, We will keep a record of that correspondence. The information you give Us may include your name and e-mail;
b) information We gather via the Platform (“Gathered Information”): this is information that is gathered via content you post, meaning uploaded pictures, your location and likes/comments/follows you make. Gathered Information also includes actions other users do and information they provide about you, meaning when others like or comment on your post, send a message to you, follow you etc.
3.3. We process the following data for the following purposes:
a) for purpose stated above in clause 3.1.a) – Submitted Information and Gathered Information;
b) for purpose stated above in clause 3.1.b) – Submitted Information;
c) for purpose stated above in clause 3.1.c) – Gathered Information;
d) for purpose stated above in clauses 3.1.d) – only your e-mail;
e) for purpose stated above in clause 3.1.e) – any of the categories of personal data listed above (determined case-by-case according to the legal right We are entitled to execute);
f) for purpose stated above in clause 3.1.f) – any of the categories of personal data listed above (determined case-by-case according to the legal or regulatory obligation or request We are subject to);
3.4. The provision of personal data by you to create an account at the Platform (“Account”) is a statutory requirement to use the Services. To create the Account, you must provide your e-mail address and name, this is a contractual requirement and necessary for creating the Account.
4. LEGAL BASIS FOR PROCESSING PERSONAL DATA
4.1. We process your personal data because it is necessary for the fulfilment of a contract concluded between you and Us for providing you the Services (see clauses 3.1.a) and 3.1.b)); or for taking steps at your request prior to entering into a contract (see clause 3.1.b)). In such a case the legal basis for processing data is the contract concluded between you and Us; or your request prior to entering into a contract.
4.2. We also process your personal data to improve the Platform. In this case the legal ground for processing your personal data is our legitimate interest for improving the Platform and providing a better Service.
4.3. Furthermore, We process your personal data (i.e. use your e-mail address) for sending you information about updates to the Platform (see clause 3.1.d)). The legal basis for that is Our legitimate interest to keep you the in loop of any advancements which the Platform may get (e.g., new functionalities, etc.), any news about the Platform. You always have the possibility to unsubscribe from such e-mails by clicking on a link which is provided under each e-mail. If you unsubscribe, We will no longer send you such e-mails.
4.4. We also process your personal data for enforcing and defending Our legal rights under legitimate interest pursued by Us (see clause 3.1.e)). It is Our legitimate interest to enforce and defend Our legal rights as We see it necessary.
4.5. Also, We process personal data for complying with legal or regulatory obligations or requests (see clause 3.1.f)) as processing is necessary for compliance with the legal obligations to which We are subject to.
5. DISLOSURE OF PERSONAL DATA
5.1. We will not disclose your personal data to third parties except for the following cases:
a) Cloud-server service provider(s). We transfer data to cloud servers where We store all Our data, for example to Digital Ocean Database.
b) Service providers. We transfer data to different service providers who provide Us IT-services, including Platform’s location services. For example, Google Maps, Google Firebase.
c) Asset transfer parties. In the event that We sell or buy any business or assets, in which case We will disclose your personal data to the prospective seller or buyer of such business or assets. If Beerhands Land OÜ or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
d) Legal authorities, institutions and other parties under law. If We are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request. In order to:
i. investigate potential breaches; or
ii. protect the rights, property or safety of Our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5.2. Where We do share your information with third parties, We will require such third parties to comply with this Privacy Policy and maintain appropriate security to protect your information from unauthorised access or processing, unless We have no ability to do so (for example, where We are sharing information with regulatory authorities or courts).
6. HOW LONG PERSONAL DATA IS STORED
6.1. We only store your personal data as long as it is necessary to fulfil the purpose for which it is processed – once the purpose has ceased, the personal data will be erased or anonymised.
6.2. Your personal data will be stored:
a) up to 30 days after deletion of the Account when We process your personal data regarding the provision of the Services (see clause 3.1.a);
b) up to 30 days after deletion of the Account when We processes your personal data regarding communicating and providing customer support (see clause 3.1.b));
c) up to 30 days after deletion of the Account where We process your personal data for improving the Platform (see clauses 3.1.c));
d) up to 30 days after deletion of the Account where We process your personal data for providing you information about updates to the Platform (see clause 3.1.d));
e) up to 3 years after deletion of the Account when We process your personal data regarding enforcing and defending Our legal rights (see clause 3.1.e));
f) up to 3 years after deletion of the Account when We process your personal data regarding complying with legal or regulatory obligations or requests (see clause 3.1.f)).
7. YOUR RIGHTS
7.1. You have the right to contact Us by writing an e-mail at info@beerhands.land to exercise your rights concerning processing of personal data. Such rights include the:
a) right to request access of personal data;
b) right to request rectification of personal data – if the data We hold about you is inaccurate or incomplete;
c) right to request erasure of personal data – if We do not have a legal reason to continue to process and store it;
d) right to request restriction of processing of personal data;
e) right to object to processing of personal data;
f)right to request portability of personal data, i.e. to obtain and reuse your personal data for your own purposes;
g) right that decisions are not taken concerning you which are based on automated decision-making;
h) right to withdraw a consent at any time;
i) right to lodge a complaint with a supervisory authority (Estonian Data Protection Inspectorate – https://www.aki.ee/en).