2. The Controller
The personal data processing controller is the company registered in Estonia Beldev Consulting OÜ, reg. No. 14441788, registered address is Rävala pst 5, Kesklinna linnaosa, Tallinn, Harju maakond, 10143.
3. The purposes of personal data processing and legitimate interests:
Transcoin.me can process personal data for the following purposes:
- preparation of various documents, including drafting and entering into contracts and agreements;
- placing orders;
- identification of customers, employees, partners or other data subjects;
- customer service and service improvement;
- ensuring the provision of services;
- improving service quality;
- registration of customers;
- delivery of goods;
- developing new services;
- handling of objections, claims, complaints, suggestions, notifications and other applications;
- maintaining communication;
- administration of accounts;
- debt recovery;
- performance of transactions in the systems of the controller;
- maintaining and analysing of statistical data;
- market research purposes;
- advertising new services and goods;
- notification of news;
- creating, implementing and improving loyalty programmes;
- other marketing activities;
- maintenance and improvement of the website and social media pages;
- prevention of risks of money laundering and terrorism financing;
- prevention of fraudulent activities;
- implementing the
anti-fraud and AML policy;
- testing and improving the internal control system;
- customer research and in-depth research;
- clarifying real beneficiaries;
- protecting the legitimate interests of the controller, data subject or third party;
- performing other legal duties;
- see below regarding video surveillance and loyalty cards;
- for other purposes if the customer has been made aware of it.
4. Legal grounds for the processing of personal data:
- requirement of laws and regulations;
- contractual relations;
- in individual cases, with your consent;
- to exercise the legitimate interests of the controller or a third party to which the personal data have been disclosed, subject to the fundamental rights and freedoms of the data subject.
5. How we collect personal data:
- When you use the Transcoin.me website or enter information there;
- When you order/use our services;
- From partners, through customer verification/identification;
- When you or a third party file a complaint.
6. Categories of personal data processing
|Personal data||Legal grounds||Purpose of processing|
(type of device and software, visit and click statistics, IP address, time, etc.)
|Your consent||To improve website performance, to collect statistics.|
|Personal identity number|
For statistical purposes and market research purposes.
|Date of birth|
|Copy of the identification document/photography||In order to perform customer identification/research, to implement |
anti-fraud and AML policies, to reduce the chances of fraud.
|Digital data (pages visited, IP address, device identifiers, type of operating system, |
geolocation data, services used).
|In order to perform customer identification/research, to implement |
anti-fraud and AML policies, to reduce the chances of fraud.
|Bank card or internet wallet details||Performance of the agreement||To settle accounts and provide the service.|
7. Transfer of personal data
- To fulfil our legal obligations, we may transfer your personal data to law enforcement authorities, as well as state and local government institutions in the events specified by law.
- We may transfer your personal data to state and local government institutions as well as to debt recovery service providers to defend our legitimate interests.
- To provide services in high quality and to ensure efficient customer service, in some cases, we transfer your personal data to companies that are providing outsource services to us (such as banks and other billing system services, out-of-court debt collectors, financial or tax audit, IT system providers, etc.). Data is only transferred in the minimum amount necessary. These companies can only process your personal data according to the controller's instructions and cannot use them for other purposes. These companies are required to provide a relevant degree of protection of personal data, in accordance with the law and our cooperation agreement.
- For customer identification and verification of personal documents, Transcoin reserves the right to introduce/transfer your personal data to third parties that provide document verification and identification services
8. Personal data safety
In order to protect the privacy of your data, we have taken appropriate technical and organisational measures and are using modern technologies. We provide regular checks and upgrades. Your data is safe with us.
9. Duration for the storage of personal data
- Your data will be processed for as long as the agreement is in force as well as until the limitation period for the claims arising from the agreement expires;
- as long as the parties can exercise their legitimate interests;
- in accordance with the requirements of laws and regulations;
- until the consent of the customer for the processing of personal data is in force, unless another legal basis for processing is in place.
10. Your rights
You are entitled to:
- find out if we are processing your personal data;
- if we process your personal data, you have the right to access the relevant information;
- if information about you is incorrect or incomplete, you are entitled to provide correct information to us and to ask for it to be corrected;
- withdraw the consent;
- in individual cases you are entitled to object to the processing of data, to ask for the restriction of data processing, to request the deletion of data. Please note that these rights are only enforceable in accordance with the requirements of the law and we reserve the right to refuse to perform the above activities based on the requirements of laws and regulations;
- receive and/or transfer personal data to another controller. The above only applies to data that you have provided to us based on you consent or the agreement and where processing is carried out by automated means.
- You may only exercise your rights based on a written application (including the one signed with a secure electronic signature). We will respond by the deadline set forth by law.
- We will examine your application in accordance with the requirements of laws and regulations. If we fail to come to a solution, you have the right to apply to the Data State Inspectorate.
11. Making automated decisions
Transcoin.me does not make automated decisions.
12. Policy updating
13. Contacting in personal data processing matters
If you have any questions regarding the processing of personal data, including about this Policy or your rights, you can contact us or our data protection officer. Use email [email protected]