PRIVACY POLICY

This Privacy Policy (hereinafter – Policy) applies to any and all information about employees, external employees, clients, potential clients, their affiliates, and affiliated individuals (hereinafter – Party or Parties) that OÜ Calyptra Invest (12296431) or its affiliates, including all persons belonging to the same group with OÜ Calyptra Invest (12296431) (hereinafter – CALYPTRA), may obtain in the course of the Parties’ use of any of CALYPTRA’s services or products, including using websites or elsewhere (hereinafter – Services) and during the performance of any agreements and contracts with the Parties. An agreement to this Policy within the framework of relations with any of the Parties shall apply to all Parties.

Legal Basis

CALYPTRA processes Personal Data under this Privacy Policy and in accordance with applicable legislation, including the General Data Protection Regulation (2016/679) (the “GDPR”) and the applicable national data protection laws in Estonia (“Data Protection Laws”).

Purposes and scope of Personal Data

CALYPTRA is committed to ensuring the privacy and confidentiality of the information pertaining to our clients, potential clients, their affiliates, and affiliated individuals, and to adhering to the policy set out below in congruence with our professional responsibilities and the applicable Data Protection Laws.

Reference in this policy to “Personal Data” means any information that identifies, or could reasonably be used to identify the Party (“Personal Data”), including for the following purposes:

a)    News, publications, service updates and events: CALYPTRA will use the information that the Party have provided to send news about the latest developments of CALYPRA, the scope of services than it can provide, as well as information about any upcoming events that may be of interest to the Party, including investment projects or business announcements. CALYPTRA will use the Personal Data for this purpose until the Party informs that it no longer wishes to receive such information. CALYPTRA may use the name, title, position, e-mail address, any provided phone numbers, address, and other information of the Party that can be used to contact the Party for the sake of providing it with this information.

b)    Cookies: CALYPTRA uses cookies to obtain information about the use of our Website. Cookies allow us to provide the Party with a more streamlined and accessible experience when using the Website. The information generally does not comprise any data that would allow us to individually identify the Party as a natural person. CALYPTRA will process the data using cookies for the duration of the period in which the Party has granted us consent. 

c)    Recruitment: CALYPTRA uses the Website and other contact channels that are listed on the Website to collect information on potential employees, partners, and clients. CALYPTRA will utilize the Personal Data that has been included in any and all of the documents that the Party has provided to us in its application/message. The application will be processed to determine whether your application matches the needs of CALYPTRA. CALYPTRA will retain the data that CALYPTRA has obtained for as long as necessary to evaluate the application and in accordance with all relevant laws and regulations. Furthermore, CALYPTRA may ask for the Party’s consent to retain its Personal Data for some time after CALYPTRA has evaluated its application.

d)    Professional services: CALYPTRA collects information that has been provided by our client or on behalf of our clients, or information that CALYPTRA acquires independently within the scope of providing professional services. This collection of Personal Data is necessary to fulfil the obligations that CALYPTRA has towards our clients, and in our legitimate interest as a financial institution, to legal counsel to our clients and potential clients. As per our professional responsibilities, CALYPTRA will take the utmost care to ensure the confidentiality and integrity of the Personal Data of our clients, potential clients, and former clients.

When providing professional services, CALYPTRA may supplement the Personal Data that you have provided to us directly with Personal Data that has been obtained from other sources.

The transfer of your Personal Data to third parties

CALYPTRA has associated companies and partners and in common with other professional service providers, CALYPTRA uses third parties located in other countries to smoothly operate and run our business.  As a result, Personal Data may be transferred outside the countries where CALYPTRA and our clients are located.  

In respect of Personal Data being regulated by EU legislation, please note that: cross border transfers may include countries outside the European Economic Area (“EEA”) and countries that do not have laws that provide specific protection for Personal Data. CALYPTRA has taken steps to ensure all Personal Data is provided with adequate protection and that all transfers of Personal Data outside the EEA are done lawfully. Where CALYPTRA transfers Personal Data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for Personal Data, the transfers will be under an agreement which covers the EU requirements for the transfer of Personal Data outside the EEA, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here.

CALYPTRA may share Personal Data with associated companies, partners and third parties where necessary for administrative purposes and to provide professional services to our clients (e.g., when providing services involving services from associated companies in different territories).

• Third parties that provide applications/functionality, data processing or IT services to us;

CALYPTRA uses third parties to support us in providing our services and to help provide, run, and manage our internal IT systems. For example, providers of information technology, cloud-based software as a service provider, identity management, website hosting and management, data analysis, data back-up, security, and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centers around the world, and Personal Data may be stored in any one of them;

• Third parties that otherwise assist us in providing goods, services, or information;
• Auditors, counsellors, attorneys, lawyers and other professional advisers;
• Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation;

Occasionally, CALYPTRA may receive requests from third parties with authority to obtain disclosure of Personal Data, such as to check that CALYPTRA is complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  CALYPTRA will only fulfil requests for Personal Data where CALYPTRA is permitted to do so in accordance with applicable law or regulation.

Changes to this privacy policy

CALYPTRA may make any changes to this Policy as CALYPTRA sees fit. If the Policy has been changed in any way, then the newest edition of this Policy will be published on our website and the parties subscribed to our newsletter will be notified on the matter. CALYPTRA encourages you to check whether any changes have been made to the Policy from time to time.

Data controller and contact information

The data controller is legal entity, a client, associated company or partner, as applicable, that is a contracting party for the purposes of providing or receiving services or the entity you have contacted.

If you have any questions about this policy or how and why CALYPTRA processes Personal Data, please contact us at:

info@calyptra.eu

+37253711131Your rights as a data subject and how to exercise them

Individuals have certain rights over their Personal Data and data controllers are responsible for fulfilling these rights. Where CALYPTRA decides how and why Personal Data is processed, CALYPTRA is a data controller and include further information about the rights that individuals have and how to exercise them below.

Access to Personal Data

You have a right of access to Personal Data held by us as a data controller. This right may be exercised by emailing us at info@calyptra.eu.

Amendment of Personal Data

To update Personal Data submitted to us, you may email us at info@calyptra.eu or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which you registered.

When practically possible, once CALYPTRA is informed that any Personal Data processed by us is no longer accurate, CALYPTRA will make corrections (where appropriate) based on your updated information.

Withdrawal of consent

Where CALYPTRA processes Personal Data based on consent, individuals have a right to withdraw consent at any time.  CALYPTRA does not generally process Personal Data based on consent (as CALYPTRA can usually rely on another legal basis). To withdraw consent to our processing of your Personal Data please email us at info@calyptra.eu or, to stop receiving an email from a CALYPTRA marketing list, please click on the unsubscribe link in the relevant email received from us. 

Right to restrict or object to our processing of Personal Data

You have the right to restrict or object to the processing of your personal information at any time, on reasonable grounds relating to your particular situation, unless the processing is required by law.

In such case, CALYPTRA will no longer process or restrict the processing of the Personal Data, unless CALYPTRA can demonstrate compelling legitimate grounds for the processing or for the establishment, exercise, or defense of legal claims.

Other data subject rights

This Privacy Policy is intended to provide information about what Personal Data CALYPTRA collects about you and how it is used.  As well as rights of access, amendment and restriction or objection to processing referred to above, individuals may have other rights in relation to the Personal Data CALYPTRA holds, such as a right to erasure/deletion and the right to data portability.  

Complaints

CALYPTRA hopes that you will not ever need to, but if you do want to complain about our use of Personal Data, please send an email with the details of your complaint to info@calyptra.eu. CALYPTRA will look into and respond to any complaints CALYPTRA receives.

You do have the right to lodge a complaint with a Data Protection Authority (“DPA”) if you think that your Personal Data is being processed incorrectly or your data subject rights have been violated by us. You can lodge a complaint by contacting the DPA that is local to your jurisdiction i.e., the location of the alleged violation of your data subject rights or the inappropriate processing or your data, or the place you live and work.

This is the list of DPAs that are relevant to the scope of this Policy:

• The Estonian Data Protection Inspectorate in Estonia: http://www.aki.ee/en