PRIVACY POLICY

Below is a description of how the data we gather from you as a visitor (hereinafter “the Visitor”, “you”, “visitor” or “Customer”) to our publicly-accessible website https://wtpscandic.eu (hereinafter known as “WTP Scandinavian Group”, “Site”, “the Site”, “We” or “Us”) and other websites where this privacy policy (hereinafter “Policy” or “the Policy”) is posted, is used and how it is kept safe. Please review this Policy before using any part of the Site as by using any part of the Site you hereby agree to the collection, use and disclosure of your information as outlined below.

The lawful basis for processing and storing data subjects personal data and data retention periods are based on the contractual obligations agreed upon by the user by creating the account on the basis of agreeing to the Terms and Conditions, legal basis derived from the EU law or by explicit consent provided for marketing purposes. Additional rights are Covered in more detail in the Data Handling Policy.

We use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your email address, name, phone number, postal address, other information (“Personal Information”).

1. What kind of data is collected:

   • Data given to Us directly – the Visitor has the option to contact Us via e-mail from the contact-us link, which is being recorded. We may also offer the Visitor the option to share details through signing-up to surveys or by signing-up to a newsletter, during which We will collect and record the information the Visitor provides Us in subscribing or using such opportunities.

   • Data collected automatically – When visiting the Site, We may collect certain data using tracking technologies like cookies, web beacons and similar technologies.

2. How is the data collected used:

   • Data given to Us directly – The data given to us directly is used to provide you with a response to the inquiries and to provide you with the reply to the surveys signed-up.

   • Data collected automatically – Data collected automatically as described in section 1 is used to understand how visitors are using the Site and to improve the usability of the Site.

We will not use the data from the Visitor for no other purposes than to provide and personalize services. We will not sell any information to any third parties.

Who We may share your data with:

• Compliance with laws – We may disclose the data provided to Us to a third party if such disclosure is required by law, regulation or legal process. Also such information may be disclosed to enforce the Policy or in case to protect the security of the Site. If We are legally required to provide such data to third parties, we will use reasonable efforts to provide the Visitor with information about such procedures.

• Service Providers – We may employ third party companies to provide the Service, to perform Service-related services or to assist us in analysing how our Service is used. These third parties have access to your Personal Information only to perform these tasks and are obligated do not use it for any other purpose as well as act in accordance with the General Data Protection Regulation. No personal information that is collected from the Visitors is disclosed unless explicit content is granted for such purposes.

WTP Scandinavian Group may also be able to access the device information.

 

1. The information collected is stored within protected storage, such that the information is not accessible for any third parties. In addition the information is protected by a log-in system.

2. The Site uses cookies to identify visitors to the website and in order to track the usage pattern of the website and to build a profile of the general usage of the Site.

3. The Visitors have the right to ask for the Site to provide information transfer, delete or make changes to the data collected. This is done by contacting Us via info@wtpscandic.eu The data collected will not be deleted if there is a legal obligation to retain such data.

4. Given the nature of the internet, data collected and processed requires the transformation on an international basis. By communicating with Us over electronically, the Visitor acknowledges that information provided during the communication may be processed outside of the European Economic Area, although the data itself will be stored with the requirements of Estonian data protection requirements.

 

Cookies

 

Cookies are files with small amount of data, which may include an anonymous unique identifier and other parameters. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

 

Communications

 

We may use your Personal Information to contact you with marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

 

Security of your data

 

The security of your Personal Information is important to us. We strive to use commercially acceptable means to protect your Personal Information, in compliance with GDPR.

 

Children Privacy

 

Our Service does not address anyone under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a children under age 13 without verification of parental consent, we take steps to remove that information from our servers.

 

International Transfer

 

Your information, including Personal Information, may be transferred to — and maintained on — telecommunication systems located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside of Estonia and choose to provide information to us, please note that we transfer the information, including Personal Information, to Estonia and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

 

Changes To This Privacy Policy

 

Changes to the Policy. The Policy is revised over time. Any changes made to the Policy will be updated and the version of the Policy with the effective date shall be written at the bottom of the document. The customer is encouraged to check the effective dates of the Policy. The continued use of the WTP Scandinavian Group service shall be considered as an acceptance to all revisions of the Policy. If the customer shall not agree to any changes made, then the customer must cease to use the service and WTP Scandinavian Group shall not be obliged to offer any services to the customer.

This revision of the Privacy Policy is dated 01.05.2018

 

TERMS OF SERVICE

 

Introduction

 

This Service agreement (“Agreement”) regulates the terms and conditions of using WTP Scandinavian Group  platform (“Service”) and is entered into by You (“User”) and WTP Scandinavian Group (“Service Provider”) located at Valge tn 13, Kesklinna linnaosa, Tallinn, Harju maakond 10127 (hereinafter jointly referred to as Parties).

The Terms and Conditions also encompass the Privacy policy and the Data handling policy.

By registering for or using the Service the User agrees having read and fully understood the Agreement. By registering for or using the Service the User also agrees having entered the Agreement and being bound by the terms in the Agreement and the Privacy Policy regardless of the form of registration or using of the Service.

By entering the Agreement the User states being at least 18 years of age and having adequate legal capacity to enter into the Agreement. The User will use the Service only for lawful purposes, in accordance to the Agreement and the instructions provided on the WTP Scandinavian Group website https://wtpscandic.eu (hereinafter jointly referred to as “Website”).

 

Your Account, Password and Security

 

In order to use the Service the Service Provider may ask for some information from the User (company name, contact information etc.). The User states that all the information provided to the Service Provider is current complete and accurate to the best of the User’s knowledge.

The Service Provider reserves the right to suspend or stop any Users from using the Service in case the information provided by the User has not been current, complete and accurate.

In case the information provided to the Service Provider by the User should change the User is obliged to immediately notify the Service Provider.

The User does not circumvent or attempt to circumvent the user authentication systems used by the Service Provider.
The User is entirely responsible for all activities which occur while or as a result of using the Service.
The User is liable for any damages, losses or costs that the Service Provider or any third party sustains as a result of the User using the Service.

The User is also liable for any damages, losses or costs that the Service Provider or any third party sustains as a result of a third party using the Service with the User’s password, account name or account information. Therefore the User is responsible for maintaining the confidentiality of passwords and any information regarding the Service or the Users personal account.
The User is to immediately notify the Service Provider (info@wtpscandic.eu) of any unauthorized use of the User’s password or account of which the User is aware of.

 

Prohibited Use of Service

 

Under any circumstances the User shall not transmit any messages using the Service which:
(a) are unsolicited. That is sending messages to recipients who have not explicitly requested to receive messages from the User.
(b) contain content deemed illegal by the laws of Estonia and/or the laws of the recipient’s country.
(c) are unlawful, harassing, defamatory, abusive, indecent, threatening, harmful, vulgar, obscene, sexually orientated, racially offensive, profane, pornographic, abusive, misleading, threatening or otherwise intend to cause distress, annoyance, inconvenience, worry or upset to the recipient.
(d) contain copyright trademarks or other intellectual property without the written permission of the holder of these rights.
(e) may lead the Service Provider negative reputation.

The User is to immediately notify the Service Provider of any such prohibited messages has sent using the Service

As a result of prohibited messages being transmitted using the Service, the Service Provider may at its discretion temporarily suspend the account which has been used to send such messages until the matter is resolved to the satisfaction of the Service Provider. In extreme cases, the Service Provider can also terminate such account and the Agreement with the User related to the account.

In the instance of any fines being levied against the Service Provider as a result of prohibited messages having been sent using the Service, the User responsible for sending such messages or owning the account used to send such messages is held liable to pay each fine in its entirety.

 

Service and Termination

 

The Service Provider makes no guarantees regarding the performance of the Service’s systems and those of the mobile operators.
This Agreement may be terminated with or without cause at any time by sending a written notice to the Service Provider (info@wtpscandic.eu). The Service Provider may investigate any activity that may violate this Agreement and may at any time in its sole discretion terminate this Agreement.

 

Final Provisions

 

This Agreement is governed by the laws of Estonia. The User agrees that the English language version of the Agreement will govern the relationship between the User and the Service Provider. All translations from the English language Agreement to some other language are provided for convenience. In case of any contradictions between the English language version of the Agreement and any translations the English language version shall take precedence.

Parties shall not be responsible for total or partial default on their obligations hereunder where this occurs due to the impact of force majeure circumstances. The Parties shall construe force majeure circumstances as circumstances which a Party could not foresee at the time of concluding the contract and could not prevent or remove with any means whatsoever. Such circumstances shall be: natural calamities, strikes, fires, war, lawful or unlawful decisions of public authorities, etc.

 

Use and Storage of Customer Data

 

All customer data processed and stored including:

• Contact information and contact information changes, including payments and payment history.

• User interface interaction activity and activity logs, previous login time and login IP.

• User uploaded data for message delivery and phonebook management.

• Traffic routing information.

is handled as confidential and sensitive information and is only accessed by a limited number of people from WTP Scandinavian Group, as well as the rights retained by the client to limit content availability via hiding or hashing content.

The data is gathered, processed and stored only in cases of:

1. Performing contractual obligations and in order to deliver the service described in the Terms and Conditions or as set forth in agreements between the client and WTP Scandinavian Group

2. Customer support to the extent required to resolve the issue and prevent future issues from occurring

3. To improve service quality to the necessary extent by processing and analysing customer data or to alternate message routing channels

4. To ensure the compliance with applicable laws and regulations, including data storage demands as set forth by Estonian and EU regulations

5. Accessed by third parties only as far as is needed to sustain service functionality and stored by third parties as demanded by law and the agreements between WTP Scandinavian Group and it’s partners.

 

Data Retention Periods:

 

All personal data relating to account are retained for the duration of the active use of the account or until the data subjects request for data deletion, unless required otherwise by law.

All user activity logs are kept for a reasonable time (no longer than six month) to provide service rapports and service use history, or until the data subjects request for data deletion, unless required otherwise by law.

All consensual personal data are kept for a reasonable time (no longer than six month) or the duration of the active use of the account or until the data subjects request for data deletion, unless required otherwise by law.