Privacy policy
of Kamjo

This data protection declaration informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Responsible person

Toomas Varjund
TAD logistics OÜ
Haapsalu mnt. 12 A
76102 Haaarjuma
Estonia

Types of data processed:

  • Inventory data (e.g., names, addresses).
  • Contact information (e.g., email, phone numbers).
  • Content data (e.g., text input, photographs, videos).
  • Usage data (e.g., web pages visited, interest in content, access times).
  • Meta/communication data (e.g., device information, IP addresses).

Categories of persons concerned

Visitors and users of the online offer
(Hereafter, we also refer to the data subjects collectively as “Users”).

Purpose of processing

  • Zurverfügungstellung des Onlineangebotes, seiner Funktionen und Inhalte.
  • Respond to contact requests and communicate with users.
  • Safety measures.
  • Reach measurement/marketing

Terms used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data.
“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
“Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. If the legal basis is not stated in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the fulfillment of our services and implementation of contractual measures as well as answering inquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR as the legal basis.

Security measures

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with Article 32 of the GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data, and response to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Article 25 of the GDPR).

Cooperation with processors and third parties

If, in the course of our processing, we disclose data to other persons and companies (order processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, is required for the performance of the contract pursuant to Art. 6 (1) lit. b GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called “order processing agreement”, this is done on the basis of Art. 28 GDPR.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this will only be done if it is done to fulfill our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the processing of data in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means, for example, that processing takes place on the basis of special guarantees, such as the officially recognized determination of a level of data protection that corresponds to that of the EU (e.g., for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

Rights of the data subjects

You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with Art. 15 GDPR.
You have accordingly Art. 16 GDPR the right to request the completion of the data concerning you or the correction of incorrect data concerning you.

In accordance with Article 17 of the GDPR, you have the right to demand that the data in question be deleted without delay or, alternatively, to demand restriction of the processing of the data in accordance with Article 18 of the GDPR.

You have the right to request to receive the data concerning you that you have provided to us in accordance with Article 20 of the GDPR and to request its transfer to other data controllers.

They also have pursuant to Article 77 GDPR the right to lodge a complaint with the competent supervisory authority.

Right of withdrawal

You have the right to withdraw consent granted pursuant to. Art. 7 par. 3 GDPR with effect for the future

Right of objection

You may object to the future processing of data concerning you in accordance with Art. 21 GDPR at any time. The objection can be made in particular against the processing for purposes of direct advertising.

Cookies and right to object to direct advertising

“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. The primary purpose of a cookie is to store information about a user (or the device on which the cookie is stored) during or after his visit within an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online store or a login status can be stored.
“Permanent” or “persistent” cookies are those that remain stored even after the browser is closed. For example, the login status can be saved when users visit them after several days. Likewise, such a cookie may store the interests of users, which are used for reach measurement or marketing purposes. Third-party cookies” are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).

We may use temporary and permanent cookies and explain this in our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies may lead to functional restrictions of this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of the services, especially in the case of tracking, via the U.S. site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by means of their deactivation in the browser settings. Please note that in this case not all functions of this online offer can be used.

Data deletion

The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 GDPR. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 Abs. 1 AO, 257 para. 1 No. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years according to § 257 para. 1 No. 2 and 3, para. 4 HGB (Commercial Letters).
According to legal requirements in Austria, the storage is carried out in particular for 7 years in accordance with § 132 para. 1 BAO (accounting records, vouchers/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real property, and for 10 years for records in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

Business processing

In addition, we process – contract data (e.g., subject matter of the contract, term, customer category).

  • Payment data (e.g. bank details, payment history)
    of our customers, prospective customers and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Contractual services

We process the data of our contractual partners and interested parties as well as other clients, customers, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. GDPR in order to provide them with our contractual or pre-contractual services. The data processed in this context, the type, scope and purpose and the necessity of their processing, are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).
As a matter of principle, we do not process special categories of personal data, unless these are components of a commissioned or contractual processing.
We process data that are necessary for the justification and fulfillment of the contractual services and point out the necessity of their indication, if this is not evident for the contractual partners. Disclosure to external persons or companies will only be made if it is required as part of a contract. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client and the legal requirements.
In the context of the use of our online services, we may store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the interests of users in protection against misuse and other unauthorized use. In principle, this data will not be passed on to third parties, unless it is necessary for the pursuit of our claims in accordance with the German Data Protection Act. Art. 6 par. 1 lit. f. GDPR is required or there is a legal obligation to do so pursuant to. Art. 6 par. 1 lit. c. GDPR.
The deletion of the data takes place when the data is no longer required for the fulfillment of contractual or legal duties of care as well as for dealing with any warranty and comparable obligations, whereby the necessity of the retention of the data is reviewed every three years; otherwise, the legal retention obligations apply.

Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. DSGVO. Customers, interested parties, business partners and website visitors are affected by the processing.
The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The cancellation of the data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.
In this context, we disclose or transmit data to the tax authorities, advisors, such as tax consultants or auditors, as well as other fee offices and payment service providers.
Furthermore, we store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. We store this data, which is mostly company-related, permanently.

Hosting and emailing

The hosting services used by us serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services, which we use for the purpose of operating this online offering.
In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with the German Data Protection Act. Art. 6 par. 1 lit. f GDPR in conjunction with. Art. 28 GDPR (conclusion of order processing contract).

Collection of access data and log files

We, respectively our hosting provider, collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.

This privacy policy is currently valid and has the status March 2021. Due to the further development of our website and the offers provided by us or due to changed legal or official requirements, it may become necessary to change this data protection declaration.

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