プライバシーポリシー

TERMS AND CONDITIONS AND PRIVACY POLICY

HUUM is determined to protect the privacy of its customers and business partners. Accordingly, we have prepared these Terms and Conditions and Privacy Policy principles addressing the collection, use, disclosure, transmission, modification, combination, restriction, deletion and storage (hereinafter processing) of personal data. Our activities on the Internet are consistent with all the relevant activities and applicable European Union legislation and the laws of the Republic of Estonia. Please take a moment to examine our Privacy Policy.

The controller of the processing activities described in this Privacy Policy is HUUM OÜ (registry code 12561761). In any matters covered by this data processing policy contact info@en.old.huum.ee.

Processing of personal data

We process the following types of personal data:

• personal data you have provided to us. For example, when you enter your contact data (incl. your name, personal identification code, postal address, telephone number, e-mail address, preferred method of contact) on our website, mobile app or elsewhere (for example, in a store);
• personal data generated as a result of ordinary communications (e.g. personal data submitted in written correspondence or via HUUM app in your mobile phone);
• personal data obviously disclosed by you (e.g. in HUUM social media);
• personal data generated when you use our services, e.g. when you make a purchase or place an order in our store and personal contact information or information about your purchasing preferences are stored (HUUM may ask you to voluntarily provide personal data and information in certain areas of the website. Such data may include your name, address, postal code, e-mail address, phone number and other data). We also collect personal data when applying for upgrades in our app;
• personal data generated as a result of visiting and using the website; For example, through the cookies when using the website (which are introduced by Cookiebot when visiting our website);
• similar personal data noted in this paragraph received from third parties;
• personal data created and combined by us (e.g. order history).
• personal such as your image and all your other personal data and activity that is visible in our video surveillance area (photo, video, audio).

Processing of other data

We also process impersonal data, i.e. data that cannot be linked to any one person (language preference, location, statistics of the use of heaters). We may also collect general data about customer behaviour on our website and HUUM app. This data is consolidated and used for providing useful information to our customers, and also for determining which parts of the website, products and services are the most attractive. Aggregated data are considered impersonal in this Privacy Policy.

Purpose and legal basis for process of personal data

We use the following grounds for processing personal data under the law:

Consent – we process personal data on the basis of consent in order to inform customers about HUUM product news, campaigns and upcoming events. Customers who do not want to receive newsletters or notifications of products that may interest them can remove themselves from the mailing list at any time. The withdrawal of consent does not influence the lawfulness of the data processing that took place on the basis of your consent before it was withdrawn. We process your personal data for the organisation of campaigns, including organisation of personalised and targeted campaigns, carrying out customer satisfaction surveys and measuring the effectiveness of marketing activities. We process you personal data for web analytics or analysis of information society services, to ensure the functioning of these channels, to improve them, to compile statistics and to analyse your behaviour and user experience and to provide a better and more personalised service.

We may process data about you based on your consent (e.g. the IP address, device information, location information) on the website and other information society services (e.g. self-service) through the use of cookies (i.e. little pieces of information saved by the browser on the hard disk of a computer or another device), or other similar technologies.

We use the processed data to be able to provide the Service and Products according to your habits, to ensure the best service quality; to inform you of content and make recommendations; to personalise advertisements, improve marketing efforts and to protect data. The collected data are also used to count visitors and record their usage habits.

We use session, permanent and advertising cookies. A session cookie is automatically deleted after each visit; permanent cookies will not be deleted in the case of repeated visits to our website and the websites of our partners that use advertising and third party cookies and are connected to our website. We do not control the emergence of these cookies, so you can get information about these cookies from the third parties.

With regard to cookies, visitors agree to their use on the website, in the settings of the information society service or in the web browser. Cookies are enabled in most web browsers. All the functions of the website may not be accessible to the visitor if some cookies are disabled. Enabling or disabling cookies and similar technologies is controlled by the visitor through their web browser settings, information society service settings and privacy enhancement platforms.

Contract – we process personal data to: take pre-contractual measures; identify the customer to the extent required by due diligence; fulfil our obligations to the customer in relation to the provision of our services (e.g. we use it to deliver Goods); to receive services debt collection services like security services, auditor services, IT services, marketing services and delivery services and to receive goods (e.g. components for heaters) for that we process of documents submitted by you containing personal data (e.g., invoices, transport documents, insurance), management and archiving of contracts with any personal data contained therein, processing of orders for products or services containing personal data, communicating with you regarding the performance of cooperation and any related amendments and much more; communicate with the customer and to ensure that the customer’s payment obligations are met;

Please note that the purpose of data processing may be additionally stipulated in the specific contract entered into with you.

For the purposes of entering into an reseller contract and fulfilling our legitimate interests, the processing of personal data of a reseller applicant comprises the following:

• the processing of data provided to us by the applicant for the purpose of entering into an reseller contract;
• the processing of personal data obtained from the person indicated by the reseller applicant as a reference;
• processing of personal data collected from public (social) media.
• In the event that the reseller applicant is not selected, we will keep the personal data collected for the purpose of entering into an reseller contract so that we can make a reseller offer to other possible reseller applicants when a suitable reseller becomes available.

Legitimate interest means our interest to manage the company and to provide the best possible Services and Products on the market. We process your personal data on the basis of a legitimate interest for the following purposes:

• to ensure a trusting customer relationship, which includes processing personal data to prevent fraud;
• for customer base management and analysis to improve the accessibility, selection and quality of the services, and to make the best and more personal offers with the consent of the Customer;
• for network, information and cyber security purposes, e.g. the measures taken to combat piracy and guarantee the security of the website, make and save backup copies;
• for organisational purposes. Primarily for financial management and transmission of personal data within the group for internal administrative purposes, including for processing the personal data of customers or employees;
• we may share personal data when we conclude business transactions or hold negotiations about a business transaction, which covers our entire business or the sale or transfer of property. These transactions may cover any merger, financing, acquisition or bankruptcy transaction or proceedings;
• for the establishment, exercising or defence of legal claims;
• if required, we will also use the data to send you special notifications regarding manufacturer-issued safety announcements and recalls;
• we use surveillance cameras in our shops. The use of cameras and the processing of recordings are for the purpose of protecting the property of employees, visitors and HUUM OÜ; ensuring security; defending and filing claims; resolving complaints and using the recordings as educational material. Recordings will be deleted after three months at the latest when the storage space is full.

We also process your personal data to comply with legal obligations. For example, legal obligations to process payments or comply with money laundering rules or accounting rules. In addition, we may be required by law to process the video recordings under the law for an investigative authority.

If personal data are processed for a purpose other than the purpose for which the personal data were collected, we will carefully analyse the possibility of such processing in accordance with data protection legislation (General Data Protection Regulation 2016/679, Article 6(4).)

Disclosure and/or transfer of personal data to third parties

To ensure better services for customers, HUUM has the right to share information about particular persons with third parties that provide services to HUUM or are resellers of HUUM products which may or may not use customized brands for their reselling activities. Third parties and resellers can, for example, be our partners who are responsible for transporting products sold in our shop or by a reseller, advertising and marketing partners; partners offering payment services; partners offering recruitment services; customer satisfaction polling companies, debt collection service providers, payment default registers, ICT partners, i.e. providers of various technical services, invoice transmission service providers. The transfer will only take place on the condition that the purpose of the transfer is lawful and the third party is processing the information on the basis of a contract in which, among other things, the third party undertakes to keep the shared information confidential.

We share your personal data within the group companies for organisational purposes, primarily for financial management and administrative purposes.

As a general rule, we don’t transmit personal data outside the European Economic Community. If we transmit personal data outside the European Union, we do it in compliance with the requirements of data protection legislation, e.g. if the European Commission has decided that adequate protection exists in the respective country, or we have taken adequate protection measures if such a decision does not exist (e.g. binding internal rules or standard data protection clauses).

Amendment of personal data processed and your rights

As a data subject, you have the following rights in relation to the processing of personal data:

• receive information about your personal data processed by us;
• access data, which covers your right to obtain a copy of the processed personal data;
• have incorrect personal data corrected;
• have data deleted:
  • if your personal data are no longer needed for the purpose for which we processed them;
  • if you withdraw your consent to the processing of your personal data and  we have  no other legal basis for processing your personal data;
  • if you object to the processing of personal data carried out by us on the basis of a legitimate interest, and we do not have any legitimate reasons for the processing that outweigh your interests, rights and freedoms, or for the purpose of preparing, presenting or defending our legal claims;
  • if you object to the processing of personal data carried out by us on the basis of your consent;
  • if we have processed your personal data unlawfully;
  • if your personal data have to be erased in order to fulfil a legal obligation prescribed by the law of the European Union or the Republic of Estonia applicable to us.
• request restriction of personal data processing:
  • during the period necessary to verify the accuracy of your personal data when submitting requests related to the accuracy of the data;
  • in the case of unlawful collection, storage or use of your personal data, if you decide not to request data deletion;
  • if we no longer needs your personal data, but you need them to prepare, present or defend legal claims;
  • during the period necessary to determine whether we have an overriding legal basis for continuing to process your personal data if you exercise your right to object to the processing of your personal data;
• transfer data, i.e. in certain cases, you have the right to obtain your personal data in machine-readable format, or demand their transmission in machine-readable format to another controller;
• obtain an opinion of a supervisory authority on whether the processing of your personal data is lawful;
• compensation for damage if the processing of your personal data has damaged you;
• rights related to automated processing, which means that you have the right to object to the processing of personal data concerning you at any time depending on the specific situation if such processing is based on automated decisions/profiling. You have the right to avoid any decisions based on automated processing of personal data, if they can be classified as profiling;
• file a complaint with us, the Data Protection Inspectorate or a court. The contact details of the Data Protection Inspectorate can be found on its website at https://www.aki.ee/et/inspektsioon-kontaktid/tootajate-kontaktid.

Protection of personal data

HUUM takes all precautions (incl. administrative, technical, and physical measures) to protect the customer’s personal data. Only authorised persons have access to personal data for making alterations and processing the same. We store personal data strictly for the minimum required period of time. We store personal data for up to five years from the date of the most recent servicing. When storing the data, we are also guided by the requirements of the Accounting Act.

Personal data whose retention term has passed will be destroyed or anonymised by using the best practices.

Security

The personal data of the Customer that have become known during their visits to HUUM webpage is regarded as confidential information. In the event of a personal data breach, we will take all necessary measures to mitigate its consequences and to address relevant risks in the future. We will register all incidents and, if required, inform the Data Protection Inspectorate and the data subjects. All data on the HUUM website, in our app and in our service database are protected and are considered confidential information.

Responsibilities

You are responsible for the preciseness, accuracy and completeness of the data provided to us. If the data you provide change, you must notify us immediately by e-mail. We are not liable under any circumstances for any damage caused to you due to submission to us of inaccurate or incomplete personal data, or your failure to notify of changes of submitted personal data.

Amendments of Terms and Conditions of and to Privacy Policy

Upon using our website, you confirm that you have read these terms and conditions and agree to them. We retain the right to make any necessary changes to the general terms and conditions of the Privacy Policy by giving notice on our website and by e-mail, if possible.

If you have any questions or concerns about this Privacy Policy or data processing, please contact info@en.old.huum.ee.

License

Unless otherwise stated, HUUM and/or its licensors own the intellectual property rights for all material on HUUM´s website. All intellectual property rights are reserved. You may access this from HUUM´s website for your own personal use subjected to restrictions set in these terms and conditions.

You must not:

• Republish material from HUUM´s website;
• Sell, rent or sub-license material from HUUM´s website;
• Reproduce, duplicate or copy material from HUUM´s website;
• Redistribute content from HUUM´s website.

This Agreement shall begin on the date hereof.

Parts of this website offer an opportunity for users to post and exchange opinions and information in certain areas of the website. HUUM OÜ does not filter, edit, publish or review comments prior to their presence on the website. Comments do not reflect the views and opinions of HUUM OÜ,its agents and/or affiliates. Comments reflect the views and opinions of the person who post their views and opinions. To the extent permitted by applicable laws, HUUM OÜ shall not be liable for the comments or for any liability, damages or expenses caused and/or suffered as a result of any use of and/or posting of and/or appearance of the comments on this website.

HUUM OÜ reserves the right to monitor all comments and to remove any comments which can be considered inappropriate, offensive or causes breach of these Terms and Conditions.

You warrant and represent that:

• You are entitled to post the comments on our website and have all necessary licenses and consents to do so;
• The comments do not invade any intellectual property right, including without limitation copyright, patent or trademark of any third party;
• The comments do not contain any defamatory, libelous, offensive, indecent or otherwise unlawful material which is an invasion of privacy
• The comments will not be used to solicit or promote business or custom or present commercial activities or unlawful activity.

You hereby grant HUUM OÜ a non-exclusive license to use, reproduce, edit and authorize others to use, reproduce and edit any of your Comments in any and all forms, formats or media.

Hyperlinking to our Content

The following organizations may link to our website without prior written approval:

• Government agencies;
• Search engines;
• News organizations;
• Online directory distributors may link to our website in the same manner as they hyperlink to the websites of other listed businesses; and
• System wide Accredited Businesses except soliciting non-profit organizations, charity shopping malls, and charity fundraising groups which may not hyperlink to our website.

These organizations may link to our home page, to publications or to other website information so long as the link: (a) is not in any way deceptive; (b) does not falsely imply sponsorship, endorsement or approval of the linking party and its products and/or services; and (c) fits within the context of the linking party’s site.

We may consider and approve other link requests from the following types of organizations:

• commonly-known consumer and/or business information sources;
• dot.com community sites;
• associations or other groups representing charities;
• online directory distributors;
• internet portals;
• accounting, law and consulting firms; and
• educational institutions and trade associations.

We will approve link requests from these organizations if we decide that: (a) the link would not make us look unfavorably to ourselves or to our accredited businesses; (b) the organization does not have any negative records with us; (c) the benefit to us from the visibility of the hyperlink compensates the absence of HUUM OÜ; and (d) the link is in the context of general resource information.

These organizations may link to our home page so long as the link: (a) is not in any way deceptive; (b) does not falsely imply sponsorship, endorsement or approval of the linking party and its products or services; and (c) fits within the context of the linking party’s site.

If you are one of the organizations listed in paragraph 2 above and are interested in linking to our website, you must inform us by sending an e-mail to HUUM OÜ. Please include your name, your organization name, contact information as well as the URL of your site, a list of any URLs from which you intend to link to our website, and a list of the URLs on our site to which you would like to link. Wait 2-3 weeks for a response.

Approved organizations may hyperlink to our website as follows:

• By use of our corporate name; or
• By use of the uniform resource locator being linked to; or
• By use of any other description of our website being linked to that makes sense within the context and format of content on the linking party’s site.

No use of HUUM‘s logo or other artwork will be allowed for linking absent a trademark license agreement.

iFrames

Without prior approval and written permission, you may not create frames around our webpages that alter in any way the visual presentation or appearance of our website.

Content Liability

We shall not be hold responsible for any content that appears on your website. You agree to protect and defend us against all claims that is rising on your website. No link(s) should appear on any website that may be interpreted as libelous, obscene or criminal, or which infringes, otherwise violates, or advocates the infringement or other violation of, any third party rights.

Reservation of Rights

We reserve the right to request that you remove all links or any particular link to our website. You approve to immediately remove all links to our website upon request. We also reserve the right to amend these terms and conditions and it’s linking policy at any time. By continuously linking to our website, you agree to be bound to and follow these linking terms and conditions.

Removal of links from our website

If you find any link on our website that is offensive for any reason, you are free to contact and inform us any moment. We will consider requests to remove links but we are not obligated to or so or to respond to you directly.

We do not ensure that the information on this website is correct, we do not warrant its completeness or accuracy; nor do we promise to ensure that the website remains available or that the material on the website is kept up to date.

Disclaimer

To the maximum extent permitted by applicable law, we exclude all representations, warranties and conditions relating to our website and the use of this website. Nothing in this disclaimer will:

• limit or exclude our or your liability for death or personal injury;
• limit or exclude our or your liability for fraud or fraudulent misrepresentation;
• limit any of our or your liabilities in any way that is not permitted under applicable law; or
• exclude any of our or your liabilities that may not be excluded under applicable law.

The limitations and prohibitions of liability set in this Section and elsewhere in this disclaimer: (a) are subject to the preceding paragraph; and (b) govern all liabilities arising under the disclaimer, including liabilities arising in contract, in tort and for breach of statutory duty.

As long as the website and the information and services on the website are provided free of charge, we will not be liable for any loss or damage of any nature.

These Terms and Conditions and Privacy Policy were last amended in March 2023.