Introduction

The Privacy Policy of AS DBT has been developed pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

The Privacy Policy of AS DBT was developed by a working group formed by the management.

Thank you for familiarizing yourself with the Privacy Policy of AS DBT (registry code 10237594, legal address: Koorma 7b, 74004, Muuga, Republic of Estonia) (controller).

AS DBT lawfully treats personal data received from its customers/clients, suppliers, co-operation partners and other interested parties and ensures the protection and secure processing of such personal data.

In this Privacy Policy, we describe how AS DBT processes your personal data when you contact us, enter into contracts with us, apply for a job in our company, visit our terminals or visit our websites.

Please read the Privacy Policy carefully. AS DBT may make changes to the Privacy Policy. The current Privacy Policy is published on AS DBT website: www.dbt.eu.

If you have any questions, please do not hesitate to contact AS DBT using the contact details provided in the section Contact.

What personal data does AS DBT process?

The personal data we process about you may include:

• first and last name;
• personal identification code or date of birth;
• details of the identity document;
• contact details (address, e-mail, phone number);
• job position;
• information related to the conclusion and performance of the contract (name, personal identification code, contact details, payment information or other information provided in the contract regarding the representative of the legal person signing the contract);
• information published by you in your CV and / or CV cover letter;
• the information regarding the vehicle you enter into the terminals’ area (vehicle mark, model or other information provided in the contract);
• security cameras’ recordings;
• any other information you have published when you contact AS DBT.

Source of personal data processed by AS DBT

AS DBT will receive your personal data when you, your employer, or any third party discloses it to AS DBT in a cooperative relationship or otherwise by contacting AS DBT. Also when you enter the territories administered by AS DBT. AS DBT also obtains your personal data from other sources, such as public databases.

For what purposes do we process your personal data?

We use security cameras in the terminals and offices of AS DBT to ensure the protection of persons and property and to ensure security while staying in the terminals’ territories.

We process personal data for purposes of pre-contractual negotiation, conclusion and performance of the contract, including, for example, when you contact AS DBT to provide or receive a service, deliver goods or apply for employment. We also process your personal data to give you access to the Muuga and Sillamäe terminals.

In addition, we process personal data to conduct customer satisfaction surveys and to improve the quality and availability and choice of services.

AS DBT also processes personal data in order to fulfill its legal obligations.

Legal basis for the processing of personal data

AS DBT processes your personal data for the purpose of concluding a client, cooperation, employment or service agreement and for the use of the services provided by AS DBT under and in accordance with the agreement concluded between AS DBT and you or your employer.

AS DBT may also process your personal data on the basis of a legitimate interest of AS DBT. Such legitimate interest is to improve the quality and availability and choice of AS DBT services.

The legal basis for the use of security cameras and recordings is the legitimate interest of AS DBT for protection and ensuring security of the employees, members of the management board, members of the supervisory board, owners, clients, partners, suppliers, service providers, guests, representatives of third parties – legal persons or natural persons and their property.

In addition, AS DBT may process your personal data in order to fulfill its legal obligations.

To whom does AS DBT disclose personal information?

AS DBT may grant access to personal data to an authority or a person having the legal right to do so (Police, Tax and Customs Board, Data Protection Inspectorate and other statutory public institutions).

In addition, AS DBT may grant access to your personal data to AS DBT authorized processors, without whose services AS DBT will not be able to fulfill its obligations. AS DBT has contractual relationships with third parties to provide, inter alia, the following services: security services, logistics services, IT services.

AS DBT may disclose your personal data in connection with the transfer of the company, for example in the course of restructuring, merger, sale, etc. Also within the group, including to third countries under standard contractual clauses.

Retention of personal data

AS DBT will retain your personal data in a form that identifies you only as long as it is reasonably necessary for the purpose of collecting the personal data or justified by the legitimate interest of AS DBT, provided that AS DBT’s legitimate interest and interference with the data subject’s rights and freedoms is balanced.

When storing personal data, we will observe, among other things, the following deadlines:

• the data collected for the conclusion of the contract shall be kept for 7 years;
• the original accounting records shall be kept for 7 years;
• we will keep records of security cameras for a maximum of 3 months;
• data of candidates who have not been elected to the position in AS DBT shall be retained for one year from the date of the denial decision;
• data collected from queries made through the website will be retained for 1 year.

After the expiry of the retention period, paper-based personal data shall be destroyed and electronic personal data deleted. If you would like further information on the retention periods applicable to personal data stored about you, please contact us using the contact details in the “Contacts” section.

Your rights regarding your personal data

AS DBT guarantees to the data subjects all rights arising from the applicable legislation. You have the following rights in connection with processing your personal data:

• the right of access to the data, which means that you have the right to ask at any time whether AS DBT has personal data about you and the right to receive information about what personal data concerning you is processed by AS DBT;
• the right to rectify personal data, which means that you have the right to ask AS DBT to clarify or correct your personal data if it is inadequate, incomplete or incorrect;
• the right to object, which means that you have the right to present the objection to the processing of your personal data by AS DBT;
• the right to demand the deletion of personal data, which means that you have the right to request the removal of your personal data by AS DBT, for example when personal data is processed with your consent and you have withdrawn your consent;
• the right to withdraw your consent to the processing of personal data if the processing of personal data is based on your consent;
• the right to lodge a complaint with the supervisory authority, which means that if you find that your rights with regard to the processing of your personal data have been violated, you can submit a complaint to the Data Protection Inspectorate by e-mail: in**@*ki.ee.

Please note that the rights listed in this chapter are not unlimited. In certain cases, your rights may be limited by the rights of other data subjects, the legitimate interests of AS DBT, and the legal obligations of AS DBT.

To exercise your rights regarding the processing of personal data or to submit applications for the processing of personal data, please contact us using the contact details provided on the “Contacts” section on our website. We will always try to respond to your requests and questions as quickly as possible.

The Terms of Privacy shall be governed by the laws of the Republic of Estonia.

If you have any questions about this Privacy Policy, questions about how AS DBT processes your personal data, or if you would like to submit requests/applications regarding the processing of your personal data, please contact AS DBT by email, telephone or mail at the following contacts:

AS DBT
Address: Koorma 7b, Muuga küla, Viimsi vald, Harju maakond 74004 ESTONIA
Phone: 664 6500
E-mail: info[at]dbt.eu