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This policy regarding the collection and processing of personal data (the “Privacy Policy”) describes how COLUMBUS EESTI AS, SIDURI TN 3, TALLINN, ESTONIA, 11314 (“we”, “us” “our”, or “Columbus”) process personal data. By the Privacy Policy we fulfill our duty to inform your as a data subject regarding our processing of your personal data.  

 

Collection and processing of Personal Data

When you visit and use our website, we process personal data about you by using cookies. We use this data to improve our website, the user experience and to perform customer support and targeted advertising.

 

We also process your personal data when you use functions on our website such as signing up for one of our newsletters or webinars, logging on to Columbus Care and sending us data or request information about one or more of our services. When you or your organization enter into agreement with us regarding delivery of our services - hereunder products and software - and when you choose to provide some or all of the following data or other personal data: Your user name, password, email address, first name, surname, job position, company name, phone number. We also process your personal data when open an email from us or click a link contained in an email, when you want to receive news or newsletters from us, as well as when you provide your own description of how we may help you and when sending us a message through our contact information.

 

If you tell us that you do not want us to use your data to make further contact with you, beyond fulfilling your request, we will respect your wishes.

In addition, some of our software products include technologies that allow us to collect certain information about product use. We may also use such technologies to determine whether you have opened an e-mail or clicked on a link contained in an e-mail. Collecting information in this manner allows us to collect statistics about the usage and effectiveness of our website, to personalize your experience and to tailor our interactions with you.

 

From time to time, we may also collect personal data that pertains to you indirectly through other sources, such as suppliers or your organization. When we do so, we ask the supplier to confirm that this third party has legally acquired the personal data and that we have the right to obtain it from them and use it. The personal data that we collect, either directly or indirectly, may be combined to help us improve its overall accuracy and completeness and to help us better tailor our interactions with you. The personal data we process will normally be of non-sensitive nature.

The following sections describe in more detail how and for what purposes we may use your personal data.

Providing our products and services: If you request something from Columbus e.g. a product or service, a call back, or specific marketing materials, we will use the data you provide to fulfil your request. To help us do this, we may share the personal data with others, for instance, our business partners, financial institutions, shipping companies, or postal or government authorities, such as Customs authorities, involved in the fulfilment of your request. In connection with a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes.

 

Personalizing your experience on our website: We may use personal data we collect about you to provide you with a personalized experience on our website, such as providing you with content in which you may be interested in and making navigation on our sites easier.

 

Marketing: The personal data you provide to Columbus, we may use for direct marketing purposes. Before we do so, however, we will ensure that either we have obtained your specific consent to have your personal data used in this way or that it is necessary for the purposes of the basis legitimate interest pursued by us in securing delivery of our products and services cf. GDPR article 6(1)f. For all the personal data collected about you indirectly or from third party to be used for direct marketing purposes, we will ensure that we have obtained your specific consent to have your personal data used in this way.You may at any time choose not to receive marketing materials from us by following the unsubscribe instructions included in each e-mail you may receive, by indicating so when we contact you, or by contacting us (see 'Contact Us' section at the end of the page) directly.

 

Profile: We store data that we collect through cookies, log files, clear gifs, and/or third party sources to create a “profile” of your preferences. We do tie your personally identifiable information to information in the profile, in order to provide tailored promotions and marketing offers and to improve the content of the site for you. We do not share your profile with other third parties.

 

Information Sharing and Disclosure:

We do not otherwise share your personal data with third parties. Except for the requirement to disclose your personal data as required by law and / or when we reasonably believe that disclosure is necessary in order to: Protect the rights or property of Columbus, our business partners, suppliers, customers, or others when we have reasonable grounds to believe that such rights or property have been or could be affected. In addition, we reserve the right to disclose your personal data as required by law and when we believe that disclosure is necessary to protect our rights or the rights of others, or to comply with a judicial proceeding, court order, or legal process served on our website.

 

Mobile Apps and Use of Personal data in relation to Social Media:

Columbus may make available mobile applications for download from various mobile application marketplaces. We may also provide social computing tools directly or indirectly to enable online sharing and collaboration among members who have registered to use them. These may include forums, wikis, blogs and other social media platforms.

When downloading and using these applications or registering to use these social computing tools, you may be asked to provide certain personal data. Registration of personal data will be subject to and protected in accordance with this Privacy Policy, except for the personal data that is automatically made available to other participants as part of your profile.

These applications and tools may also include supplemental privacy statements with specific personal data about collection and handling practices. Read those supplemental statements to understand what the tools and applications may do. Any other content you post, such as pictures, information, opinions, or any other type of personal data that you make available to other participants on these social platforms or applications, is not subject to this Privacy Policy. Rather, such content is subject to the Terms of Use of those applications or platforms, and any additional guidelines and privacy information provided in relation to their use, as well as the process by which you can remove your content from such tools or get help to do so.

Please refer to them to understand better yours, ours, and other parties' rights and obligations with regard to such content. You should be aware that the content you post on any such social computing platforms might be made broadly available to others inside and outside Columbus.

 

Legal Basis for Processing of Personal Data

When you visit our website, the basis for the processing of your personal data is that it is necessary for us in order to pursue our legitimate interests in improving our website and customer experience. Cf. 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 (General Data Protection Regulation) which entered into force on 24 May 2016 and will apply from 25 May 2018 (“GDPR”), article 6(1)f.

When we process personal data in order to provide our products and services the basis for the processing can be that it is necessary for the performance of a contract where you are a party. Cf. GDPR article 6(1)b. Alternatively, it is necessary for the purposes of the basis legitimate interest pursued by us in securing delivery of our products and services cf. GDPR article 6(1)f.

If we process sensitive personal data (so-called “special categories of personal data”), our processing will be based on your prior explicit consent hereto, In accordance with GDPR, article 9(2)b. Alternatively, because it is necessary to establish, exercise or defend legal claims, cf. GDPR, article 9(2)f, or if the processing relates to data which are manifestly made public by you, cf. GDPR, article 9(2)e.

In addition to the above, we may process your personal data for tracking and profiling for purposes of direct marketing, behavioral advertisement, location-based advertising and/or tracking-based digital market research. In these cases, the basis for this processing is GDPR, article 6(1)a, or article 9(1)a.

We do not believe our site is appealing to children, nor is it directed to children under 16. We do not knowingly collect personal data from persons under the age of 16. If you are a parent of a child under 16, and you believe that, your child has provided us with information about him or herself, please contact us (see 'Contact Us' section at the end of the page).

 

Cookies

This processing of collecting and using of cookies is based on directive 2002/58/EC, article 5(3), as amended and transposed into national legislation. In the case that a cookie has the sole purpose of carrying out communication over an electronic communications network or is strictly necessary for the provision of a service on our website requested by you, and only to the greatest extent permissible by law, the legal basis for the processing of personal data ‘contained’ in a cookie is the relevant provision of the GDPR as otherwise described in this section. 

See the section below for a description of the legal basis for transfer of personal data to countries outside the EU/EEU.

 

Group Transfers and International Transfers

Columbus is part of a global organization with business processes, management structures and technical systems that cross borders. As such, we may share personal data about you within the Columbus Group and transfer it to countries in the world where we do business in connection with the uses identified above and in accordance with this Privacy Policy. Our Privacy Policy and our practices are designed to provide a globally consistent level of protection for personal data all over the world. This means that even in countries whose laws provide for less protection for your personal data, we will still handle your personal data in the manner described here.

In some cases, we use suppliers located in various countries to collect, use, analyze, and otherwise process personal data on our behalf. These suppliers are called data processors. It is our practice to require such data processors to handle personal data in a manner consistent with our policies. We also engage with other businesses, which cannot be considered data processors, to deliver our services. These businesses are data controllers and include, for example, postal services and logistics companies We share information with such parties if necessary. Such parties can be located inside or outside the EU/EEA.

 

We may transfer your personal data to so-called “third-countries” outside the EU/EEA, including the United States, Switzerland, India and Russia. Such transfers are based on either the standard contractual clauses of the European Commission, adequacy decisions from the European Commission, the recipients’ self-certifications under the EU-U.S. and/or Swiss-U.S. Privacy Shield Frameworks or another applicable legal basis for such transfer.

Please contact us (see 'Contact Us' section at the end of the page) if you have questions on our use of data processors, engagement of other data controllers or transfer to third countries, including any requests of documentation of the necessary levels of data protection. Find our contact information at the end of this Privacy Policy.

 

Your Rights as a Data Subject

You have a number of rights regarding personal data relating to you. Columbus is committed to helping you with exercising your rights as an individual. To do so, please contact us (see 'Contact Us' section at the end of the page)These rights include:

  1. to know what personal data we process about you, for what purposes we process it, and whether we disclose the data to others;
  2. to rectify your personal data if it is incorrect;
  3. in certain cases, to have some or all of your personal data deleted;
  4. in certain cases, to have the processing of your personal data restricted to storage;
  5. to transmit or receive the personal data concerning you, which you have provided to us, when the legal basis for the processing is your consent or a contract with you, unless it is a matter covered by the GDPR, article 20(3) or (4) (so-called data portability);
  6. in certain cases and on grounds relating to your particular situation, to object at any time to the processing of your personal data;
  7. to withdraw any consent that you have given to the processing of your personal data, without affecting the lawfulness of processing based on consent before its withdrawal;
  8. to lodge a complaint with a supervisory authority: or
  9. not to be subject to a decision based solely on automated processing, which produces legal effects concerning you or similarly significantly affecting you, unless the decision is necessary for entering into or performing in accordance with a contract between you and us, or the decision is authorized by Union or Member State law to which we are subject, or the decision is based on your explicit consent.

 

Business Transitions

In the event Columbus goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, the possibility and legal basis to process your personal data may be among the assets transferred. We will provide you prominent notice on our website for 30 days about any such change in ownership or control of your personal data.

 

Information Security and Accuracy

We endeavor to protect your personal data and to maintain its accuracy and in order to do so we implement reasonable physical, administrative and technical safeguards to protect the personal data submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however, therefore, while we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. At the same time, we encourage you to use caution when disclosing personal data online. If you have any questions about security on our website, please contact us (see 'Contact Us' section at the end of the page).

 

Retention

We will retain the personal data you provide to us for 24 months or for as long as the personal data is required to fulfil your request, except when we are allowed or required to do otherwise by law. If you wish to request that, we no longer use your personal data, please contact us (see 'Contact Us' section at the end of the page). We reserve the right to retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

Cookies and Other Technologies

Log Files: We gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit webpages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole. We do link this automatically collected data to personally identifiable information.

We use a third-party tracking service that uses log files to track non-personally identifiable information about visitors to our site in the aggregate.

 

Cookies: A cookie is a small text file that is stored on a user's computer for record-keeping purposes. We use cookies on this site. Cookies are typically categorized as "session" cookies or "persistent" cookies. Session cookies help you navigate through the website efficiently, keeping track of your progression from page to page so that we do not ask for information you have already provided during the current visit. Session cookies are stored in temporary memory and erased when the web browser is closed. Persistent cookies, on the other hand, store user preferences for current and successive visits. They are written on your device's hard disk, and are still valid when you restart your browser. We use session ID cookies. We do not use persistent cookies. If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as contests or surveys, will be limited.  Some of our business partners may use cookies on their sites. We have no access to or control over these cookies. This Privacy Policy covers the use of cookies by Columbus only; it does not cover the use of cookies by any advertisers.

 

Links to Other Sites

The Columbus website may contain links to other sites that Columbus do not own or control. Please be aware that Columbus is not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of every website that collects personal data. This Privacy Policy applies only to personal data collected by this website.

 

Changes to this Privacy Policy

We will not reduce your rights under this Privacy Policy without your consent. We reserve, however, the right to modify this Privacy Policy at any time, so please review it frequently. If we decide to change our Privacy Policy, we will communicate this at our website, by e-mail or by other communication means.

 

Complaints 

You have the right to make a complaint at any time to the Competent Supervisory Authority in our jurisdiction. However, we would appreciate the chance to deal with your concerns before you approach the Competent Supervisory Authority in our jurisdiction, so please contact us (see 'Contact Us' section at the end of the page) in the first instance.

 

Contact Us

If you have a question about this Privacy Policy or our handling of your personal data, please Contact Us. If you no longer wish to receive marketing e-mails from Columbus, please follow the unsubscribe instructions included in the marketing email.