Approved on

[February 2th, 2023]

Osaühing Ikov Tõlkebüroo (hereinafter Ikov Translation Agency) adheres to the requirements and principles set out in this Policy. Ikov Translation Agency considers the privacy of individuals and personal data protection important and, therefore, has developed this Privacy Policy that provides for the purposes, terms and conditions of personal data processing and rights relating to the personal data of data subjects. Ikov Translation Agency guarantees the lawfulness of personal data processing.

1. Terms and definitions

1.1. Personal data means any information relating to an identified or identifiable natural person (‘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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1.2. Processing means any operation or set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

1.3. Controller means the natural or legal person, public or local government authority being the original collector of personal data. The controller determines the purposes and means of the processing of personal data.

1.4. Processor means a natural or legal person, public or local government authority that processes personal data on behalf of and on instructions from the controller.

1.5. Third party means a natural or legal person, public or local government authority, agency or body.

1.6. Personal data breach means a breach leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

1.7. Data subject means a person whose personal data are processed.

2. Principles

2.1. When processing personal data, Ikov Translation Agency follows the following principles.

2.1.1. The principle of lawfulness, fairness and transparency – personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject.

2.1.2. The principle of purpose limitation – personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

2.1.3. The principle of data minimization – personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

2.1.4. The principle of accuracy – personal data shall be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.

2.1.5. The principle of storage limitation – personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

2.1.6. The principle of integrity and confidentiality – personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

3. Security of processing

3.1. Following the principle of reasonableness, Ikov Translation Agency applies different organizational, physical and information technology security measures to protect personal data.

3.2. Ikov Translation Agency may, in certain cases, use processors for the processing and provision of services. Ikov Translation Agency ensures that processors process personal data on instructions from Ikov Translation Agency and in accordance with applicable law as well as take relevant security measures. Confidentiality agreements have been entered into with any and all processors.

3.3. Ikov Translation Agency immediately notifies data subjects of any personal data breaches.

4. Categories of personal data

4.1. Ikov Translation Agency processes personal data obtained directly from data subjects and personal data obtained in the course of the provision of services, which are considered the Services and/or any other services that might be provided by Ikov Translation Agency (hereinafter collectively or individually referred to as “Services”). Ikov Translation Agency does not collect, store, analyze or use personal data arising from the Services for purposes other than the Services and generating a Customer database.

4.2. Ikov Translation Agency is a controller of personal data and adheres to the principles of ensuring the confidentiality of personal data to guarantee the privacy rights of individuals.

4.3. Persons authorized by Ikov Translation Agency only have access to personal data to alter and process the data.

5. Purposes of processing

5.1. Ikov Translation Agency processes personal data to perform an agreement and ensure performance thereof.

6. Third parties, authorized persons and cross-border transmission of personal data

6.1. Proceeding from the purposes strictly limited to necessity, Ikov Translation Agency may transmit personal data to third parties and authorized persons for the following objective:

6.1.1. to perform the Services agreed (to provide the service).

6.2. Due to the nature and language combinations of the Services, there may be situations requiring the cross-border transmission of personal data (personal data arising from the Services) to partners.

6.3. Ikov Translation Agency confirms that they apply appropriate security measures to cross-border transmission of personal data.

6.4. Ikov Translation Agency confirms that they only transmit personal data to such third parties and processors that apply adequate security measures to ensure the security of protection of personal data.

7. Rights of data subjects

7.1. Data subjects have the right to have their personal data erased.

7.2. Data subjects have the right to make inquiries concerning their personal data that they have submitted to Ikov Translation Agency.

7.3. Data subjects have the right to restrict the processing of their personal data.

7.4. Data subjects have the right to lodge a complaint about the processing of personal data with the Data Protection Inspectorate.

8. Storage of personal data

8.1. Ikov Translation Agency keeps personal data in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed, unless Ikov Translation Agency has to comply with a requirement arising from law providing for different terms of storing personal data.

8.2. Ikov Translation Agency will destroy and/or erase securely any personal data with no purpose for storage after one year has passed from the provision of the service, unless otherwise agreed between the recipient of the service and Ikov Translation Agency.

9. Use of cookies

9.1. The website managed by Ikov Translation Agency may use cookies to make the user experience more convenient and the use of the website smoother.

9.2. A cookie is a small text file automatically saved by the web browser in the device used by the person. Cookies are used to:

9.2.1. collect anonymous and generalized statistics regarding the number of visitors of the website and information about the manner of using the website in order to make the website even more user-friendly and convenient.

9.3. Cookies saved in the device can be blocked by not agreeing to the use of cookies. To this end, the respective settings of the web browser must be changed. Web pages might not work properly and some of the services might be unavailable if cookies are not allowed.

10. Amendments to Privacy Policy

10.1. Ikov Translation Agency considers the privacy of individuals important and, therefore, Ikov Translation Agency updates this Privacy Policy on a regular basis. The latest version of the Privacy Policy is always available on the website.

11. Contact details

11.1. If you have any questions, concerns or proposals concerning the processing of personal data, you can contact the controller, using the following contacts details:

Ikov OÜ
+372 5687 6845