Data security

Data security

1. General provisions

1.1. These data protection conditions regulate the principles of personal data collection, processing, and storage. The personal data responsible processor is Brightspark OÜ (hereinafter referred to as the data processor).
1.2. The data subject, for the purposes of data protection conditions, is the customer or another natural person whose personal data the data processor processes.
1.3. The customer, for the purposes of data protection conditions, is anyone who purchases the company’s services through the data processor’s website.
1.4. The data processor follows the principles of data processing as set forth in the legislation, including processing personal data lawfully, fairly, and securely. The data processor can confirm that personal data has been processed in accordance with the provisions of the law.

2.Personal data collection, processing, and storage

2.1. Personal data that the data processor collects, processes, and stores are collected electronically, primarily through the website and email.
2.2. By sharing their personal data, the data subject grants the data processor the right to collect, arrange, use, and manage the personal data for the purpose defined in the data protection conditions, which the data subject shares directly or indirectly with the data processor when purchasing services on the website.
2.3. The data subject is responsible for ensuring that the submitted data is accurate, correct, and complete. The deliberate submission of false information is considered a breach of data protection conditions. The data subject is obliged to inform the data processor immediately of any changes to the submitted data.
2.4. The data processor is not responsible for any damage caused to the data subject or third parties by the submission of false information by the data subject.

3. Processing of customers’ personal data

3.1. The data processor may process the following personal data of the data subject:

3.1.1. first and last name;
3.1.2. date of birth;
3.1.3. phone number;
3.1.4. e-mail address;
3.1.5. billing account number.

3.2. In addition to the above, the data processor has the right to collect data about the client, which is available in public registers (e.g., the personal identification code of the official representative of a legal entity).
3.3. The legal basis for personal data processing is Article 6(1)(a), (b), (c), and (f) of the General Data Protection Regulation:

3.3.1. the data subject has given consent to the processing of their personal data for one or more specific purposes;
3.3.2. the processing of personal data is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract;
3.3.3. the processing of personal data is necessary for compliance with a legal obligation to which the data controller is subject;
3.3.4. the processing of personal data is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

3.4. Processing of personal data according to the processing purpose:

3.4.1. Processing purpose – security and safety
Maximum storage time of personal data – according to the deadlines specified by law
3.4.2. Processing purpose – responding to an information request
Maximum storage time of personal data – stored in the sales software until the end of the sales process (the end of the sales process is fixed by the data subject’s written refusal)
3.4.3. Processing purpose – ensuring the functioning of services
Maximum storage time of personal data – stored in the sales software until the full fulfillment of obligations set out in the contract related to the data subject
3.4.4. Processing purpose – customer management and marketing
Maximum storage time of personal data – stored in the sales software from the first contact with the data subject until their written request for data removal
3.4.5. Processing purpose – financial activity, accounting
Maximum storage time of personal data – according to the deadlines specified by law
3.4.6. Processing purpose – personnell management and recruitment
Maximum storage time of personal data – during the employment relationship

3.5. The data processor has the right to share customers’ personal data with third parties, such as authorized data processors, accountants, transport and courier companies, companies providing transfer services. The data processor is the personal data responsible processor.
3.6. In the processing and storage of the data subject’s personal data, the data processor applies organizational and technical measures that ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.
3.7. The data processor stores data subjects’ data depending on the purpose of processing, but not longer than 10 years.

4. Data subject’s rights

4.1. The data subject has the right to inquire about personal data collected about them.
4.2. The data subject has the right to receive information about the processing of their personal data.
4.3. The data subject has the right to supplement or correct inaccurate data.
4.4. If the data processor processes the data subject’s personal data based on the data subject’s consent, then the data subject has the right to withdraw consent at any time.
4.5. The data subject can contact the online store’s customer support at info@brightspark.ee to exercise their rights.
4.6. The data subject also has the option to file a complaint with the Data Protection Inspectorate to protect their rights.

5. Final provisions

5.1. These data protection conditions have been prepared in accordance with the European Parliament and Council Regulation (EU) No. 2016/679 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 Personal Data Protection Act of the Republic of Estonia, and other legislation of the Republic of Estonia and the European Union.
5.2. The data processor has the right to partially or completely change the data protection conditions, notifying the data subjects of the changes through the website https://lexi.market .