- Postimees Grupp – company AS Postimees Grupp, registry code 10184643, location Tartu mnt 80, Tallinn 10112. Customer support phone: 666 2525 (Mon-Fri 8-17, Sat 8-12) and e-mail: email@example.com.
- Subscriber - a natural or legal person who has subscribed to the publications of Postimees Grupp and/or to a newsletter.
- Subscription - a contract of purchase and sale concluded between Postimees Grupp and the subscriber, which stipulates a subscription of a paper and/or digital product.
- User - a user of the web environment of Postimees Grupp and/or a subscriber of a publication.
- User account - a user account for all media portals of Postimees Grupp.
- Publication - a paper product or digital product issued by Postimees Grupp.
- Paper product - a publication the content of which is available on paper with regularly published daily, weekly or other Summaries.
- Digital product - a publication the content of which is available in digital form with regularly published daily, weekly or other Summaries.
- Summaries - part of the Digital Product and Paper Product, which Postimees Grupp uses to provide to Subscribers its media content in summarized form in order to make news and other content quickly and aptly available. Summaries may be made available by sending them to the postal or e-mail address provided by a Subscriber. A Subscriber always has the right to request to receive various thematic as well as regional Summaries. If a Subscriber does not want to receive Summaries, they should contact Postimees Group.
- Advertisement - an advertisement appearing in a paper newspaper of Postimees Grupp.
- General terms - these terms for the use of the web page and for subscribing to publications.
2.1 The general terms apply to all users.
2.2 Postimees Grupp has the right to amend the general terms. The amended general terms come into force with the publication of the updated terms in the web environment of Postimees Grupp www.postimees.ee/tingimused.
2.3 Postimees Grupp has the right to change the subscription price after a reasonable notice time. Subscribers are notified of a price change via various channels: in a paper newspaper, by e-mail, by SMS. Changed subscription prices take effect at the beginning of the next subscription period after the price change date.
2.4 Postimees Grupp has the right to partially or fully suspend or terminate the publishing of a publication. In the case Postimees Grupp decides to suspend or terminate a publication, the advance payment paid by the subscriber is returned to them.
2.5 Postimees Grupp does not guarantee the fulfilment of a subscription and may suspend or terminate the subscription if:
- the information provided by the subscriber is incorrect and/or inaccurate;
- the subscriber’s mailbox does not meet the requirements of section 2.2;
- the subscriber does not pay the agreed subscription fee by the payment deadline;
- the subscriber is in breach of other requirements set out in the general terms.
3.1 Access to paid content of digital products is provided via a user account immediately after the subscription has been paid for and/or from the date specified as the start of the subscription. For details on how to create and use a user account, see section 4.
3.2 A subscription paid by a standing order is automatically renewed at the end of each subscription period, unless the subscriber cancels the subscription before the end of the current subscription period. The duration of the new subscription period and the terms of payment will be derived from the previous subscription period, unless it is a promotional offer, the price and duration of which are determined separately.
3.3 In the case of a one (1) month subscription paid by a standing order, it is possible to change the package without canceling the subscription. When exchanging a package for a higher priced one, the package will be exchanged immediately, but the price will change on the next payment date.
3.4 A subscription paid by a standing order can be canceled from the user account under “My subscriptions” or via customer support. If you cancel a subscription, it will last until the end of the prepaid period and the advance payment will not be refunded.
3.5 Programmes/series may have geographical viewing restrictions, meaning that the producer of a programme/series has granted the right to show it only on Estonian territory. The geographical restrictions also extend to subscribers.
3.6 The 14-day right to withdrawal does not apply to agreements whose object is the delivery of digital content that is not delivered on a physical data medium.
3.7 Upon the due date of the subscription, Postimees Grupp forwards to the subscriber a new invoice/quote to enable the subscriber to proceed conveniently with the subscription. If the subscriber has expressed a wish to not receive offers, no new offer will be sent.
4.1 When signing up for the web environment of Postimees Grupp, you must specify a user name (e-mail address) and a password.
4.2 The e-mail address used as the user name must be in real use in order for us to be able to send important messages
4.3 The user name and password are confidential information that cannot be released to third parties.
4.4 The user has the right to use digital products only with a personal user name and password..
4.5 Postimees Grupp has the right to request that the password of a user account be changed when a violation of the general terms is detected, to restrict access to digital products and/or to terminate the subscription.
5.1 Postimees Grupp aims to ensure the proper and consistent availability of its digital products and applications, but in no way guarantees their availability at all times and does not rule out possible disruptions in their operation.
5.2 Postimees Grupp reserves the right to suspend the availability of its digital products and applications at any time, for technical or other reasons, without informing users in advance. Consequently, Postimees Grupp is in no way responsible for any inconvenience or damage caused by these disruptions. These disruptions do not give rise to the return of the subscription fee, to discounts or other financial compensation, except in cases where these disruptions are the result of a deliberate and informed action of Postimees Grupp.
5.3 Postimees Grupp is not responsible for temporary or permanent damage or malfunctions that may arise from the use or during the use of the digital products and applications of Postimees Grupp. In particular, Postimees Grupp is not responsible for viruses or malware that may spread with the digital products and applications.
5.4 Postimees Grupp has the right to analyze the activities of the web environment users in order to improve the services, mainly regarding the users’ previous history of service use.
6.1 In order to deliver the subscription, the subscriber must provide:
- a secure, accessible mailbox that corresponds to the publication’s dimensions, can be identified as the subscriber’s mailbox and has a slot of minimal size of 230 x 20 mm (length, width);
- a free access to their mailbox that has been cleared of snow and ice in winter.
6.2 It is possible to change the subscription’s delivery address within the Republic of Estonia. The corresponding request must be submitted to the customer support of Postimees Grupp. The address change takes effect no later than 10 working days after the receipt of the relevant notice.
6.3 A subscription paid by a standing order is renewed automatically up to 10 calendar days before the end of the current subscription period, unless the subscription has been canceled.
6.4 The duration of the new subscription period and the terms of payment will be derived from the previous subscription period, unless it is a promotional offer, the terms of which are specified separately.
6.5 In the case of an e-invoice based standing order agreement, the first payment of the e-invoices submitted to the subscriber may amount to the subscription fee for three periods:
- the calculation of the payment for the first period is based on the price of the subscription of the past period that was received at the time the invoice was issued;
- the payment for the second period is the subscription price for the current period;
- the payment for the third period is a prepayment for the following period.
6.6 A subscription paid by a standing order can be canceled via customer support. The e-invoice based standing order agreement can also be terminated in a bank or online bank.
6.7 If you cancel a subscription paid by a standing order, the subscription will last until the end of the prepaid period and the advance payment will not be refunded.
6.8 The 14-day right to withdrawal does not apply to agreements whose object is the delivery of newspapers, magazines or other periodical publications (except in the case of long-term agreements entered into for the purpose of subscribing to such publications).
7.1 When publishing advertisements, we comply with the advertising and other appropriate laws, and the advertiser undertakes to comply with all requirements provided by law (including the rights of other persons), as well as with the general terms and conditions of Postimees Grupp AS. The advertiser is liable for any claims, costs and damages related to the advertisement, occurred to Postimees Grupp AS or other persons.
7.2 The editorial staff reserves the right to make linguistic corrections in advertisements without distorting the content.
7.3 Claims can be submitted within 7 days of the date of the advertisement’s publication.
7.4 All advertisement-related claims submitted to Postimees Grupp will be reviewed and responded to as soon as possible, but no later than 7 days from the receipt of the notice.
8.1 The user has the right to submit claims concerning a publication or its delivery to Postimees Grupp within 1 month of the discovery of the deficiency.
8.2 All claims submitted to Postimees Grupp will be reviewed and responded to as soon as possible, but no later than 7 days from the receipt of the notice.
8.3 Postimees Grupp is obligated to resolve the user’s claim if the reasons for the claim do not depend on the user.
9.1 The loyalty program of Postimees gives a joined subscriber an opportunity to participate in prize draws and receive loyalty offers.
9.2 You can join the loyalty program and see information about current prize draws and offers at lojaalsus.postimees.ee
9.3 To join the loyalty program, the subscriber must fill out all required information.
9.4 Postimees Grupp has the right to transfer the data of the subscriber who joined the program to its cooperation partner (for example, if the subscriber has to identify itself with the cooperation partner in order to obtain the discount).
9.5 From time to time, we notify the subscribers who have joined the program of loyalty offers by e-mail or via other channels.
9.6 Upon termination of the subscription, the subscriber loses the right to participate in prize draws.
10.1 A newsletter is a daily, weekly, monthly or less frequent e-mail sent to the subscriber, containing the news of postimees.ee and its subdomains.
10.2 Subscribing to Postimees Grupp’s newsletters (Postimees, rus.Postimees, Maa Elu, 60+, Elmar) is free. To subscribe to a newsletter, the user must enter their e-mail address on the web page.
10.3 Postimees Grupp, as controller of personal data, may forward the e-mail address of a newsletter subscriber to a third party who is the processor of the subscriber’s personal data and forwards newsletters to subscribers on behalf and instead of Postimees Grupp.
10.4 Upon subscribing to newsletters, the subscriber gives their withdrawable consent to Postimees Grupp to use their electronic contact information for the purpose of forwarding the newsletters.
10.5 You can unsubscribe from a newsletter at any time by clicking the „LAHKUN NIMEKIRJAST“ (LEAVE THE LIST) link at the end of the newsletter. If you unsubscribe from a newsletter, your e-mail address will be removed from the list and the newsletter will no longer be forwarded.
10.6 For questions related to the forwarding of newsletters, please contact us at firstname.lastname@example.org.
11.1 By offering the commenting option, Postimees Grupp takes into account the good practice of commenting established by the Estonian Newspaper Association (EALL), according to which:
- the following comments are removed from the commenting environment: comments that contain profanity; incite hostility, war between peoples and races; invite to use drugs and weapons, to overthrow or betray a state, or to be physically violent against specific persons; spread lies or unduly discredit other persons;
- a comment which does not conform to good practice must be deleted within a reasonable period from the time it was noted as such;
- all information relating to the comment which is not in accordance with good practice must be given to a court or other procedural body at their request;
- other measures may also be taken against writing inappropriate comments (word filters, blocking of IP addresses of users who have previously violated the rules, reporting to law enforcement authorities).
11.2 By conveying only their opinions, notices and other information via the web environment of Postimees Grupp, the author also transfers their publishing rights (the author’s economic rights) to the paper publications of Postimees Grupp as well.
11.3 Only identified users can comment in the web environments of Postimees Grupp. An identified user is, in particular, a user identified by the ID card or Mobile ID. Postimees Grupp also has the right to deem identified a user whose internet identity is in our opinion sufficiently reliable.
11.4 By publishing a comment, the commentator has given the permission to process personal data indicating racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data used to uniquely identify a natural person, health data or data on the sexual life and sexual orientation of a natural person.
11.5 By publishing the comment, the commentator has given permission to disclose their first and last name along with the comment.
11.6 All possible works sent to Postimees Grupp via web address are not subject to remuneration, unless the parties agree otherwise.
11.7 Postimees Grupp guarantees the confidentiality of the personal data of the commentators (including the contact address), with the exception of the personal data referred to in section 11.5 and in the case the transfer of personal data to a third party (including at the request of a court or other procedural body) is necessary to fulfil a legal obligation of Postimees Grupp and if the commentator has given their consent to Postimees Grupp to transfer their personal data (delivering the results of possible game wins, subscriptions, etc.).
12.1 Users can forward news tips to Postimees Grupp about events and topics of interest or concern. When submitting news tips, the following must be taken into account:
- by forwarding the news tip, the forwarder has given the permission to publish the material;
- when forwarding images and videos, the forwarder confirms that the image/video material belong to them;
- when forwarding a news tip via the web environment of Postimees Grupp or via e-mail, the forwarder will also hand over their publishing rights (the author’s economic rights) to the paper publications of AS Postimees Grupp as well;
- by forwarding the news tip, the forwarder agrees to the processing of their IP address by AS Postimees Grupp.
12.2 When forwarding a news tip, the forwarder has the option to add their contact information (name, phone, e-mail address); by submitting the data, the forwarder agrees to the processing of their personal information by Postimees Grupp.
12.3 By forwarding the news tip, the forwarder has given the permission to process personal data indicating racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data used to uniquely identify a natural person, health data or data on the sexual life and sexual orientation of a natural person.
12.4 All possible works sent to Postimees Grupp via web address are not subject to remuneration, unless the parties agree otherwise.
12.5 12.5. Postimees Grupp guarantees the confidentiality of personal data of news tip forwarders, unless the transfer of personal data to a third party (including at the request of a court or other procedural body) is necessary to fulfil a legal obligation of Postimees Grupp and in the case the news tip forwarder has given their consent to Postimees Grupp to transfer their personal data (delivering the results of possible game wins, subscriptions, etc.).
13.1 The copyright of Postimees Grupp and its journalists regarding articles and other materials must be respected when using the materials of Postimees Grupp. This applies regardless of whether the material is obtained through news agencies, internet sites or other media.
13.2 The use of materials is subject to the legal rules and principles governing the free use of a work. In particular, referencing articles is permitted on the basis of, in accordance to and to the extent set out in legislation. When referencing an article, the place of publication and the author of the referenced article must be disclosed. When referencing in an online environment, then before referencing, a link to the referenced material must be included in addition to the above. An article is generally allowed to be referenced to the extent of the title and one sentence. However, this sentence cannot be longer than the introductory sentence of the original text. After the referenced material, an exact reference to the original material of Postimees Grupp must be added on the internet: “Refereeritud artikli täisteksti loe AS Postimees Grupi veebilehelt” (Read the full text of the referenced article from AS Postimees Grupp’s website), which is clickable and directs directly to the used material of Postimees Grupp. The above requirements apply unless otherwise agreed.
13.3 To avoid doubt, it should be noted that without Postimees Grupp’s consent given in a written form or form reproducible in writing, it is not permitted to copy, publish or otherwise make materials available to third parties, in whole or by surpassing the extent allowed by legislation, on any physical or electronic medium, including but not limited to social media. The rule mentioned also applies to videos on YouTube accounts of Postimees Grupp. Among others, it is also not permitted to download the material automatically or non-automatically, nor save or process it in some other way, nor forward the material to any third party, including forwarding it with the purpose of downloading.
13.4 The use of materials that surpasses the free use of materials (including as a whole), including the use of materials for a commercial purpose, is possible with Postimees Grupp’s consent given in a written form or form reproducible in writing if a license agreement as been entered into with Postimees Grupp for that purpose. For more detailed information on the terms of the license agreement and the license fee, please contact the editorial staff of Postimees.
- single unlawful use of materials – 200 € (not including VAT);
- repeated (two or more times) unlawful use of materials – 320 € each time (not including VAT).
These General Principles of Personal Data Processing (hereinafter the Principles) explain how Postimees Grupp AS (registry code 10184643, address Tartu mnt 80, 10112 Tallinn) and its group company Maaportaal OÜ (registry code 14619329, address Tartu mnt 80, 10112 Tallinn) and companies Duo Media Networks OÜ (registry code 16077430, address Tartu mnt 80, 10112 Tallinn) and OMG TV OÜ (registry code 16030629, address Tartu mnt 80, 10112 Tallinn), Postimehe Kirjastus OÜ (registry code 16259326, address Tartu mnt 80, 10112 Tallinn) and (hereinafter together Media Companies) process Personal Data in the course of offering and providing their Services. If you use or have used the Services of the Media Companies, the Websites or participated in campaigns, raffles or otherwise transmitted your Personal Data to the Media Companies, these Policies apply directly to you. Therefore, we encourage you to familiarize yourself thoroughly with these Principles. If you do not agree with the General Principles of Processing Personal Data of Media Companies, the Website or the Services are not intended for you and you must refrain from visiting the Websites and using the Services.
We emphasize that not all of the following principles and the rights of the data subject always apply in full to personal data contained in articles and other journalistic content published in the publications of Media Companies. In applying each principle and the right of the data subject, it must be borne in mind that the Media Company processes this data in the exercise of the right to freedom of expression and information and for journalistic purposes.
1.1. Postimees Group – AS Postimees Grupp (registry code 10184643, address Tartu mnt 80, 10112 Tallinn), which processes the User's Personal Data as a controller within the meaning of the GDPR in accordance with these Principles; Postimees and its news portals in Estonian, Russian and English; Tartu Postimees, Pärnu Postimees, Sakala, Virumaa Teataja, Järva Teataja, South-Estonian Postimees and their news portals, weekly Maa Elu ja magazines Osuti, 60+ and Koolilõpp; Entertainment websites Elu24 and Russian-language Limon; OMG.tv; Neti.ee; in addition, more than ten thematic portals; Radio stations Kuku, Elmar, MyHits, Narodnoe Radio and DFM; BNS news agency; Postimees Publishing House; AS Kroonpress; Direct mail Target Master OÜ; SIA TVNET; SIA LETA; 15min UAB; UAB Diginet LTU; BNS Lithuania, processes the User's Personal Data as a controller within the meaning of the GDPR in accordance with these Principles;
1.2. Duo Media Networks – TV channels Channel 2, Channel 11, Channel 12, MyHits;
1.3. OMG tv A streaming service, which gives the Customer access to various films, TV series and TV channels, as well as other services offered by OMG TV or its partners.
1.4. Maaportaal Maaportaal and advertisement portal soov.ee
1.5. Postimehe Kirjastus offers titles in both fiction and non-fiction for adults, young adults and children.
1.6. GDPR – Regulation by European Parliament and Council (EU) 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)
1.7. Personal data – means any information relating to an identified or identifiable natural person;
1.8. User – a natural person who visits the Webpage; Creates an account on the Webpage or uses the Services;
1.9. Agreement – an agreement to be concluded between the Media companies and the User on the basis of which the User gains access rights to the paid content of the Webpage and/or the subscription to the newspaper, and will pay the fee to the Media companies if it is agreed upon. For the purposes of these Principles, the Agreement also includes agreements concluded between the Media companies and the User, on the basis of which the User is entitled to post comments on the articles appearing on the Webpage;
1.10. Service – all services and functionalities that have been made available to the User by the Media companies, e.g. subscribing to the publications belonging to the Postimees Group, commenting on the articles, reading the articles, subscribing to the news letters, announcements of the products, services and benefits of the companies and/or partners belonging to the Media companies; organizing consumer games, campaigns and/or lotteries;
1.11. Processing – any automated or non-automated operation or a set of operations, including collection and transferring, carried out with the Personal data or their aggregates;
1.12. Webpage – postimees.ee and all the related sub-domains, secure.pmo.ee, kliinik.ee, targetmaster.ee, maaportaal.ee, 15min.lt, tvnet.lv and all the related sub-domains and the mobile applications managed by the Media companies.
2. Personal data and the ways to collect them
2.1. The Media companies collect Personal data upon the conclusion of the Agreement, in the provision of the Services, and otherwise in the use of the Webpage by the User as follows:
2.1.1. The User himself/herself transfers to the Media companies his/her Personal data (for example, name, contact information, user name, password, posts comments, uses various Webpage features and Services);
2.1.3. The Media companies can confirm the User's identity and/or the payment order with the third person who provides the corresponding service. For example, a user can identify him/herself via an ID-card, Mobile-ID, a bank link, a Facebook account, or a Google+ account, and make payments under the Contract via the bank link service. The Media companies do not see the User PIN 1 or PIN 2 codes and do not save them. By authenticating via an ID-card and Mobile-ID, and by signing the statements of intent or confirmations, the User is required to comply with the security requirements and recommendations of the respective developers and the Media companies. To do this, we recommend that you get acquainted with the additional information at https://www.id.ee/mobiil-id/ and https://www.id.ee;
2.1.4. Media companies, including Postimees Group journalists can record their location on the premises and messages and orders received via communication channels (email, phone etc.), also information and other operations and use these recordings to prove orders or other operations as necessary.
2.2. Media companies Process the following Personal data:
- identification data (name, date of birth, gender, personal identification code)
- contact data (phone, email, address)
- In the case of contractual payments, bank data (User's bank account, bank name)
- Data of IP addresses and cookies
3. Objectives and a legal basis for the processing of personal data
3.1. The Media companies process the User's Personal data for the following purposes and legal basis:
3.1.1. To conclude or execute the Agreement to be concluded or concluded with the User, e.g.
184.108.40.206. To assist and advise the User who has entered into an Agreement, if the User has submitted a corresponding request to Media companies;
220.127.116.11. The Agreement concluded with the User for the transfer of invoices or other important notices related to the Service;
18.104.22.168 The Agreement concluded by the User for the provision of contractual Services and the delivery of goods, including the access to the contents of the Webpage.
3.1.2. Based on the User’s consent, e.g.
22.214.171.124. By the estimation of the Media companies, the display of an advertisement of interest to the User, if the User has agreed to install the corresponding cookies in his web browser;
126.96.36.199. Sending notifications to the User about the goods, services and benefits of the Media companies and the partners of the Media companies, if the User has given the corresponding consent;
188.8.131.52. Sending a newsletter to the User, if the User has forwarded his/her e-mail address to the Media companies for this purpose;
184.108.40.206. Carrying out of the consumer games, lotteries and campaigns organized by the Media companies, provided that the User has given the corresponding consent.
3.1.3. Based on the legitimate interest of the Media companies, e.g.
220.127.116.11. To contact the User for the direct marketing purposes if it is possible to assume that the User is interested in the respective offer under the previously concluded Agreement or on the basis of the provided Service, and the User has not expressed dissatisfaction or objected to such communications;
18.104.22.168. To ensure the execution of the Agreement entered into with the User, including for the detection of violations of the Agreement or the legislation by the User, and for its verification (for example, for presenting claims against the User). In this case, the legitimate interest of the Media companies in protecting their rights is the legal basis for the Processing. In the event that the User has violated the Agreement or the legislation, the interests and rights of the User are not considered superior to the legitimate interest of the Media companies;
22.214.171.124. For the collection of the statistics of the Webpage visitation, and the use of the Service, and for other non-personalized technical information regarding the use of Webpage, in order to supplement the Webpage and Services.
126.96.36.199. For processing CCTV camera recordings on the territory of media enterprises. The purpose of using cameras and processing recordings is to protect the property of employees, visitors, Postimees Grupp AS and other persons in the territory; security; defense and submission of claims, and the resolution of claims. In addition, Postimees can process camera recordings and for journalistic purposes. Read more.
3.1.4. To fulfill the obligations arising from the law on the Media companies, e.g.
188.8.131.52. statutory obligation to maintain the accounting records;
184.108.40.206. on the basis of legitimate requests, statutory obligation to transfer to the competent authorities the Users’ personal data;
220.127.116.11. the obligation arising from the law on the Media companies Act to respond to a request or order submitted by the User.
3.2. The User's personal data may also be processed if this is necessary in a specific case in the legitimate interest of the Media companies or a third party, unless such interests are overridden by the User's interests or fundamental rights and freedoms for which the personal data must be protected, or if this is necessary to protect the vital interests of the User or any other natural person.
3.3. If the Processing of Personal data is based on the legitimate interest of the Media companies, the User has the right to file an objection at any time.
4. Transfer of personal data to service providers (authorized processors)
4.1. The Media companies uses the service providers for Processing the User’s Personal data (authorized processors within the meaning of the GDPR). The Media companies is convinced of the reliability of such service providers by entering into the data processing agreements with them and being responsible for their activities.
4.2. The Media companies uses the following categories of the Authorized Processors: The companies belonging to the Media companies, providers of servers and cloud service, providers of platforms used for conducting consumer games, lotteries and campaigns organized by the Media companies, home delivery service providers.
4.3. Users have the right to request from the Media companies more detailed information on the authorized processors by using the contact details in clause 12.
5. Transferring personal data to the third persons
5.1. The Media companies will only transfer Personal data to the third parties to the extent that the Media companies is obligated to do so by law, if necessary for the execution of the Agreement entered into with the User, if the Media companies has a legitimate interest or if the User has given its consent.
5.2. The Media companies transfers the User's Personal data to the following third parties:
5.2.1. For the postal service provider (including e-mail service provider) to deliver orders and promotional materials. In this case, the legal basis for the transfer is the execution of the Agreement entered into with the User, the legitimate interest of the Media companies or the consent of the User;
5.2.2. for a payment service provider. In such a case, the legal basis for the transfer is the performance of the Agreement entered into with the User. (Maksekeskus AS, EveryPay AS, Zlick Ltd, Swedbank AS, AS SEB Pank, AS LHV Pank, Coop Pank AS, Luminor Bank AS)
5.2.3. for the associations belonging to the Media companies, to enable to offer the customer the discounts for the companies belonging to the Media companies. In this case, the legal basis for the transfer is the legitimate interest of the Media companies in providing the service;
5.2.4. on the bases provided for in legislation for the supervisory, investigative and law enforcement agencies. In this case, the legal basis for the transfer is the fulfillment of the statutory obligation of the Media companies;
5.2.5. for the auditors, legal and other advisers, if this is necessary for the performance of their duties to the Media companies and provided that they keep the relevant data confidential. In this case, the legal basis for the transfer is the fulfillment of the statutory obligation of the Media companies (for example, auditors) or the legitimate interest of the Media companies in protecting their rights;
5.2.6. for a debt collector if the User has incurred debts owed to the Media companies. In this case, the legal basis for the transfer is the legitimate interest of the Media companies in protecting their rights. In a situation where the User has violated the Agreement or otherwise violated the rights of the Media companies the interests and rights of the User shall not be considered superior to the legitimate interest of the Media companies.
5.2.7. to the company providing the accounting system. In such a case, the legal basis for the transfer is the performance of the contract entered into with the User and the performance of the obligations arising from law to the Media Company;
5.2.8. for registration and self-validation, you may also use tools provided by third parties such as Google or Facebook based on your consent. In that case, we will be able to create a profile for you based on the information we receive from such third party service providers and the information about you will be provided to those service providers. You can also log in to your account using the services of these third parties, if you already have one;
5.2.9. in order to obtain website traffic, website usage statistics and other non-personalized technical information, the User's personal data may be transferred to Service Providers such as Google and Facebook to improve the Website and Services, as well as the User experience based on Media Companies' legitimate interests.
6. Transferring personal data to the third countries
6.1. In the event that the User's data is transferred or processed in a country outside the EU / EEA, Media companies will provide appropriate guarantees for the protection of your personal data, for example, by concluding a standard data protection clause that provides security measures to ensure compliance with the protection law data, and also undertakes to introduce the necessary additional protection mechanisms to ensure that the User is provided with the same data protection guarantees as GDPR.
7. Storage of personal data
7.1. The Media companies stores the User's Personal data as long as it is necessary for the purpose of their collection, for the protection of the rights of the Media companies or until required by law.
7.2. Depending on the type of personal data, Media companies stores the User’s Personal data as follows:
7.2.1. Accounting documents: 7 years from the end of the relevant fiscal year, as required by law;
7.2.2. Personal data related to the Agreement: 10 years from the termination of the Agreement, due to the maximum limitation date for the intentional infringement;
7.2.3. Cookies data: according to terms of cookies usage.
7.2.4.Criteria for determining the retention period for journalistic content. Preservation of journalistic content is closely linked to freedom of the media and the press. Notes or recordings from a media company journalist may also be needed years later to create both new journalistic content; dispute resolution as well as evidence in court or other authorities. Material collected for the production of journalistic content is deleted 10 years after the publication of the journalistic content, ie if the media company and the journalist can be sure that there can be no (court) disputes over the application and the media company and the journalist are convinced that the material is no longer needed in public. for an article or other content of interest in the future.
8.1. The Media companies takes the necessary organizational, physical and info-technological security measures to ensure the User's Personal data security.
8.2. The User, who created the account on the Webpage, undertakes to keep the user name and password required for entering the Webpage in secret and in such a way that it will not fall into possession of the third parties, except if s/he has authorized a third party to use his user name and password for the use of the Services.
8.3. The User, who created the account on the Webpage, must immediately inform the Media companies if its user name or password has been lost or fallen into possession of the third parties in order to enable the Media companies to take appropriate measures to ensure the security of personal data.
8.4. The Media companies is not liable for any breach of security requirements arising from the User's activity.
9. User rights and liabilities
9.1. To the extent governed by the relevant legislation (in particular, the GDPR), the User has the right to exercise the following rights regarding the Personal data Processed by the Media companies:
9.1.1. request access to your Personal data;
9.1.2. request Personal data correction;
9.1.3. request deletion of Personal data;
9.1.4. request objections to the processing of Personal data, especially if the Media companies process them on the basis of a legitimate interest;
9.1.5. request transfer of Personal data.
9.2. In order to exercise his/her rights, the User shall contact the Media companies via the contact details given in clause 12 of the Principles. The User, who created the account on the Webpage, can also exercise certain rights via his user account.
9.3. The Media companies has the right to request the submission of additional information necessary for the identification of the User.
9.4. The Media companies meets the User's request within 1 month and informs the User whether and what measures have been taken to resolve the application of the User by the Media companies. If the application is complicated or voluminous, the Media companies may extend the deadline for replying by 2 months. If the Media companies does not take action according to the User's request, it shall notify the User of the reasons for the non-action and shall explain the possibility of submitting a complaint to the Data Protection Inspectorate or turn to the court for protection of its rights.
9.5. If the User's applications are clearly unreasonable or excessive, in particular due to their repeated nature, the Media companies may either:
9.5.1. ask for a reasonable fee, or
9.5.2. refuse to take the requested measures.
9.6. The User may only require the deletion of Personal data if one of the following grounds exists:
9.6.1. Personal data are no longer needed for the purpose for which they were collected or otherwise processed;
9.6.2. the User takes back the consent given to the Processing of Personal data and there lacks any other legal basis for the Processing of Personal data;
9.6.3. the User objects to the Processing of Personal data based on the legitimate interest of the Media companies, and there are no overriding legitimate reasons for the processing;
9.6.4. the User opposes the Processing of Personal data for direct marketing purposes;
A media company may, on the basis of a legitimate interest, use the customer's contact details for the direct marketing of its similar products or services. A person has the right to prohibit the use of his or her contact data for direct marketing both upon the initial collection of contact information and upon receipt of an offer. To do so, contact us email@example.com or click on the rejection hyperlink at the end of the offer e-mail.
9.6.5. Personal data has been processed illegally;
9.6.6. Personal data must be deleted in order to comply with the obligation arising from the law on the Media companies;
9.6.7. this is a Personal data of a child under 13 years of age that is processed on the basis of consent.
9.7. If the User requests the deletion of Personal data, then in the respective application, s/he must justify on the basis of which, specified in Clause 6 of the Principles, s/he demands it. The Media companies is not required to delete Personal data if there is no basis for this, or if the Personal data Processing is necessary for the following reasons:
9.7.1. for the execution of the right to freedom of expression and information;
9.7.2. in order to comply with the obligation arising from the Law on the Media companies;
9.7.3. in order to draw up, submit or defend legal requirements;
9.7.4. the Media companies has other statutory basis for the processing of Personal data.
9.8. If the User's Processing of Personal data is based on the User's consent, the User is entitled to withdraw the consent given to the Processing of Personal data at any time. The withdrawal of consent shall not affect the legality of the Processing that was made on the basis of the consent prior to the withdrawal.
9.9. If a violation should occur in connection with the User's Personal data, and according to the opinion of the Media companies, it is likely to be a major threat to the rights and freedoms of the User, the Media companies informs the User about this without an undue delay via the contact details provided by the User to the Media companies or, if that is not possible, publicly.
9.10. In order to keep the User's personal data up-to-date, the User is obligated to inform the Media companies about the change in his/her Personal data.
9.11. In the event that the User's rights have been violated, the User has the right to file a complaint with the Data Protection Inspectorate or to turn to the court for the protection of his rights.
10. Profiling for marketing purposes
10.1. The Media companies conducts profiling of Users for the marketing purposes on the users' web browsers, using the text files or cookies installed by the Media companies or some third parties. Profiling is a data processing aimed at making predictions about the demographic characteristics (gender, age) and interests of the User and, in this regard, displaying ads and offers to the User that the Media companies believes could be of interest to the User.
10.2. As a result of profiling for marketing purposes, no decision is made with respect to the User with the legal significance.
10.4. The Media companies does not use personal data for profiling that the User, having created an account on the Webpage, has transferred to the Media companies for the purpose of establishing the account or concluding the Agreement.
11. Change of Principles
11.1. The Media companies may need to change these Principles due to the changes in the legislation, the processes of processing personal data of the Media companies, or the instructions given by supervisory authorities or courts. In this case, the Media companies will notify the User before the appropriate changes are made within a reasonable time.
12. Contact data
12.1. In order to exercise their rights, withdraw their consent, as well as obtain additional clarifications and submit a complaint to the Media companies, the User may contact the Media companies at the following contact points:
- Postimees: firstname.lastname@example.org
- Duo Media Networks: email@example.com
- OMG TV: firstname.lastname@example.org
- Maaportaal.ee: email@example.com
- BNS: firstname.lastname@example.org
- Tartu mnt 80, 10112 Tallinn, Eesti