privacy policy

These privacy terms have been prepared in accordance with the General Data Protection Regulation (EU Regulation 2016/679 of the European Parliament and Council) and the Personal Data Protection Act and apply to the customers of HUPPA OÜ. 

The controller of personal data for SHOP.HUPPA.EU is HUPPA OÜ (registration code 10729506), located at Männiku tee 101, Tallinn, phone +372 6559507, and email info@huppa.eu.

The privacy terms are an integral part of the contracts between HUPPA and the customer and include the following information: 

• What types of personal data we collect;
• Why and on what basis we collect your personal data;
• How we handle your personal data;
• Your rights;
• Our contact details for information about your personal data processing rights and how to exercise those rights.

USEFUL TERMS

HUPPA uses the following terms in these rules: 

Customer – A natural or legal person who uses, has used, or has expressed a desire to purchase goods and services offered by HUPPA or is otherwise related to HUPPA services. 

Data Subject – A natural person about whom HUPPA has information and data to identify the person. Data subjects include, for example, natural person customers, visitors, and those submitting inquiries and requests. Referred to in these privacy terms as person or customer.

Personal Data – Any information about an identified or identifiable natural person (“data subject”); 

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

PERSONAL DATA

HUPPA processes customer personal data only based on the law and for the purposes and on the grounds stated in these privacy terms. HUPPA processes the following customer personal data: 

• Name, phone number, and email address;
• Delivery address;
• Bank account number;
• Cost and data related to goods and services payments (purchase history);
• Customer support data.

HUPPA collects the above data in various ways:

• Data provided by the person to HUPPA (data disclosed during order);
• Data received during payment for goods and services (information related to card payment, bank transfer, etc.).

PURPOSE AND BASIS OF DATA PROCESSING

HUPPA has a legal basis and interest in processing the personal data of the customer or the customer’s representative for the establishment, maintenance, and termination of cooperation and customer relationship and retaining all data related to the person throughout the process, including retaining data to fulfill legal obligations, submit claims, and conduct legal disputes.

access to personal data and security

HUPPA ensures the confidentiality of customer data required by law through secure storage and organizes the protection of personal data against unauthorized access, illegal processing, or disclosure, accidental loss, alteration, or destruction. 

Access to personal data is only available to HUPPA’s legal representatives or employees designated for this purpose. Certain personal data may be transferred to third parties, i.e., authorized processors, to fulfill obligations arising from the contract and the law (see data sharing below). 

HUPPA organizes all information exchanges in a secure manner using multiple personal access and identification codes and secure information transmission channels, thus hindering third-party access and minimizing the risk of data leakage. 

use of cookies

To ensure the proper functioning of the website, small files called cookies are stored on the user’s device. A cookie is a small text file that a website saves on a user’s computer or mobile device when the user visits the site. It enables the website to remember the user’s actions and preferences (such as username, language, text size, and other display preferences) over a period of time, so the user doesn’t have to re-enter them each time they return to the site or browse from one page to another. The legal basis for the use of cookies is our legitimate interest in ensuring the technical functionality and operation of the website according to the user’s preferences and choices. Cookies generally expire within a short period (day, week, or month); in some cases, they can last up to a year. We may use cookies and similar tools to provide services and improve service quality and user experiences. Cookies may also be used by third parties whose services we use. Cookies are used for various reasons: 

• Personalizing content and ads,
• Providing social media features, and
• Analyzing website usage.

We may also share information about how the website is used with our social media, advertising, and analytics partners. The implementation of such cookies is not strictly necessary for the functioning of the website, but it ensures a better browsing experience. You can delete or block cookies, but in this case, some website functionalities may not work as intended. Cookies help us provide better services. 

Controlling Cookies. You can control and/or delete cookies as you wish (see www.youronlinechoices.com/). You can delete all cookies already on your computer and reject cookies at any time by changing your browser settings (if your browser allows it) or stopping the use of the website. Be aware that some website functions can only be provided using cookies, and if you refuse cookies, these functions may not be available to you. You can disable cookies in your browser settings or visit the following websites:

• https://tools.google.com/dlpage/gaoptout?hl=en
• http://www.youronlinechoices.com/.

Google Analytics

We may use Google Analytics, a web analytics service provided by Google, Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). Google Analytics uses cookies to analyze how users use the website. As mentioned above, users can disable cookies in their browser settings, but in this case, they may not be able to use the full functionality of the website. Users can also disable their data collection by Google Analytics at any time. To do so, users must download the relevant browser add-on from the following website: [Google Analytics Opt-out](https://tools.google.com/dlpage/gaoptout?hl=en). 

More information can be found by reviewing Google Analytics data processing rules: https://support.google.com/analytics/answer/6004245?hl=en.

Website Logs

The server hosting our website may store requests made by users to the server (web address opened by the user, browser and device used by the user, IP address, access time). These data are used only for technical purposes to ensure the functioning and security of the website and to identify security incidents.

data sharing

HUPPA transfers customer personal data to third parties if required by law, necessary for organizing HUPPA’s work, fulfilling legal obligations or rights, or on another legal basis. Personal data provided to authorized processors are processed on the basis and to the extent necessary.

HUPPA transfers personal data to the following recipients:

• Authorized processors to organize HUPPA’s work (e.g., accounting service providers, IT system administrators, such as customer program managers, business software, accounting software, archiving service, etc.), and the online store customer support for managing purchases and purchase history and resolving customer issues;
• Authorities (law enforcement agencies, bailiffs, bankruptcy administrators, notary offices, court, Road Administration, etc.);
• Third parties related to the sale of goods, provision of services, and fulfillment of the contract with the customer – transport and courier service providers, payment intermediaries, communication, IT, and postal service providers, advertising and marketing specialists;
• Legal advisors, financial advisors, insurers;
• In the event of the transfer of claim rights, the new creditor.

Transfer of Personal Data Outside the European Union (EU) – We transfer your personal data outside the EU and store it there only if we have a legal basis for doing so, including to a recipient in a country where personal data protection is adequately ensured, or that falls under a measure meeting the EU’s requirements for personal data transfer outside the EU.

retention and deletion of personal data

HUPPA does not process personal data longer than necessary to fulfill the purposes related to the data, including fulfilling the data retention obligations prescribed by law.

• When closing the online store customer account, personal data will be deleted unless such data need to be retained for accounting or consumer dispute resolution;
• If a purchase is made in the online store without a customer account, the purchase history is retained for three years;
• In case of disputes related to payments and consumer disputes, personal data are retained until the claim is fulfilled or the limitation period expires;
• Information arising from the customer agreement is retained for three years;
• Accounting records and data required by law will be retained for seven years;
• Information obtained based on consent will be stored until the consent is withdrawn.

The Customer has the right to withdraw their consent at any time by submitting a notification to the HUPPA representative via email or in person. The withdrawal of consent does not affect the legality of personal data processing that took place before the consent was withdrawn.

customer rights

In relation to the organization of personal data protection at HUPPA, the Customer has the following rights:

• To access information about themselves and, if necessary, receive a copy of the data;
• To request the correction of outdated or incorrect data;
• To request the deletion of data or cessation of processing if there is no legal basis for retaining or processing the data, and if retaining the personal data is no longer necessary for processing;
• To request the transfer of data to a third party;
• The right to file a complaint with a supervisory authority.

The Customer can view and make corrections to their personal data in their HUPPA online store user profile. If the purchase was made without a user account, the Customer can view personal data through customer support.

Withdrawal of Consent

If personal data processing is based on the Customer’s consent, the Customer has the right to withdraw their consent by notifying customer support via email.

Deletion

To delete personal data, the Customer must contact customer support via email. A response to the deletion request will be provided within one month, including details on the deletion period.

Transfer

A response to a transfer request submitted via email will be provided within one month. Customer support will verify the identity and notify the Customer about the applicable personal data for transfer.

Direct Marketing Notices

The email address and phone number will be used for direct marketing messages if the Customer has given consent. If the Customer does not wish to receive direct marketing messages, they should select the relevant option in the email header/footer or contact customer support. If personal data is processed for direct marketing purposes (profiling), the Customer has the right to object at any time to the processing of their personal data, including profiling related to direct marketing, by notifying customer support via email (this information should be provided clearly and separately from any other information).

If the Customer suspects that their personal data is being misused, they should immediately notify HUPPA customer support at: info@huppa.eu. 

HUPPA has the right to update and change the privacy policy. Changes will be made visible to customers on the HUPPA website.