Privacy Policy for Snabb Platform

This Privacy Policy is adopted by Snabb OÜ (registry code 12801774, address Peterburi tee 49, Tallinn, 11415, Estonia, e-mail ask@snabb.xyz) (“Snabb”, “we”, “us” and “our”). Snabb is the owner and operator of Snabb platform (“Platform”) as the information society service provider, provided through a webpage https://snabb.xyz/ and mobile application that enables the Clients (also referred to as “you” or “data subject”) to book and order parking spaces car wash services and other car-related services (all collectively the “Services”) offered by respective providers (the “Providers”) through the Platform.

Unless defined in this Privacy Policy, the terms used in Privacy Policy are used in the meaning given to them in Article 4 of the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”).

As this Privacy Policy sets out the principles of processing your personal data by Snabb when you use our Platform, please read the Privacy Policy carefully. If you have any questions about how we process your personal data or if you wish to submit an application for exercising your rights related to processing your personal data, please contact us through the contact information provided in the section “Contacts” below.

1. DEFINITIONS

1. WHY WE PROCESS PERSONAL DATA AND WHAT PERSONAL DATA DO WE PROCESS?

1. 1. When you have opted to use our Platform, we need to process your personal data to enable the Providers to offer Services to you (data subject) via our Platform.
   2. We process personal data that is submitted to us directly by you in the course of using our Platform.
   3. We process personal data that is submitted to us directly by you also if you contact us with a query or question via Platform or via any other channel (by sending an e-mail, for example). In such a case we process your personal data included in the inquiry to the extent that is necessary to respond to you.
   4. Personal data we process about you in the course of using our Platform may include following data about you:
      
      1. general personal information: first name and last name that you disclose to us when you register as a user through our Platform or order any Services through the Platform;
      2. contact details: email address that you disclose to us when you register as a user through our Platform or order any Services through the Platform;
      3. car data: license plate number and location of your car at the time of the Service that you disclose to us through our Platform;
      4. payment data: if you have opted credit card payment, then type of credit card (visa/master), token (unique card identifier by Everypay), name of the card holder, four last numbers of credit card, card expiration month and year;
      5. usage data: we collect information about how you use the Platform, for example how many times you have used certain Services (parking spaces, car washing services etc) to amend and better adapt the Platform and to offer various discounts to you.

1. 1. We process your personal data to make the Platform available to you to enable the Providers to provide information about their available Services to you so that you can book and order Services and enter into User Agreements with the Providers and pay for Services (please read the Terms). Legal basis for such data processing is GDPR Article 6-1-(b), i.e. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
   2. In certain specific situations we might also process your personal data where processing your personal data is necessary for the purpose of our legitimate interests pursued by us. Legal basis for such data processing is GDPR Article 6-1-(f). In such a case we shall ensure that processing is proportionate and that we have carried out legitimate interest impact assessment. For example, for the purpose of our legitimate interest we analyse how our Services and Platform are used by our Clients so we can provide better service.
   3. In certain specific situations we may also process your personal data based on your consent. Legal basis for such data processing is GDPR Article 6-1-(a). In those situations, we process your personal data on the terms as provided in the consent that you have granted to us.
   4. Additionally, we might process your personal data when processing is necessary for compliance with a legal obligation to which we are subject, for example for accounting purposes under applicable accounting legislation. Legal basis for such data processing is GDPR Article 6-1-(c).
   5. More specifically, we rely on following legal bases when processing your personal data:

1. WHEN DO WE SHARE YOUR PERSONAL DATA?

1. 1. To the extent this is necessary for the provision of our services through the Platform, we may share your personal data with certain third parties.
   2. Upon ordering Services via Platform, we share your personal data with the specific Provider providing Services to you through Platform with whom you have concluded User Agreement(s) via Platform. Personal data shared with Providers includes following data: your name (first name and last name), phone number, car license plate number, color, mark, location of your car at the time of the Service (address, coordinates) and the list of the Services ordered.
   3. We may also share your personal data with third party suppliers providing services to us, e.g. IT suppliers or other service providers. At the moment of adopting this Privacy Policy, we use the following service providers:
      
      1. Amazon Web Services, Inc. for data storage and data centre service. We use Amazon data centres located in EU. Privacy terms for Amazon Web Services are available here: https://aws.amazon.com/privacy/;
      2. EveryPay, AS, as payment service providers to enable you to make payments for Services though Platform. Privacy terms for EveryPay, AS, are available at https://every-pay.com/privacy-policy/;
      3. Adyen N.V. as payment service providers to enable you to make payments for Services though Platform. Privacy terms for Adyen N.V., are available at https://www.adyen.com/policies-and-disclaimer/privacy-policy.
   4. We may also transfer your personal data to third countries, i.e. countries outside the EU/EEA area, for the purposes explained in this Privacy Policy. When transferring your personal data to third countries, we will ensure that the transfer is subject to appropriate safeguards under GDPR and that your rights are protected, such as the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and/or 2010/87/EU. You may request a copy of the safeguards we have put in place with respect to the transfer of personal data by contacting us via contact details below.

1. HOW LONG IS YOUR PERSONAL DATA RETAINED?  

1. 1. Snabb does not retain personal data longer than it is necessary for the purposes of processing personal data or pursuant to applicable law.
   2. Personal data related to contracts can be retained during the term of the contract and based on our legitimate interest pursuant to Article 6 (1) (f) of the GDPR until the end of the statutory limitation periods under applicable law. Accordingly, as a general rule Snabb retains your personal data as long as it is necessary for the provision of the Services during the term of the contract concluded between you and Snabb and for three years after the term of the contract. In this regard, as a general rule, if you have not used our Platform for three years (you have not logged in to your profile on our Platform for three years), your profile and all personal data therein will be deleted, unless we have a legal basis for retaining your personal data for longer time period.  
   3. Pursuant to the Accounting Act, we may retain accounting documents for seven years.
   4. More specific terms concerning the retention periods of your personal data are outlined in the table in Section 3 above.

1. HOW DO WE PROTECT YOUR PERSONAL DATA?

To protect your personal data from unauthorized access, unlawful processing or disclosure, accidental loss, modification or destruction, we use appropriate technical and organisational measures that comply with applicable laws. These measures include but are not limited to the implementation of appropriate computer security systems, protection of paper and electronic format files by technical and logical means, controlling and limiting access to documents and buildings.

1. COOKIES

1. 1. Our Platform uses cookies. This section incorporates our cookie policy (the “Cookie Policy”) that applies when you use Platform.
   2. Cookies are small data files stored on your hard drive by a website. Cookies help us monitor and improve the functionality and usage of our Platform and your experience on Platform. We can use cookies to see which areas and features are popular and to count visits to our Platform to recognize you as a returning visitor and to tailor your experience of the Platform according to your preferences. We may also use cookies for targeting or advertising purposes.
   3. We use following type of cookies on our Platform:
      
      1. Strictly necessary cookies, that are essential in order to enable you to move around and navigate on Platform and use the features of Platform.
      2. Functional cookies, that record information about choices you have made and allow to tailor Platform. Functionality cookies remember choices you make such as language preference, country location, or other online settings and provide personalized or enhanced features that you select, so that next time you visit you won’t have to enter all this information again.
      3. Statistics cookies, that record information about the way our Platform is used, to acquire knowledge on how often our Platform is visited, where on our Platform our visitors spend the most time, how often they interact with a page or part of a page, this allows us to make the structure, navigation, and content of our Platform as user-friendly as possible.
      4. Advertising cookies, to help measure the delivery and the performance of advertising campaigns and limit the number of times you see an advert. Third-party targeted advertising cookies may be placed on your device by third-party advertisers, ad networks, data exchanges, marketing analytics and other service providers.
   4. The specific cookies that Platform uses are the following:

1. 1. You can delete or block cookies on Platform through your browser settings at any time. However, some cookies might be necessary for the functionality of Platform. Therefore, you understand that when blocking or deleting the cookies some features of Platform might not function correctly.
   2. For more general information about cookies including the difference between session and persistent cookies please see www.allaboutcookies.org.
   3. In case you have any question concerning Cookie Policy, you may contact us via contact details provided below.

1. YOUR RIGHTS

1. 1. Snabb is dedicated ensuring that all data subject rights arising under applicable law are always guaranteed to you. In particular, you as a data subject have:
      
      1. the right to access the personal data that Snabb processes about you;
      2. the right to request that Snabb rectifies any inaccurate personal data about you;
      3. the right to request Snabb to erases your personal data and/or restricts of processing of your personal data if we do not have valid legal basis for processing;
      4. the right to receive your processed personal data in a structured, commonly used and machine-readable format and have the right to transmit your personal data to another controller;
      5. the right to object to the processing of your personal data.
   2. If you believe that your rights have been infringed, you may contact and lodge a complaint to the supervisory authority applicable for your jurisdiction (Data Protection Inspectorate in Estonia address Tatari 39, Tallinn 10134, info@aki.ee or other competent authority in your jurisdiction).

1. GOVERNING LAW AND JURISDICTION

This Privacy Policy shall be governed by the laws of the Republic of Estonia. Any disputes arising from these Privacy Policy shall be settled in the Harju County Court in the Republic of Estonia, unless you have a right to turn to the court of your residence pursuant to statutory law.

1. CONTACTs

If you have any questions about this Privacy Policy or Cookie Policy or if you have any concerns about how we use your personal or if you want to exercise your rights as described above, you may contact us via e-mail or in writing using the following contact information:

Snabb OÜ

e-mail: ask@snabb.xyz

address: Peterburi tee 49, 11415 Tallinn, Estonia