1. General conditions and consepts
1.1. The service provider is AS Postimees Group (Postimees Group), registry code 10184643, located at Tartu mnt 80, Tallinn 10112. Customer support phone: 666 2525 (Mon-Fr 8-17, Sat 8-12) and email: email@example.com.
1.2. The subscription is considered as an agreement concluded between Postimees Group and the subscriber, which is deemed to have been concluded upon payment of the order.
1.3. By making a subscription to Postimees Group (subscription), the subscriber agrees to follow the terms of subscription of Postimees Group.
The Subscriber is a private or legal person who has subscribed to Postimees Group Publications.
A Subscription is a contract of purchase and sale between Postimees Group and the Subscriber for the purpose of subscribing to a Publication.
A Publication is a paper or digital product delivered based on the Subscription. A Paper Product is a Publication the contents of which are delivered on paper. A Digital Product is a Publication the contents of which can be accessed through all digital mediums: personal computers, tablet computers and cell phones.
2. Subscription to Paper Products
2.1. Information required for a Subscription: first and last name, exact address (street, house number, apartment number, city/town or village/county, postal index), phone number and, if possible, email address and personal identification code. If the Subscriber is not the one paying for the Subscription, the Subscriber is obligated to provide the information for both persons.
2.2. For the purpose of delivery, the Subscriber shall ensure:
a secure and accessible mailbox that can be identified as belonging to the Subscriber that fits the Publication and has a slot no smaller than 230 x 20 mm (length, width);
easy access to the mailbox, cleared of ice and snow in the winter.
2.3. The Subscription can be registered to a new address within the Republic of Estonia. A corresponding application needs to be addressed to Postimees Group customer support. Re-registration will take effect inside 10 working days of filing the application.
2.4. When the Subscription period ends, Postimees Group will send the Subscriber a new advance payment invoice/sales offer to allow the Subscriber to continue their Subscription comfortably. The offer will not be sent if the Subscriber has chosen not to receive offers.
2.5. The Subscriber can apply for premature termination of the Subscription and refund of advance payments.
2.6. Premature termination of the Subscription requires a written application that lists the Subscriber's name, subscription information and time of termination, account number and name of account owner.
2.7. The Subscriber will be refunded the cost of the Subscription from the date of termination to the final date of the subscription period. The refund will be withheld if the Subscription has been registered with free added value or is a direct debit Subscription. (See clause 3 for additional information).
2.8. Upon premature termination of the Subscription, Postimees Group will refund the Subscriber using the account number provided in the Subscriber's written application, cash refunds are not possible.
3. Subscription to Paper Products with direct debit
3.1. A Subscription can be made using e-invoice standing order agreements.
3.2. A standing order Subscription will be renewed at the end of every subscription period (1 month), unless the Subscriber terminates the Subscription before the end of the current subscription period.
3.3. Conditions of payment will be lifted from the previous Subscription, except in case of campaign offers that are subject to specific prices and terms of validity.
3.4. In case of a standing order Subscription, the first Paper Product will reach the Subscriber's mailbox inside 10 working days.
3.5. The first payment for e-invoices delivered to the Subscriber could be for up to three subscription periods, based on the time of Subscription and the e-invoice standing order agreement:
The first period payment is calculated based on price of Subscription delivered for the previous period by the time of issue of invoice.
The second period payment is the price of the current period's Subscription.
The third period payment is advance payment for the following period.
3.6. An e-invoice standing order agreement can be terminated by visiting the bank or online bank.
3.7. Mobile payments can be terminated by contacting Postimees Group customer support.
3.8. Upon termination of a standing order Subscription, the Subscription will remain valid until the end of the prepaid subscription period.
4. Subscription to Digital Products
4.1. The Postimees Group digital subscription is a monthly paid subscription service that provides access to the paid content of Postimees, Pärnu Postimees, Sakala, Järva Teataja, Virumaa Teataja, Lõuna-Eesti Postimees webpages.
4.2. The use of the service requires the existence of a user account. The user account is a personal account through which the customer identifies him/herself.
4.3. The service can be used in five unique devices (incl. browser and mobile app)
4.4. Immediately upon completion of the order, Postimees Group will provide the subscriber with a confirmation giving the access to the paid content of the webpages. The confirmation is forwarded for the use of the user account to the e-mail address specified by the subscriber.
4.5. The subscriber is required to submit the required mandatory information for formalizing the subscription.
4.6. The Subscriber can use the discount offer once. If the Subscriber cancels the Subscription and signs up for a new Subscription, the new Subscription will be priced normally.
4.7. In case the data provided by the subscriber is incorrect and/or incomplete, Postimees Group is not responsible for the proper execution of the subscription.
4.8. The payment will automatically renew at the end of the subscription period unless the subscriber cancels the order before the end of the current subscription period. The terms and conditions of the new payment will be charged to the previous payment, unless it is a promotional offer, the price and validity of which are separately determined.
4.9. The subscription can be canceled under “My subscriptions” in user account settings or by contacting customer support. Cancellation will see the subscription retained until the end of the subscription period.
4.10. The subscription can be canceled on through the customer support.
5. Right of withdrawal
5.1. For the contracts relating to the transmission of digital content that are not delivered on a physical medium, the 14-day right of withdrawal is not applicable.
5.2. The 14-day right of withdrawal does not apply to contracts concerning delivery of newspapers, magazines or other periodicals (except in the case of long-term contracts for subscription to such publications).
6.1. The subscribers has the right to submit complaints about the service to Postimees Group within 2 months from the discovery of the deficiency.
6.2. All complaints submitted to Postimees Group will be reviewed and answered as soon as possible but not later than within 14 days of the receipt of the notice.
6.3. Postimees Group undertakes to resolve the complaint by the subscriber if the reasons for the complaint are not dependent on the subscriber.
6.4. If Postimees Group does not resolve the complaints of the subscriber within a reasonable time, the subscriber may contact the Consumer Protection Board.
7. Compliance with subscription conditions and changes
7.1. Postimees Group does not guarantee appropriate execution of subscriptions and has the right to terminate a Subscription if:
information provided by the Subscriber is false and/or inaccurate:
the Subscriber's mailbox does not meet requirements outlined in clause 2.2
the Subscriber fails to pay for the Subscription by the payment deadline
the Subscriber fails to comply with other subscription conditions.
7.2. Postimees Group has the right to unilaterally change the terms of subscription by notifying about in on the webpage or otherwise at least 1 month in advance.
7.3. If the subscriber does not agree to the subscription terms, s/he will be able to unsubscribe within 1 month from the publication of the change. If the subscriber does not express the willingness to terminate the subscription within 1 month, the changes are deemed to have come into effect.
7.4. Postimees Group has the right to change the price of the subscription by informing the subscribers in advance of the price change. Changes in the subscription prices come into force at the beginning of the next subscription period after the date of the price change.
7.5. Postimees Group retains the right to suspend the publishing or discontinue the Publication either in part of in full. Should Postimees Group decide to suspend the publishing or discontinue the Publication, the Subscriber will be refunded for advance payments made.
1. Joining with the AS Postimees Groupp newsletters (Postimees, rus.Postimees, Maa Elu, Elmar) is free.
2. The newsletter is an email sent to a subscriber every day, once a week, once a month or less frequently, including postimees.ee and the news of its subdomains on topics selected by the subscriber.
3. To subscribe to the newsletter, the subscriber's e-mail address must be entered, collected both by AS Postimees Group and Smaily.com, through which the newsletters are sent to the subscribers.
4. The subscribed newsletter can opted out at any time via the link LEAVING THE LIST at the end of the newsletter.
5. If you opt out of the newsletter, the email address will be removed from the list and the newsletter will no longer be sent.
6. By joining the newsletter, you consent to the storage and processing of your personal data in accordance with the general principle of the processing of personal data of Postimees Group.
7. If you have questions, you can contact firstname.lastname@example.org.
The newspaper Postimees owned by AS Postimees Group and the county newspapers belong to the Estonian Newspaper Association (EALL), which supports the possibility of commenting as a democratic manifestation in the online environment, and considers the comments as a free opportunity for discussion on various topics. The possibility for commenting generated at the online newspapers is not considered as a journalistic activity, and the comments published there are the readers' views about the content they are responsible for.
1. Providing the possibility of commenting, AS Postimees Group is based on the good practice established by the Estonian Newspaper Association (EALL), according to which:
1.1 comments that contain obscenities are deleted from the comment environment; incite hatred between peoples and races, war; call for the use of drugs and weapons, the overthrow of state or betrayal, or physical violence against specific individuals; disseminate lies or disparage other persons unjustifiably;
1.2 a comment that does not conform to the good practice must be deleted within a reasonable time after submission of the relevant notice;
1.3 at the request of a court or other procedural authority, all information that is stored in a comment that does not comply with the good practice must be rendered up;
1.4 other measures may also be taken against the writing of inappropriate comments (word filters, blocking the previously transgressed IP address, reporting to the law enforcement authorities).
2. By submitting only their opinions, notices and other information through the online environment of AS Postimees Group, their author also submits their publication rights (author's proprietary rights) to the paper publications of AS Postimees Group.
3. With the publication of the comment, the commentator has given a permission to process the personal information revealing the racial or ethnic origin, political opinions, religious or philosophical beliefs or belonging to a trade union, genetic data, biometric data used to uniquely identify a natural person, health data or data on a person’s sexual life and sexual orientation.
4. All possible works that are sent via the web-address of AS Postimees Group are not subject to remuneration, unless the parties agree otherwise.
5. AS Postimees Group guarantees the confidentiality of personal data (including contact address) of commentators, except in cases provided for by the law (incl. at the request of a court or other procedural body) and in the special agreements (for the delivery of possible game prizes, subscription, etc. to the addressee).
6. Only the identified users can comment on the AS Postimees Group online environments. An identified user is considered to be an user primarily identified by an ID card or a Mobile ID. AS Postimees Group has the right to consider as identified also a user whose internet identity, in our estimation, is sufficiently reliable.
7. AS Postimees Group guarantees the anonymity of the people giving the potential news hints according to the good journalistic practice and the Code of Ethics of the Estonian Press.
AS Postimees Group awaits readers’ hints concerning interesting or worrying events and topics. Hints can be sent in as text, image or video. Images and video require an explanation – who, where, when and why? Hints should observe the aspect of newsworthiness – news photos need to be taken inside the past two weeks.
1. Keep in mind when sending in hints:
1.1 By sending in a hint, the person gives their consent for the publication of the material.
1.2 When sending in hints, the person confirms they are the author of images/video.
1.3 By sending in hints using AS Postimees Group online portal or via email, the person also gives publication rights (the author’s financial rights) to AS Postimees Group print publications.
2. By sending in hints, the person agrees to their IP address being processed by AS Postimees Group.
3. When sending in a hint, the person can attach their contact information (name, phone, email); by adding said information, the person agrees to AS Postimees Group processing their personal information.
4. By sending in a hint, the person has allowed AS Postimees Group to process their personal data in terms of racial or ethnic background, political views, religious or philosophical convictions, union affiliation, genetic information, biometric data for the purpose of singular identification, health data or data on sexual life and orientation.
5. Works sent to AS Postimees Group online are not subject to remuneration provided the sides have not agreed differently.
6. AS Postimees Group ensures the privacy of the person’s personal information, unless sharing the information with third persons (incl. by order of the court or other bodies authorized to carry out proceedings) is necessary for AS Postimees Group to fulfill its legal obligations or if the person has provided consent for forwarding personal information (for the purpose of delivery of game victories, subscriptions etc.)
Materials published in the webpages of AS Postimees Group (including articles, photographs, blogs and forums, comments, etc.) are the copyright protection objects within the meaning of the Copyright Act, the copying and distribution of which without the written consent of AS Postimees Group is generally prohibited. For a written consent, please contact us at: email@example.com. The right to use the digital media of AS Postimees Grupp is set out in this document of terms and conditions. The user agrees to the use of the applications or the related services under these terms. AS Postimees Group reserves the right to make corrections in the terms at any time. These changes are made available with these applications or services, and will be effective from the moment of publishing.
1. General conditions
1.1.1 The general terms and conditions apply to all users of the Postimees Group services and visitors to the webpages.
1.1.2 AS Postimees Group has the right to change the general terms due to the substantive or technical development of the field, amendments to the laws or regulations.
1.1.3. The change to the general terms and conditions applies from the moment when the updated terms are published on the webpage related to AS Postimees Group.
1.1.4. If the users of the AS Postimees Group service or visitors of the webpage do not agree to the changes in the terms, they have the right to terminate the use of the AS Postimees Group services within one (1) month from the publishing of the terms. If the user does not waive using the service within one (1) month of the enforcement of the terms, the changes shall be deemed to come into force and the user as having accepted them.
2. Availability of digital applications, services, and content
2.1. AS Postimees Group is committed to ensuring a good and continuous availability of its digital applications, services, and content, but in no way guarantees their availability at all times and does not prevent the possible interferences in their work.
2.2. AS Postimees Group reserves the right at any time to suspend the availability of its applications, services or content for the technical or other reasons without informing users in advance. As a result, AS Postimees Group is in no way responsible for any inconvenience or damage caused by such interferences. Such interferences do not give rise to the reimbursement of fees paid for the applications or services, discounts or other financial compensation, except in cases where such interferences result from the deliberate and knowing activities of AS Postimees Group.
2.3. AS Postimees Group is not responsible for the temporary or permanent damage or the malfunctions that may arise from the use of the digital media applications or services of AS Postimees Group, or occur in use. In particular, AS Postimees Group is not responsible for the viruses or malware that may spread through the digital applications or services.
3. Sale and subscription of digital editions
4. Use of materials
4.1. When using Postimees Group materials, copyright of AS Postimees Grupp and its journalists’ articles and other materials must be observed, irrespective of whether the material has been obtained through news agencies, websites or other mediums.
4.2. Use of materials is subject to legal rules and principles of the free use of works. Referencing articles is permitted in the cases and volume provided by law. For every article referenced, the publication and author need to be mentioned. When referencing online articles, a link to the original story needs to be included. It is generally permitted to reference the headline and a single sentence of an article. The sentence should not be longer than the lead of the original text. Online synopses need to be accompanied by an exact reference to AS Postimees Group original materials as follows: “The full text of the referenced article can be found on AS Postimees Group website.” The reference needs to be in the form of a hyperlink that takes the reader directly to AS Postimees Grupp original material used. These requirements apply if the sides do not have a different previous agreement.
4.3. Let it be said in the interests of clarity that without written consent or consent that can be reproduced in writing from AS Postimees Grupp, copying, publication or making available to third persons of materials on physical or electronic data mediums, including but not limited to social media, is prohibited in any capacity exceeding cases provided in the law. This rule also applies to videos uploaded to YouTube using AS Postimees Grupp accounts. It is furthermore prohibited to automatically or manually download materials, save or process them, as well as to forward materials to third persons, including for the purposes of downloading.
4.4. Use of materials in any capacity (including in full) exceeding free use of works, also use of materials for commercial purposes, is possible with written consent or consent that can be reproduced in writing from AS Postimees Grupp provided a license agreement with AS Postimees Grupp has been signed. For more information on licensing conditions and licensing fees, please contact the editorial of Postimees.
4.5. Failure to comply with aforementioned conditions for use of materials and referencing gives AS Postimees Grupp the right to charge the violator based on the following price list:
Single instance of illegal use of materials - €200 (VAT not included);
Repeated (two or more) instances of illegal use of materials - €320 per incident (VAT not included)
This General Principles of the Processing of Personal Data (hereinafter the Principles) explains how Media Investments & Holding OÜ (registry code 14609223, address Rävala pst 4, 10143 Tallinn) and its affiliated companies process Personal data in the course of the provision of their Services. If You use or have used the Services of the Media Investments & Holding, Webpages, or participated in the campaigns, lotteries organized by the Media Investments & Holding, or have released your Personal data in some other form to the Media Investments & Holding, these Principles related directly to You. Therefore, we are encouraging you to thoroughly familiarize yourself with these Principles. If you do not agree with the General Principles of the Processing of Personal Data of the Media Investments & Holding, the Webpage and Services are not intended for you, and you must refrain from visiting the Webpages and using the Services.
These Principles do not apply to the personal data contained in the articles published in the publications of the Media Investments & Holding. The Media Investments & Holding processes these data for the purpose of exercising the right to freedom of expression and information and for the journalistic purposes, and although the data subjects are also entitled to the protection of personal data in these situations, these Principles have not been drafted in the light of this.
1. Terms used in the Principles
1.1. Postimees Group – AS Postimees Group(registry code 10184643, address Tartu mnt 80, 10112 Tallinn), which processes the User's Personal Data as a controller in the meaning of the GDPR in accordance with these Principles;
1.2. Media Investments & Holding – Postimees and its news portals in Estonian, Russian, and English; Tartu Postimees, Pärnu Postimees, Sakala, Virumaa Teataja, Järva Teataja, Lõuna-Eesti Postimees and their news portals, a weekly Maa Elu and magazines Osuti, 60+ and Koolilõpp; Entertainment webs Elu24 and the Russian-language Limon, in addition, more than ten theme portals; Radio stations Kuku, Elmar, MyHits, Narodnoe Radio and DFM; TV channels Kanal 2, Kanal 11, Kanal 12, MyHits; News agency BNS; Postimees Publishing house; AS Kroonpress; Direct mail Target Master OÜ; Maaportaal OÜ; SIA TVNET; SIA LETA; 15min UAB; UAB Diginet LTU; BNS Lithuania.
1.3. 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)
1.4. Personal data – means any information relating to an identified or identifiable natural person;
1.5. User – a natural person who visits the Webpage; Creates an account on the Webpage or uses the Services;
1.6. Agreement – an agreement to be concluded between the Media Investments & Holding OÜ 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 Investments & Holding if it is agreed upon. For the purposes of these Principles, the Agreement also includes agreements concluded between the Media Investments & Holding and the User, on the basis of which the User is entitled to post comments on the articles appearing on the Webpage;
1.7. Service – all services and functionalities that have been made available to the User by the Media Investments & Holding, 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 Investments & Holding; organizing consumer games, campaigns and/or lotteries;
1.8. 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;
1.9. 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 Investments & Holding.
2. Personal data and the ways to collect them
2.1. The Media Investments & Holding collects 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 Investments & Holding 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 Investments & Holding 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 Investments & Holding does 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 Investments & Holding. To do this, we recommend that you get acquainted with the additional information at http://mobiil.id.ee and http://www.id.ee;
2.1.4 Media Investments & Holding, 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 Investments & Holding Processes the following Personal data:
2.2.1 identification data (name, date of birth, gender, personal identification code)
2.2.2 contact data (phone, email, address)
2.2.3 In the case of contractual payments, bank data (User's bank account, bank name)
2.2.4 Data of IP addresses and cookies
3. Objectives and a legal basis for the processing of personal data
3.1. The Media Investments & Holding processes 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.
188.8.131.52 To assist and advise the User who has entered into an Agreement, if the User has submitted a corresponding request to Media Investments & Holding;
184.108.40.206 The Agreement concluded with the User for the transfer of invoices or other important notices related to the Service;
220.127.116.11 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.
18.104.22.168 By the estimation of the Media Investments & Holding, the display of an advertisement of interest to the User, if the User has agreed to install the corresponding cookies in his web browser;
22.214.171.124 Sending notifications to the User about the goods, services and benefits of the Media Investments & Holding and the partners of the Media Investments & Holding, if the User has given the corresponding consent;
126.96.36.199 Sending a newsletter to the User, if the User has forwarded his/her e-mail address to the Media Investments & Holding for this purpose;
188.8.131.52 Carrying out of the consumer games, lotteries and campaigns organized by the Media Investments & Holding, provided that the User has given the corresponding consent.
3.1.3. Based on the legitimate interest of the Media Investments & Holding, e.g.
184.108.40.206 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;
220.127.116.11 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 Investments & Holding 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 Investments & Holding;
18.104.22.168 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.
3.1.4. To fulfill the obligations arising from the law on the Media Investments & Holding, e.g.
22.214.171.124 statutory obligation to maintain the accounting records;
126.96.36.199 on the basis of legitimate requests, statutory obligation to transfer to the competent authorities the Users’ personal data;
188.8.131.52 the obligation arising from the law on the Media Investments & Holding 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 Investments & Holding 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 Investments & Holding, 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 Investments & Holding uses the service providers for Processing the User’s Personal data (authorized processors within the meaning of the GDPR). The Media Investments & Holding 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 Investments & Holding uses the following categories of the Authorized Processors: The companies belonging to the Media Investments & Holding, providers of servers and cloud service, providers of platforms used for conducting consumer games, lotteries and campaigns organized by the Media Investments & Holding, home delivery service providers.
4.3. Users have the right to request from the Media Investments & Holding 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 Investments & Holding will only transfer Personal data to the third parties to the extent that the Media Investments & Holding is obligated to do so by law, if necessary for the execution of the Agreement entered into with the User, if the Media Investments & Holding has a legitimate interest or if the User has given its consent.
5.2. The Media Investments & Holding transfers the User's Personal data to the following third parties:
5.2.1 For the postal 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 Investments & Holding or the consent of the User;
5.2.2 for the associations belonging to the Media Investments & Holding, to enable to offer the customer the discounts for the companies belonging to the Media Investments & Holding. In this case, the legal basis for the transfer is the legitimate interest of the Media Investments & Holding in providing the service;
5.2.3 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 Investments & Holding;
5.2.4 for the auditors, legal and other advisers, if this is necessary for the performance of their duties to the Media Investments & Holding 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 Investments & Holding (for example, auditors) or the legitimate interest of the Media Investments & Holding in protecting their rights;
5.2.5 for a debt collector if the User has incurred debts owed to the Media Investments & Holding. In this case, the legal basis for the transfer is the legitimate interest of the Media Investments & Holding in protecting their rights. In a situation where the User has violated the Agreement or otherwise violated the rights of the Media Investments & Holding the interests and rights of the User shall not be considered superior to the legitimate interest of the Media Investments & Holding.
6. Transferring personal data to the third countries
6.1. The Media Investments & Holding will transfer personal data to the third countries (countries not included in the countries of the European Economic Area) only if the Media Investments & Holding has the statutory legal basis for this, in particular if the addressee country offers the adequate protection of personal data according to the European Commission's decision. In the event that the addressee country does not belong to the third countries providing the adequate protection, the Media Investments & Holding will transfer Personal data only in case of the application of the appropriate protection measure, as required by European Union and Estonian legislation.
7. Storage of personal data
7.1. The Media Investments & Holding 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 Investments & Holding or until required by law.
7.2. Depending on the type of personal data, Media Investments & Holding 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.
8.1. The Media Investments & Holding 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 Investments & Holding if its user name or password has been lost or fallen into possession of the third parties in order to enable the Media Investments & Holding to take appropriate measures to ensure the security of personal data.
8.4. The Media Investments & Holding 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 Investments & Holding:
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 Investments & Holding 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 Investments & Holding 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 Investments & Holding has the right to request the submission of additional information necessary for the identification of the User.
9.4. The Media Investments & Holding 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 Investments & Holding. If the application is complicated or voluminous, the Media Investments & Holding may extend the deadline for replying by 2 months. If the Media Investments & Holding 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 Investments & Holding 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 Investments & Holding, 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;
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 Investments & Holding;
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 Investments & Holding 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 Investments & Holding;
9.7.3 in order to draw up, submit or defend legal requirements;
9.7.4 the Media Investments & Holding 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 Investments & Holding, it is likely to be a major threat to the rights and freedoms of the User, the Media Investments & Holding informs the User about this without an undue delay via the contact details provided by the User to the Media Investments & Holding 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 Investments & Holding 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 Investments & Holding conducts profiling of Users for the marketing purposes on the users' web browsers, using the text files or cookies installed by the Media Investments & Holding 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 Investments & Holding 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 Investments & Holding does not use personal data for profiling that the User, having created an account on the Webpage, has transferred to the Media Investments & Holding for the purpose of establishing the account or concluding the Agreement.
11. Change of Principles
11.1. The Media Investments & Holding may need to change these Principles due to the changes in the legislation, the processes of processing personal data of the Media Investments & Holding, or the instructions given by supervisory authorities or courts. In this case, the Media Investments & Holding 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 Investments & Holding, the User may contact the Media Investments & Holding at the following contact points: