THIS PRIVACY POLICY HAS BEEN LAST UPDATED ON 1 JULY 2024

This Privacy Policy governs the collection, processing and storage of Personal Data and is an integral part of the DinneroTech OÜ Terms of Service (see www.dinnero.eu). 

By using our Website and related Services, you agree to the terms of this Privacy Policy. By continuing to use the Website, you confirm that you have read, understood and agree to this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, please do not use our Website and Services.

1. Terms and definitions

1.1. Dinnero means the controller of Personal Data, i.e. DinneroTech OÜ (registry code 16916391, address Lesta tn 10/2-25, Tallinn, Estonia, 13516).

1.2. Service User means a natural person who has expressed a willingness to use Dinnero's Services (including by visiting Dinnero's Website) or who uses or has used Dinnero's Services.

1.3. Personal Data means any information relating to an identified or identifiable natural person (the Data Subject). 

1.4. Processing of Personal Data means any operation or set of operations which is performed upon Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

1.5. Profiling means any automated processing of Personal Data that involves the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person, his or her personal preferences, interests, reliability, behaviour or location.

1.6. Third Party means any natural or legal person, public authority, agency or body, except the Data Subject, the controller, the processor and persons who process Personal Data under the direct authority of the controller or processor.

1.7. Website means the website owned and operated by DinneroTech OÜ at the following address www.dinnero.eu.

1.8. Data Controller means the person who processes Personal Data on behalf of Dinnero.

2. General Provisions

2.1. The processing of Personal Data in Dinnero is carried out in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation), the Personal Data Protection Act, other legislation and the Dinnero Customer Data Privacy Policy. 

2.2. Dinnero reserves the right to unilaterally amend this Privacy Policy in the event of changes to the legislation governing the protection of Personal Data or to Dinnero's data processing policies. The latest version of Dinnero's Personal Data processing policy is always available on the Website at www.dinnero.eu. If the Service User does not agree to the changes, he/she has the right to stop using the Website and the Services and to request the deletion of his/her Personal Data.

2.3. By sharing his or her Personal Data, the Service User grants Dinnero the right to collect, organize, use and manage the Personal Data that the Service User directly or indirectly shares with Dinnero through the use of the Website's goods or services for the purposes specified in the Privacy Policy.

2.4. It is the responsibility of the Service User to ensure that the information they provide is accurate, correct and complete. Knowingly providing false information will be considered a breach of the Privacy Policy. The Service User is required to inform Dinnero immediately of any changes to the data provided.

2.5. Dinnero shall not be liable for any damage caused to the Service User or to Third Parties as a result of the provision of false information by the Service User.

2.6. Dinnero and its employees are required to keep Personal Data confidential indefinitely and are liable for any breach of their obligations. Access to and processing of Personal Data is permitted only to employees who have received the appropriate training. Processing of Personal Data shall be limited to what is necessary for the performance of assigned tasks and the fulfilment of obligations arising from legislation. Processors authorised to process Personal Data are also required to process Personal Data in accordance with data protection requirements.

3. Legal basis and purposes of Personal Data processing 

3.1. The Personal Data that Dinnero collects, processes and maintains is collected using electronic means, mainly through the Website and e-mail. 

3.2. Dinnero processes Personal Data for the following purposes and on the following legal grounds: 

3.2.1. To determine whether the Data Subject is eligible for the Services provided by Dinnero. The processing of Personal Data is based on Article 6(1)(a), (b) and (c) of the GDPR. Among other things, Dinnero assesses the age-appropriateness and identifies the potential Service User. 

3.2.2. To perform a contract (including debt recovery) entered into with the Service User. The processing of Personal Data is based on Article 6(1)(b) of the General Data Protection Regulation. 

3.2.3. To prevent fraud and other criminal offences. The processing of Personal Data is based on Article 6(1)(b) of the General Data Protection Regulation. 

3.2.4. To comply with other legal obligations. The processing of personal data is based on Article 6(1)(c) of the GDPR. Legal obligations may change from time to time. 

3.2.5. To produce statistics for analytical purposes and to improve products and services. The processing of Personal Data is based on Article 6(1)(b) of the General Data Protection Regulation. 

3.2.6. To provide Dinnero's Services to the Service User. The processing of Personal Data is based on Article 6(1)(b) of the General Data Protection Regulation. 

3.2.7. To perform contracts entered into with the Partners. The processing of Personal Data is based on Article 6(1)(b) of the General Data Protection Regulation.

3.3. For example, Dinnero uses profiling to prevent and mitigate fraud and other abuses, for marketing purposes, and to monitor transactions to combat fraud. Automated decisions (i.e. a decision is made using IT tools and without human intervention). Automated decisions and profiling are based on the Personal Data known about the Service User, collected in accordance with these Terms and Conditions. Such processing of Personal Data is carried out either on the basis of Dinnero's legitimate interest (marketing profiling), for the performance of legal obligations, or for the entry into or performance of a contract with the Service User, as applicable.

4. Categories of Personal Data processed

4.1. Given names and surname;

4.2. Date of birth; 

4.3. Contact details (e-mail address, phone number, and address);

4.4. Payment card details;

4.5. Current account number; 

4.6. User ID;

4.7. Where applicable, information on the origin of the Service User's assets; 

4.8. Information obtained as a result of the use of the Website, which may or may not be Personal Data, depending on the circumstances and the requirements of applicable legislation: approximate physical location information, IP address, information collected through the use of cookies, JavaScript or other technologies, log files and similar information. 

4.9. Communication data collected in the course of the provision of the Service (which is collected when communicating with the Service User via e-mail, messaging, social media and other forms of communication, including telephone conversations).

4.10. In addition to the above, Dinnero has the right to collect information about the Customer that is available in public registers.

5. Transmission of Personal Data

5.1. Dinnero has the right to transmit the collected Personal Data to the following categories of persons, if such obligation is required by law and/or is necessary for the entry into, performance or enforcement of a contract with the Service User: 

5.1.1. server, network and communications service providers; 

5.1.2. marketing service providers; 

5.1.3. analytical service providers;

5.1.4. collection agencies;

5.1.5. payment default registers; 

5.1.6. payment service providers. Dinnero transmits the Personal Data necessary for the execution of payments to the authorised processor AS LHV Pank ,registration code: 10539549;

5.1.7. Dinnero's advisers; 

5.1.8. courts, bailiffs, police and prosecutor's office.

6. Retention of Personal Data

6.1. Dinnero will retain Personal Data only for as long as necessary to achieve the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

6.2. The Data Subject's data is stored:

6.2.1. For the duration of the contractual relationship and for up to five years after the end of the contractual relationship, unless a longer retention period is provided for by law.

6.2.2. Accounting records are kept for seven years from the end of the financial year in which the transaction took place, in accordance with the law.

6.2.3. Data processed for the purposes of direct marketing is kept for as long as the Data Subject has given his or her consent therefor. If the Data Subject withdraws his or her consent, the processing of the data for the purposes of direct marketing will cease.

6.2.4. For the performance of other legal obligations, the data will be kept in accordance with the time limits laid down in the legislation.

6.3. At the end of the retention period, Dinnero destroys or anonymizes the Personal Data of the Data Subjects in a way that prevents its recovery and further use.

7. Rights of Data Subject

7.1. Right to examine data

The Service User has the right to receive confirmation as to whether Dinnero is processing his or her Personal Data and, if so, to obtain access to his or her Personal Data and the following information:

• processing purposes;
• categories of the Personal Data processed;
• recipients of the Personal Data or categories of recipients to whom the Personal Data has been disclosed or will be disclosed;
• where possible, the expected period of retention of the Personal Data or, if this is not possible, the criteria for determining the retention period;
• if the Personal Data are not collected from the Data Subject, all information about their source;
• automated decision-making, including profiling, and, at least in those cases, the logic used, as well as the significance of such processing and the expected consequences for the Data Subject.

7.2. Right to rectification of data

The Service User has the right to demand that Dinnero immediately rectify incorrect Personal Data concerning him or her. Considering the purposes of the processing, the Data Subject has the right to request the completion of incomplete Personal Data, including by adding an additional statement.

7.3. Right to deletion of data (right to be forgotten)

The Service User has the right to demand that Dinnero delete his or her Personal Data immediately, and Dinnero is obliged to delete this Personal Data immediately if one of the following circumstances applies:

• the Personal Data are no longer necessary for the purposes for which they were collected or otherwise processed;
• the Data Subject withdraws the consent on which the processing was based and there is no other legal basis for the processing;
• the Data Subject objects to the processing and there are no overriding legitimate grounds for the processing;
• the Personal Data have been unlawfully processed;
• the Personal Data must be erased in order to comply with a legal obligation;
• the Personal Data have been collected in connection with the provision of information society services.

7.4. Right to restriction of processing

The Service User has the right to request Dinnero to restrict the processing if one of the following circumstances applies:

• the Data Subject contests the accuracy of the Personal Data for a period of time that allows Dinnero to verify the accuracy of the Personal Data;
• the processing is unlawful and the Data Subject opposes the erasure of the Personal Data and requests instead the restriction of the use of the Personal Data;
• Dinnero no longer needs the Personal Data for processing, but the Data Subject needs them for the establishment, exercise or defence of legal claims;
• the Data Subject has objected to the processing, pending verification whether Dinnero's legitimate grounds outweigh the Data Subject's objections.

7.5. Right to data portability

The Service User has the right to receive the Personal Data concerning him or her which he or she has provided to Dinnero in a structured, commonly used and machine-readable format and to transmit such data to another controller, if:

• the processing is based on consent or a contract;
• the processing is automated.

7.6. Right to object

The Service User has the right file objections at any time, on grounds relating to his or her particular situation, to the processing of his or her Personal Data based on the public interest or the legitimate interests pursued by Dinnero, including profiling based on these provisions. Dinnero will not further process Personal Data unless Dinnero can demonstrate that there are substantial legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject, or for the establishment, exercise or defence of legal claims.

7.7. Automated decision-making and profiling analysis

The Service User has the right not to be subject to a decision based solely on automated processing, including profiling, where that decision produces legal effects concerning him or her or significantly affects him or her. This right does not apply if the decision is:

• necessary for the entry into or performance of a contract between the Service User and Dinnero;
• permitted by applicable law, which also provides for appropriate measures to safeguard the rights and freedoms and legitimate interests of the Data Subject;
• based on the Data Subject's explicit consent.

7.8. Right to withdraw consent

Where the processing of the Personal Data is based on the Service User’s consent, the Service User has the right to withdraw his or her consent at any time, without prejudice to the lawfulness of the processing that took place prior to the withdrawal.

7.9. Right to complain 

For further information about the processing of the Personal Data or the exercise of the rights, or to make a complaint, it is possible to contact Dinnero using the contact details provided in this Privacy Policy. However, if the Service User considers that the processing of his or her Personal Data is in breach of the legal requirements, he or she has the right to turn to the Data Protection Inspectorate or to a court in order to protect his or her rights and interests.