SUNERGIA Privacy Policy

About us

Controller: Sunergia OÜ, registration code: 16068632, address Linnamäe tee 6 Keila Harju maakond, hereinafter – SUNERGIA.

The use of any word “you”, “your” or similar expressions in this Privacy Policy means any visitor to www.sunergiagroup.com, hereinafter – the Website. Terms such as “we”, “our” or similar expressions mean SUNERGIA.

This Privacy Policy explains how SUNERGIA processes data of natural persons, the procedure for exercising the data subject’s rights and the issues related to the protection of personal data. SUNERGIA Privacy Policy applies to the processing of personal data performed by SUNERGIA on the Website and in connection with the provision of operation of this website. Buyers who purchase products on the Website are also subject to the additional terms and conditions set forth in the General Terms and Conditions of Transactions.

SUNERGIA complies with the requirements of the General Data Protection Regulation No. 2016/679 requirements in processing personal data.

Your privacy

Our goal is to inform you as clearly and comprehensibly as possible about how and why we use your personal information.

Our goal is to make you feel safe when disclosing your personal data to us. Personal data is any information that can be used to identify an individual who is a natural person.

We take appropriate measures to ensure that personal data is always safe with us and that your personal data is processed in accordance with the valid legal enactments on data protection, our internal policies and procedures.

We protect your personal information and observe the confidentiality in everything we do. This policy allows you to find out what data we may obtain about you, how we will use it, and provides information about your rights and how you can contact us.

We regularly follow data protection and privacy issues, therefore this Privacy Policy may be amended or supplemented at any time. The current Privacy Policy will be published on this Website. Any version of the Privacy Policy published on the Website supersedes all previous versions of the Privacy Policy and comes into effect immediately upon posting.

What categories of personal data do we collect and why?

Provision of services (sale of products)

Categories of personal data

Legal basis

– Personal information (name, surname)

– e-mail address

– phone number

– name of the company (if specified)

– country, address

– delivered products, product group or those of interest

– product delivery type, process

– payment type

– payment information (e. g., current account number, payment card data)

– IP address

– main information about the third parties receiving the products

– customer, customer’s order and/or invoice number

Different legal bases can be used for sale of products, preparation of delivery documentation and provision for delivery, delivery of products and preparation of documentation, as well as issuing and sending of invoices:

General Terms and Conditions of Transactions and the contract between you and SUNERGIA on purchase of products and use of the website.

In order to conclude a contract on purchase of products according to your invitation or interest (including preparing and sending an offer).

Our legitimate interest to sell products, providing information and product sale service.

Fulfilment of legal obligations provided in laws and regulations (incl., accounting and registration of payments, ensuring the product conformity conditions).

– Personal information (name, surname)

– e-mail address

– name of the company (if specified)

For provision of the after-sales service – General Terms and Conditions of Transactions and the contract between you and SUNERGIA on the purchase of products, as well as our legitimate interest to improve service and promote sale of products.

Registration and recurrent buyers’ information

Categories of personal data

Legal basis

– Personal information (name, surname)

– e-mail address

– phone number

– name of the company (if specified)

Contract between you and SUNERGIA on purchase of products and use of the website (General Terms and Conditions of Transactions) – performance of the contract, conclusion of the contract on the initiative of the customer.

–

Investigation and prevention of illegal activities directed against us

In order to detect and prevent illegal activities against SUNERGIA (e. g., to investigate and prevent violations, protect and improve our IT systems, prevent attacks and intrusions or unauthorized editing of or blocking access to the Website, prevent spamming, phishing or other unauthorized activities), we may collect and process the data available to us, including passing it on to law enforcement authorities or information technology security incident prevention institutions.

Categories of personal data

Legal basis

– User-generated data, visit history, data related to the devices used and their settings, e. g., language settings, time zone, operating system and platform, IP and MAC addresses, browser settings, other information about the use of the Website and SUNERGIA digital services, other identifying information

Our legitimate interest to prevent abuse of services or interference with provision of services, or to investigate and prevent criminal activity against the company.

To fulfil a legal obligation provided for by applicable legal enactments (laws and regulations).

Direct marketing, advertising and information materials

Having received your consent, we inform you about various news and current events related to our services, promotions and offers and those of our cooperation partners. If you would like to receive our news, you must indicate it on our Website or by applying in another offered way.

Having received your consent, we will personalize communication and offers and will profile data, including taking into account the product groups of interest, previous purchases (purchase history), information specified to us, current offers for the location (country, region), as well as taking into account the language of communication, will select the offers that might best meet your interests and needs.

Categories of personal data

Legal basis

– Personal information (name, surname)

– name of the company (if specified)

– Contact information (e-mail address, phone number)

– Product types of interest

For sending personalized communication – your consent.

– Country

– Previously purchased products

For preparing offers and profiling, adjusting the language of communication – your consent.

Data provided by you when communication with us takes place

When you contact us or we need to inform you to respond to your request, process your application or contact you in cases provided for in applicable legal enactments, we may identify and contact you using the contact information available to us (phone number, e-mail address), request additional identifying information if necessary to adequately protect your privacy or to fulfil our obligation, as well as to inform our cooperation partners so that we can better respond to your wishes or improve our products and services.

Categories of personal data

Legal basis

– Personal information (name, surname)

– Other identifying information

– Contact information (address, e-mail address or mobile phone number)

To fulfil a legal obligation provided for by applicable legal enactments (laws and regulations).

Our legitimate interest.

What sources do we obtain personal data from, how accurate is it?

We obtain personal data from you. We summarize information we receive when you visit and use the Website, providing us data (including data you provide to us before receiving our service (purchasing products) or filling in information fields on the Website), as well as data you provide contacting us. We may receive data from service providers ensuring operation of the Website, including its operation statistics services, counter-attack, security and intrusion protection services.

If your data you have provided to us has changed (e. g., contact information for receiving news), you must notify us immediately by correcting incorrect or inaccurate data.

Who do we transfer your personal data to?

– Service providers and cooperation partners

In order to fulfil our obligations to you, ensure the operation of the Website and operation of SUNERGIA (including customer service, sale of products and invoicing), we transfer your personal data to companies and institutions providing services to us, e. g., the services related to maintenance and operation of the website, or to send direct marketing messages, to ensure the process of the product purchase and the product delivery, e. g., to a payment service provider, a product delivery or insurance service provider. Also, SUNERGIA service providers (IT maintenance and data storage service provider, accounting outsourcing provider) may in some cases be considered the processors of your personal data.

Your data can mainly be processed by our cooperation partner (processor) Scoro -customer relationship management system helping to manage our interaction with potential and existing customers and to process the inquiries about our products and services. However, we may change the cooperation partners, therefore we invite you to follow information about the data processing performed by SUNERGIA.

Cookies are processed and received by us and our cooperation partners, who ensure the operation of the Website, summarize and analyse your activities on the Website.

If you use any information exchange facility or tool on the Website, your data may be transferred to the respective cooperation partners associated with your chosen information exchange or transfer facility, as well as messaging service providers.

Personal data may be disclosed (transferred) to another person in connection with the transfer of companies, any merger, acquisition, sale of assets, transfer of business to another merchant, etc. In such cases, the customer database is not sold (transferred) separately, unless it is related to the transfer of the entire company.

We make reasonable efforts to verify all service providers processing your personal data on our behalf. We assess whether the cooperation partners (personal data processors) apply appropriate security measures so that the processing of your personal data takes place in accordance with our tasks, directions, instructions and the requirements of regulatory enactments. These companies are not entitled to use your personal data for any other purpose. We transfer your personal data to the third parties involved in the provision of your chosen service.

– Law enforcement authorities, public and municipal institutions

In order to fulfil the obligations provided for in regulatory enactments (laws and regulations), we may transfer your personal data to the law enforcement authorities (e. g., to the police), public and municipal institutions upon their request (e. g., to the supervisory authority responsible for personal data protection). We may transfer your personal data to the law enforcement agencies (e. g., courts), as well as public and municipal institutions, also to protect our legitimate interests, compiling, filing and defending claims, complaints and applications.

Cookies

Use of cookies

This Website, like many others, uses cookies to help improve the website usage experience and ensure that its excellent operation. We invite you to get acquainted with the principles of use of cookies.

Personal data may be processed during the use of cookies. By using this Website, you agree to the type of use of cookies described here (unless your browser is set to not accept cookies). You should be aware that if you choose to disable certain necessary cookies, the Website will not be able to operate properly.

Information about cookies

This Website is accessed using a browser, e. g., Chrome, Firefox, Safari, Edge, Opera, etc.

Cookies are information that this browser obtains and stores at the time when you use our Website. The next time you again visit our Website, the browser will remember your actions and will perform some of them for you, e. g., will choose your working language or control the display of cookies notice. With the help of cookies, the Website obtains the ability to store the user’s individual settings, recognize the user and respond accordingly.

Types of cookies and their purposes

There are several types of cookies – session and persistent cookies. Cookies are also divided into first-party cookies and third-party cookies. The mentioned concepts are explained below, so that you can better understand the nature of cookies and why we use them.

Session cookies allow to recognize you when you visit a particular website by memorizing any changes or choices on a particular website, so that they are also saved on other pages. These cookies allow you to use multiple pages of the same website quickly and easily, avoiding the need to process each visited page. Session cookies are non-persistent – they expire when you close your browser or end a session on a particular website.

Persistent cookies are cookies that are stored on your device (end-device) for a certain period of time after the end of an Internet browsing session, therefore they allow to save the user’s choices or actions on the website and use them the next time the user visits a website using these cookies.

First-party cookies are cookies maintained by entities administered by the website operator, in this case us. Third-party cookies are maintained by other domains not belonging to us. Third-party cookies that may be stored on your device (computer, phone or tablet) when you browse our Website.

Categories of cookies according to their function

The following categories of cookies are distinguished in the above types of cookies:

– Mandatory (short-term, first-party): These cookies are essential for you to be able to browse various websites and use their functionality. They are needed to provide the basic functions of the website, i. e., to add products to the shopping cart, ensure the purchase process and display the specific version of the page. Without these cookies, you will not be able to receive the necessary services and the proper operation of the website will not be possible.

– Performance cookies (long-term, first-party and third-party): These cookies summarize information about how visitors use websites, e. g., which websites they visit most often. The information summarized using cookies is mostly summarizing, therefore direct identification is almost impossible. The information is only used to ensure the better operation of the website. Sometimes cookies of such type may be called analytics cookies since they help to store more information, e. g., how a visitor uses the website and what links are used. The cookie host may use it to make a profile of your interests and display relevant ads on other sites. Analytics cookies mostly work by identifying your browser and device.

– Functional cookies (long-term, first-party and third-party): These cookies allow a specific web page to remember your choice and offer you better, more modern features. These cookies are optional, but allow the website to provide advanced functions and enhance the user experience – allow websites to store information you have entered as a user of web pages (e. g., user ID, language selection, user location, personal data security settings). The purpose of these cookies is to offer all users advanced, personalized functions. Functional cookies are also used to allow the use of some desired functions, e. g., video playback. These cookies cannot track your browsing activity on other websites.

– Advertising cookies (long-term, first-party and third-party): These cookies are used as a source of advertising containing information that is important to you and relevant to your interests. They are also used to limit the number of ads you see and as an additional tool to measure the effectiveness of your ad campaigns. They are usually placed by advertising systems with the network operator’s permission.

List of cookies used on the Website

The periods of use (validity) of the cookies used on our Website are indicated as maximum periods and you can delete the cookies earlier.

Cookie	Type	Service provider	Purpose	Period	Additional information
_ga	Analytics HTTP	Google Tag Manager	Registers a unique identifier used to generate statistical data on how the user uses the website.	1 year
_gat	Analytics HTTP	Google Tag Manager	Used by Google Analytics to improve the number of requests	1 day
_gid	Analytics HTTP	Google Tag Manager	Registers a unique identifier used to generate statistical data on how the user uses the website.	1 day
_hjid _hjid [x2]	Analytics HTTP	Google Tag Manager	Sets a unique session identifier. It allows the website to obtain data on behaviour of visitors for statistical needs.	1 year
collect	Analytics Pixel	Google	Used to send data to Google Analytics on the visitor’s device and activity. Allows to reach the visitor on various devices and marketing channels.	A particular connection session
Facebook pixel	Advertising Pixel	Facebook	Used to show ads based on behaviour and interests of people in the Internet environment.	180 days
Google ads	Advertising Pixel	Facebook	Used to show ads based on behaviour and interests of people in the Internet environment.	540 days

How do we use cookies?

To save personal settings

These cookies allow our Website to remember information affecting the appearance or behaviour of the Website, e. g., the desired language or area of your location. These cookies can also help you change the text size, font and other elements of websites that can be personalized. Cookies also help to use the website by providing a convenient product offer browsing, placing an order and making payments for the ordered product.

Provision of protection

We use cookies to authenticate users, prevent fraudulent use of access data and protect user data from unauthorized access.

Registration of statistics, visitor flow measurements and network security

Every time you visit our Website, the analytics software saves cookies anonymously. They help find out how many users visit our site repeatedly. In this way, we better understand the behaviour of our visitors on the website, as well as what they prefer and what interests them. This information is in no way related to other information. For example, we know that this section is repeatedly visited by a number of people a month. However, we don’t know who they are.

The data we record can also be used to protect our network and prevent attacks.

To save registration information

For registered users or recurrent buyers, we store login or logout information in cookies, as well as help to fill in the text input fields provided in the Website forms.

Advertising purposes

We also use cookies to increase the attractiveness of ads to you as a user and to offer advertisers better advertising conditions. Cookies are usually used to select ads based on what’s relevant to users (remarketing), to improve campaign productivity reports, and to prevent users from seeing ads they’ve already seen. We only use remarketing data for visitor segmentation to help ensure relevant ad content. Segments are created on the basis of several general visitor behaviour patterns and the content of the pages they visit.

If we have your consent to the processing of personal data for marketing purposes, including profiling, we may associate these cookies dedicated to this purpose with your other personal data and, using automated processing, create individual profiles that are then used for personalized advertising purposes.

How to customize the use of cookies

In most cases, there is no set way to disable cookies without complete or partial restriction of the Website functionality. If you’re not sure whether cookies are necessary to use the services provided properly, we recommend you to keep settings.

You can customize and disable cookies using the tool provided on the Website when you open this website for the first time.

You can delete cookies in your browser – this option is usually available in the “History of visited websites”.

Browsers also allow you to block cookies on your computer, e. g., by using the “Enable tracking protection” function. Please note that in this case functionality of our Website may be limited. For information on how to set cookies in your browser, visit the Website of the respective browser.

Additionally, useful information about cookies, how to refuse saving of a cookie, as well as the possibility to exclude the use of various analytics cookies by third parties is available at https://www.youronlinechoices.com/.

Transfer of personal data outside the European Union and the European Economic Area (EU/EEA)

We always try to process your personal data in the territory of the European Union and the European Economic Area (EU/EEA).

The transfer and processing of personal data outside the EU/EEA may take place if it has a legal basis, i. e., to fulfil a legal obligation, conclude or perform a contract, or with your consent, and appropriate safety measures have been taken.

In some cases, our processors may be located outside the EU/EEA, however, in such cases we continue to pay attention to the reliability of the processors and the fulfilment of requirements of the General Data Protection Regulation on preconditions and safeguards for such transfers of data (e. g., by concluding standard data protection clauses).

How long is your personal data stored?

All personal data obtained from you is stored for as long as you use our services (including delivery of products, ensuring obligations of warranty or product compliance), or until you withdraw your consent if your personal data is processed on the basis of it. Longer period of storage of personal data is permitted in order to comply with the requirements of laws regarding the minimum period of storage of documents or information or to protect our legitimate interests.

At the end of this period, we will securely delete your personal data or make it inaccessible (archiving) or unidentifiable so that it can no longer be linked to you.

We reserve the right to delete or permanently anonymize your data earlier if the legal basis for its use has been lost or it is not necessary for the provision of further service.

You are responsible for storing and deleting the data located on your end-device (use the respective settings of your browser to clear cache and cookies).

How do we protect your personal data?

We provide, constantly review and improve protection measures, in order to protect your personal data from unauthorized access, accidental loss, disclosure or destruction. In order to implement this, we use modern technologies, technical and organizational measures, including using firewalls, intrusion detection, analysis software and data encryption.

However, we recommend you to comply with the general computer and Internet use security rules, as well as the requirements for protection and storage of your personal data, and we do not assume liability for unauthorized access to your personal data and/or data loss due to your fault or negligence.

What are your rights?

The data subject has general rights provided for by the General Data Protection Regulation and other applicable legal enactments (laws and regulations), including:

– Access to personal data

You have the right to request from us a confirmation whether we process personal data related to you, and in such cases to request access to that personal data, or to provide information about personal data if provision of direct access is not intended.

– Correction of personal data

If you believe that the information about you is incorrect or incomplete, you have the right to ask us to correct or supplement it.

– Withdrawal of consent

To the extent that we process your personal data on the basis of your consent, you have the right to withdraw your consent to the processing of personal data at any time. Withdrawal of consent will not affect the lawfulness of the processing based on the consent given before the withdrawal, as well as in cases where the data processing is carried out under another legal basis.

– Objection to the data processing for the purpose of supplying addressed information

You have the right to object to the processing of your personal data for the purposes of direct marketing, supply of addressed information, at any time.

– Objection to the processing based on legitimate interests

You have the right to object to the processing of personal data which we process on the basis of our legitimate interests, however, we will continue to process your data even if you object to it, if we have a justified reason to continue processing your personal data. In order to exercise the mentioned right, please submit an application in writing to us.

– Deletion

In certain circumstances, you have the right to ask us to delete your personal data, however, this doesn’t apply to the cases where the law requires us to retain the data. In order to exercise the mentioned right, please submit an application in writing to us.

– Processing restriction

In certain circumstances, you have the right to restrict the processing of your personal data. Please take into account that if you request that your data processing be restricted, it may affect your possibilities to receive our services and purchase products. In order to exercise the mentioned right, please submit an application in writing to us.

– Data transfer

You have the right to receive or transfer your personal data to another data controller. This right only includes the data you have provided to us on the basis of your consent or contract, as well as if the processing is carried out automatically. In order to exercise the mentioned right, please submit an application in writing to us.

What law governs the operation of the website?

The operation of the Website, as well as all relations between you and SUNERGIA are governed by the legal enactments of the European Union.

Who governs the data processing on other linked websites?

The SUNERGIA website may contain links to third-party websites that have their own terms of use and personal data protection, which SUNERGIA does not assume liability for.