PRIVACY POLICY
Updated on October 3rd, 2023
Ajapaik (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how
your
personal information is collected, used, and disclosed by Ajapaik.
This Privacy Policy applies to our website, and its associated subdomains (collectively, our “Service”)
alongside our application, Ajapaik. By accessing or using our Service, you signify that you have read,
understood, and agree to our collection, storage, use, and disclosure of your personal information as
described in this Privacy Policy and our Terms of Service.
Definitions and key terms
To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are
referenced, are strictly defined as:
- Cookie: small amount of data generated by a website and saved by your web browser. It is used to
identify your browser, provide analytics, remember information about you such as your language
preference or login information.
- Non-profit Organization (NPO): when this policy mentions “NPO,” “we,” “us,” or “our,” it refers to
MTÜ Eesti
Fotopärand,
(Raekoja tn 6 Tallinn Harjumaa 10146), that is responsible for your information under this Privacy
Policy.
- Country: where Ajapaik or the owners/founders of Ajapaik are based, in this case is Estonia
- User: refers to the company, organization or person that signs up to use the Ajapaik Service.
- Device: any internet connected device such as a phone, tablet, computer or any other device that
can
be used to visit Ajapaik and use the services.
- IP address: Every device connected to the Internet is assigned a number known as an Internet
protocol
(IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be
used to identify the location from which a device is connecting to the Internet.
- Personnel: refers to those individuals who are employed by Ajapaik or are under contract to perform
a
service on behalf of one of the parties.
- Personal Data: any information that directly, indirectly, or in connection with other information —
including a personal identification number — allows for the identification or identifiability of a
natural
person.
- Service: refers to the service provided by Ajapaik as described in the relative terms (if
available)
and
on
this platform.
- Third-party service: refers to partners and others who provide our content or whose products or
services we think may interest you.
- Website: Ajapaik’s site, which can be accessed via this URL: ajapaik.ee
- You: a person or entity that is registered with Ajapaik to use the Services.
What Information Do We Collect?
We collect information from you when you visit our website, register on our site, interact with our website,
subscribe
to
our newsletter.
- Name / Username
- Email Addresses
We also collect information from mobile devices for a better user experience, although these features are
completely optional:
- Location (GPS): Location data helps show historic photos near your location. Location access is not
required to use the application.
- Photo Gallery (Pictures): Granting photo gallery access allows the user to upload picture from their
photo gallery, uploading pictures is voluntary and not required to use the application.
When does Ajapaik use end user information from third parties?
Ajapaik will collect End User Data necessary to provide the Ajapaik services to our users. End users
may voluntarily provide us with information they have made available on social media websites. If you
provide us with any such information, we may collect publicly available information from the social media
websites you have indicated. You can control how much of your information social media websites make
public by visiting these websites and changing your privacy settings.
When does Ajapaik use user information from third parties?
We may occasionally collect information that is made publicly available on social media websites. You can
control how much of your information.
social media websites make public by visiting these websites and changing your privacy settings.
Do we share the information we collect with third parties?
We may share the information that we collect, both personal and non-personal, with third parties such as
partners, and others who provide our content or
whose products or services we think may interest you. We may also share it with our current and future
affiliated NPOs, and if we are involved in a merger or other NPO reorganization, we may also share or
transfer your personal and non-personal information to our
successors-in-interest.
We may engage trusted third party service providers to perform functions and provide services to us, such as
hosting and maintaining our servers and the website, database storage and management, e-mail
management. We will likely share your personal information, and
possibly some non-personal information, with these third parties to enable them to perform these services
for
us and for you.
We may share portions of our log file data, including IP addresses, for analytics purposes with third
parties
such as web analytics partners and application developers. If your IP address is shared, it
may
be used to estimate general location and other technographics such as connection speed, whether you have
visited the website in a shared location, and type of the device used to visit the website. They may
aggregate
information about what you see on the website and then provide auditing, research and
reporting for us.
We may also disclose personal and non-personal information about you to government or law enforcement
officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to
respond
to claims, legal process (including subpoenas), to protect our rights and interests or those of a third
party, the
safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable
activity, or to
otherwise comply with applicable court orders, laws, rules and regulations.
Where and when is information collected from users?
Ajapaik will collect personal information that you submit to us. We may also receive personal information
about you from third parties as described above.
How Do We Use The Information We Collect?
Any of the information we collect from you may be used in one of the following ways:
- To personalize your experience (your information helps us to better respond to your individual
needs)
- To improve our website (we continually strive to improve our website offerings based on the
information
and feedback we receive from you)
- To improve customer service (your information helps us to more effectively respond to your customer
service requests and support needs)
- To administer a contest, promotion, survey or other site feature
- To send periodic emails in case you've signed up for the newsletter
How Do We Use Your Email Address?
By submitting your email address on this website, you agree to receive emails from us. You can cancel your
participation in any of these email lists by contacting us at:
info@ajapaik.ee.
We only send emails to
people who have authorized us to contact
them, either directly, or through a third party. We do not send unsolicited commercial emails, because we
hate spam as much as you do. We may send newsletters to users who have accepted newsletters on our website.
How Long Do We Keep Your Information?
We keep your information only so long as we need it to provide Ajapaik to you and fulfill the purposes
described in this policy. This is also the case for anyone that we share your information with and who
carries
out services on our behalf. When we no longer need to use your information and there is no need for us to
keep it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or
depersonalize it so that we can't identify you.
How Do We Protect Your Information?
We implement a variety of security measures to maintain the safety of your personal information when you
enter, submit, or access your personal information. We offer the use of a secure server.
All
supplied personal information is transmitted via Secure Socket Layer (SSL) technology and then
encrypted into our database only to be accessible by those authorized with
special access rights to such systems, and are required to keep the information confidential. Ajapaik does
not store any user sensitive information, only personal information as stated in "What Information Do We
Collect?"
We cannot, however, ensure or warrant the absolute security of any information you transmit to Ajapaik
or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a
breach of any of our physical, technical, or managerial safeguards.
Could my information be transferred to other
countries?
Ajapaik is incorporated in Estonia. Information collected via our website, through direct interactions with
you,
or from use of our help services may be transferred from time to time to our offices or personnel, or to
third
parties, located throughout the world, and may be viewed and hosted anywhere in the world, including
countries that may not have laws of general applicability regulating the use and transfer of such data. To
the
fullest extent allowed by applicable law, by using any of the above, you voluntarily consent to the
trans-border transfer and hosting of such information.
Is the information collected through the Ajapaik
Service secure?
We take precautions to protect the security of your information. We have physical, electronic, and
managerial
procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your
information. However, neither people nor security systems are foolproof, including encryption systems. In
addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while
we
use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If
applicable law imposes any non-disclaimable duty to protect your personal information, you agree that
intentional misconduct will be the standards used to measure our compliance with that duty.
Can I update or correct my information?
The rights you have to request updates or corrections to the information Ajapaik collects depend on your
relationship with Ajapaik. Personnel may update or correct their information as detailed in our internal
NPO policies.
Customers have the right to request the restriction of certain uses and disclosures of personally
identifiable
information as follows.
You can contact us in order to:
- update or correct your personally identifiable
information
- change your preferences with respect to communications and other information you receive
from us,
- delete the personally identifiable information maintained about you on our systems (subject
to
the following paragraph), by cancelling your account. Such updates, corrections, changes and
deletions
will
have no effect on other information that we maintain, or information that we have provided to third
parties
in
accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect
your
privacy and security, we may take reasonable steps (such as requesting a unique password) to verify
your
identity before granting you profile access or making corrections. You are responsible for
maintaining
the
secrecy of your unique password and account information at all times.
You should be aware that it is not technologically possible to remove each and every record of the
information you have provided to us from our system. The need to back up our systems to protect
information from inadvertent loss means that a copy of your information may exist in a non-erasable
form
that will be difficult or impossible for us to locate. Promptly after receiving your request, all
personal
information stored in databases we actively use, and other readily searchable media will be updated,
corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and
technically
practicable.
If you are an end user and wish to update, delete, or receive any information we have about you, you
may do
so by contacting the organization of which you are a customer.
Personnel
If you are a Ajapaik worker or applicant, we collect information you voluntarily provide to us. We
use the
information collected for Human Resources purposes in order to administer benefits to workers and
screen
applicants.
You may contact us in order to
- update or correct your information
- change your preferences
with
respect to communications and other information you receive from us
- receive a record of the
information we have relating to you. Such updates, corrections, changes and deletions will have no
effect on
other information that we maintain, or information that we have provided to third parties in
accordance with
this Privacy Policy prior to such update, correction, change or deletion.
Merger of NPO
We reserve the right to transfer information to a third party in the event of merger or
other
transfer of
all or substantially all of the assets of Ajapaik or any of its Corporate Affiliates (as defined
herein), or
that
portion of Ajapaik or any of its Corporate Affiliates to which the Service relates, or in the event
that we
discontinue our business or file a petition or have filed against us a petition in bankruptcy,
reorganization or
similar proceeding, provided that the third party agrees to adhere to the terms of this Privacy
Policy.
Affiliates
We may disclose information (including personal information) about you to our Corporate Affiliates.
For
purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity which directly or
indirectly
controls, is controlled by or is under common control with Ajapaik, whether by ownership or
otherwise. Any
information relating to you that we provide to our Corporate Affiliates will be treated by those
Corporate
Affiliates in accordance with the terms of this Privacy Policy.
Governing Law
This Privacy Policy is governed by the laws of Estonia without regard to its conflict of laws
provision. You
consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising
between
the
parties under or in connection with this Privacy Policy except for those individuals who may have
rights to
make claims under Privacy Shield, or the Swiss-US framework.
The laws of Estonia, excluding its conflicts of law rules, shall govern this Agreement and your use
of the
website. Your use of the website may also be subject to other local, state, national, or
international laws.
By using Ajapaik or contacting us directly, you signify your acceptance of this Privacy Policy. If
you do
not
agree to this Privacy Policy, you should not engage with our website, or use our services. Continued
use of
the website, direct engagement with us, or following the posting of changes to this Privacy Policy
that do
not
significantly affect the use or disclosure of your personal information will mean that you accept
those
changes.
Your Consent
We've updated our Privacy Policy to provide you with complete transparency into what is being set
when you
visit our site and how it's being used. By using our Ajapaik, registering an account, or making a
purchase,
you hereby consent to our Privacy Policy and agree to its terms.
Links to other websites
This Privacy Policy applies only to the Services. The Services may contain links to other websites
not
operated or controlled by Ajapaik. We are not responsible for the content, accuracy or opinions
expressed in
such websites, and such websites are not investigated, monitored or checked for accuracy or
completeness
by us. Please remember that when you use a link to go from the Services to another website, our
Privacy
Policy is no longer in effect. Your browsing and interaction on any other website, including those
that have
a
link on our platform, is subject to that website’s own rules and policies. Such third parties may
use their
own
cookies or other methods to collect information about you.
Cookies
Ajapaik uses "Cookies" to identify the areas of our website that you have visited. A Cookie
is a
small piece
of
data stored on your computer or mobile device by your web browser. We use Cookies to enhance the
performance and functionality of our website but are non-essential to their use. However, without
these
cookies, certain functionality like videos may become unavailable or you would be required to enter
your
login details every time you visit the website as we would not be able to remember that you had
logged in
previously. Most web browsers can be set to disable the use of Cookies. However, if you disable
Cookies,
you may not be able to access functionality on our website correctly or at all. We never place
Personally
Identifiable Information in Cookies.
Blocking and disabling cookies and similar
technologies
Wherever you're located you may also set your browser to block cookies and similar technologies, but
this
action may block our essential cookies and prevent our website from functioning properly, and you
may not
be able to fully utilize all of its features and services. You should also be aware that you may
also lose
some
saved information (e.g. saved login details, site preferences) if you block cookies on your browser.
Different
browsers make different controls available to you. Disabling a cookie or category of cookie does not
delete
the cookie from your browser, you will need to do this yourself from within your browser, you should
visit
your
browser's help menu for more information.
Kids' Privacy
We collect information from kids under the age of 13 just to better our services. If You are a
parent or
guardian and You are aware that Your child has provided Us with Personal Data without your
permission,
please contact Us. If We become aware that We have collected Personal Data from anyone under the age
of
13 without verification of parental consent, We take steps to remove that information from Our
servers.
Changes To Our Privacy Policy
We may change our Service and policies, and we may need to make changes to this Privacy Policy so
that
they accurately reflect our Service and policies. Unless otherwise required by law, we will notify
you (for
example, through our Service) before we make changes to this Privacy Policy and give you an
opportunity to
review them before they go into effect. Then, if you continue to use the Service, you will be bound
by the
updated Privacy Policy. If you do not want to agree to this or any updated Privacy Policy, you can
delete
your account.
Third-Party Services
We may display, include or make available third-party content (including data, information,
applications and
other products services) or provide links to third-party websites or services ("Third- Party
Services").
You acknowledge and agree that Ajapaik shall not be responsible for any Third-Party Services,
including
their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality
or any
other aspect thereof. Ajapaik does not assume and shall not have any liability or responsibility to
you or
any
other person or entity for any Third-Party Services.
Third-Party Services and links thereto are provided solely as a convenience to you and you access
and use
them entirely at your own risk and subject to such third parties' terms and conditions.
Tracking Technologies
- Local Storage - sometimes known as DOM storage, provides web apps with methods and protocols for
storing client-side data. Web storage supports persistent data storage, similar to cookies but with
a
greatly enhanced capacity and no information stored in the HTTP request header.
- Sessions - are used to identify the areas of our platform that you have visited. A Session is a
small
piece
of data stored on your computer or mobile device by your web browser.
Information about General Data Protection
Regulation (GDPR)
We may be collecting and using information from you if you are from the European Economic Area
(EEA),
and in this section of our Privacy Policy we are going to explain exactly how and why is this data
collected,
and how we maintain this data under protection from being replicated or used in the wrong way.
What is GDPR?
GDPR is an EU-wide privacy and data protection law that regulates how EU residents' data is
protected by
companies and enhances the control the EU residents have, over their personal data.
The GDPR is relevant to any globally operating company and not just the EU-based businesses and EU
residents. Our customers’ data is important irrespective of where they are located, which is why we
have
implemented GDPR controls as our baseline standard for all our operations worldwide.
What is personal data?
Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of
information
that could be used on its own, or in combination with other pieces of information, to identify a
person.
Personal data extends beyond a person’s name or email address. Some examples include financial
information, political opinions, genetic data, biometric data, IP addresses, physical address,
sexual
orientation, and ethnicity.
The Data Protection Principles include requirements such as:
- Personal data collected must be processed in a fair, legal, and transparent way and should only be
used in a way that a person would reasonably expect.
- Personal data should only be collected to fulfil a specific purpose and it should only be used for
that
purpose. Organizations must specify why they need the personal data when they collect it.
- Personal data should be held no longer than necessary to fulfil its purpose.
- People covered by the GDPR have the right to access their own personal data. They can also request
a
copy of their data, and that their data be updated, deleted, restricted, or moved to another
organization.
Why is GDPR important?
GDPR adds some new requirements regarding how companies should protect individuals' personal data
that
they collect and process. It also raises the stakes for compliance by increasing enforcement and
imposing
greater fines for breach. Beyond these facts it's simply the right thing to do. At Ajapaik we
strongly
believe
that your data privacy is very important and we already have solid security and privacy practices in
place
that
go beyond the requirements of this new regulation.
Individual Data Subject's Rights - Data Access,
Portability and Deletion
We are committed to helping our users meet the data subject rights requirements of GDPR. Ajapaik
processes or stores all personal data in fully vetted, DPA compliant vendors. We do store all
conversation
and personal data for up to 6 years unless your account is deleted. In which case, we dispose of all
data in
accordance with our Terms of Service and Privacy Policy, but we will not hold it longer than 60
days.
We are aware that if you are working with EU users, you need to be able to provide them with the
ability
to access, update, retrieve and remove personal data. We got you! We've been set up as self-service
from
the start and have always given you access to your data and your users' data. Our customer
support is available for you to answer any questions you might have about working with the API.
Contact Us
Don't hesitate to contact us if you have any questions.
Via Email:
info@ajapaik.ee