HUGO AND WEBSITE’S PRIVACY POLICY

  1.     TERMS USED IN THE PRIVACY POLICY
  • GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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).
  • Personal data any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as the person’s name, surname, identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Personal data processing – any operation or set of operations which is performed on 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 by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • Controller – a natural or legal person which, alone or jointly with others, determines the purposes and means of the processing of Personal data.
  • Processor – a natural or legal person which processes Personal data on behalf of the Controller.
  • Data subject – indirectly or indirectly identified or identifiable natural persons – visitors of website www.hugo.legal/de and users of HUGO.
  1.     GENERAL PROVISIONS

This website Privacy Policy (henceforth – Privacy Policy) are a set of rules set by OÜ HUGO designed to provide information about OÜ HUGO Personal data processing purposes, legal basis on processing data acquired from the website www.hugo.legal/de and the HUGO lawbot  (hereinafter – HUGO)  therein, scope, protection, processing and storage periods, Personal data recipients, and Data subject’s rights during data acquisition and processing.

The full OÜ HUGO Privacy Policy on processing of Personal data can be accessed by request, by sending a request to the OÜ HUGO e-mail address.

 

  1.     THE CONTROLLER

OÜ HUGO

Registration No: 12821618

Legal address: Tartu mnt 2, 10145, Tallinn

Contacts: hugo@hugo.legal

  1.     CONTACT PERSON IN PERSONAL DATA PROTECTION MATTERS

In case of any questions concerning the processing of Personal data carried out by OÜ HUGO, we kindly ask to contact us by sending a message to the e-mail address: hugo@hugo.legal.

 

  1.     CATEGORIES AND PURPOSE OF THE PROCESSED PERSONAL DATA

The OÜ HUGO website www.hugo.legal/de (hereinafter – Website) processes Personal Data, providing customers with the opportunity to familiarise themselves with the HUGO, offer of the services, as well as ensures convenient and rapid communication by using the lawbot on the Website for acquiring information on the Data subject’s case. OÜ HUGO processes the following categories of Personal Data for the specific following purposes:

 

Purpose of processing Personal data Personal data category
Receiving and administering applications obtained from HUGO. Identification data – name, surname;

 

Contact details – 

E-mail; address

 

Other information — 

Bank name, bank account, date of birth, period for which the User has been a client to the respective bank, 

 

For the ensuring of functioning and analytics of the Website Cookies and their stored information (see Table 1.1)
To send offers, commercial messages or reminders Identification data – name

 

Contact details – 

e-mail

 

 

  1.     LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

OÜ HUGO processes Personal data on the basis of the following legal grounds contained in Article 6 of GDPR:

  • The conclusion and performance of a contract – in order to ensure the processing of applications received through HUGO, the conclusion of a contract and the further pursuing of the claim.
  • Legitimate interest – in order to ensure that the rights and interests of the Data subjects or OÜ HUGO are defended, to execute the legitimate interest of OÜ HUGO to carry out direct marketing activities, provide answers to information requests from Data subjects and complaints.
  • Consent– in certain cases, the processing of Data subject’s Personal may be carried out on the basis of freely made and unambiguous consent. Such consent may be requested by the OÜ HUGO to provide other data processing activities where this is necessary for legitimate purposes and does not endanger the rights and freedoms of the client, such as the deployment of cookies and the analysis of visits related to the Internet site..
  1.     SOURCES OF PERSONAL DATA

The main source of the Personal data acquired from the Website is the Data subject itself, for example, when the Data subject provides answers to HUGO on the Data subject’s case. Personal data may also be obtained by OÜ HUGO if the Data subject has voluntarily contacted the Controller.

  1.     DATA PROCESSORS

In order to ensure the functioning of the Website and the fulfilment of obligations against the Data subject, OÜ HUGO is entitled to attract and authorise external service providers to carry out separate activities on behalf of OÜ HUGO, for example, through the involvement of IT service providers, lawyers who pursue the Data subject’s claim in court or other partners. If, in the performance of these tasks, entities authorised by OÜ HUGO process the Data subject’s data held by OÜ HUGO”, the authorised party of the relevant task shall be deemed to be the Processors of Personal Data held by OÜ HUGO, and OÜ HUGO shall have the right to transmit the necessary Personal data of the Data Subject to the Processors in the extent it is necessary to perform the allocated activities.

Information on the Personal Data held by the Processors and sub-processors OÜ HUGO provides at the request of the Data Subject.

  1.     TRANSFER OF PERSONAL DATA TO THIRD PARTIES

Personal data held by OÜ HUGO shall not be transferred to third parties except in cases where:

  •  the third party concerned must transfer the data within the framework of the contract in order to carry out any function necessary for the performance of the contract or delegated by law;
  •  for the transfer of Personal data, the Data subject has given clear, unambiguous consent;
  • the disclosure of Personal data to the persons provided for in external regulatory enactments, upon a reasonable request is an obligation imposed on  OÜ HUGO by law, and in accordance with the procedures and to the extent specified in the external regulatory enactments;
  • The protection of the legitimate interests of OÜ HUGO must be ensured, e.g. by turning to a court or other State authorities against a person who has infringed the legitimate interests of OÜ HUGO.

When transferring personal data to third parties, OÜ HUGO assesses the level of protection provided by third parties in accordance with regulatory enactments in order to ensure the greatest protection possible of the Data subject’s information.

  1. PERSONAL DATA PROTECTION

OÜ HUGO protects Personal data of the Data Subject by using opportunities provided by modern technologies, taking into account existing privacy risks and the reasonably available organisational, financial and technical resources of OÜ HUGO, including, by ensuring the following security measures:

  •  provides protection against unauthorized access to OÜ HUGO internal IT systems, maintained databases and Personal data stored in electronic mail;
  • OÜ HUGO uses an SSL-security certificate in operation of the www.hugo.legal/de Website, providing encrypted data transmission between the Data subject and the server on which the Data subject’s Data, which has been received through the Website, is stored;
  • grants rights of access to the internal IT systems and databases of OÜ HUGO  only to a limited number of persons employed by OÜ HUGO
  1. LINKS TO OTHER SITES AND SOCIAL NETWORKS

OÜ HUGO Website may place links to other websites. OÜ HUGO does not control and shall not be held responsible for the content provided by a third-party website or Personal Data collected by a third-party website. Given that OÜ HUGO uses the following social media networks:

  Facebook

  Linkedin

– Whatsapp

We inform that when any of the aforementioned websites or any other third-party website is visited, a privacy policy of the third-party website holder applies to the processing of Personal data of the Data subject. We strongly advise to get acquainted with the policies provided by third parties under the privacy section of the respective website.

  1. STORAGE OF PERSONAL DATA

Personal data for the purpose of sending commercial materials, as well as for the purpose of processing and providing a response to incoming Data subject’s applications, shall be stored until the Data subject withdraws his Consent or objects to the Processing of Personal data or for a period of three years after the provision of services.

  1. COOKIES

OÜ HUGO informs that cookies are used to ensure the functioning of the www.hugo.legal/de Website as well to improve user experience and to obtain user statistics..

Small files stored on Website visitor (hereinafter – User) devices. At the time the User accesses OÜ HUGO Website, our system reads these cookies and adjusts the settings accordingly. Cookies are like a key that your browser requests for customized information. Cookies are also used for other functions such as for obtaining statistics.

The Website may use the following cookies:

  • Necessary cookies – provides customized Website operation according to the choices made by the user, for instance, by saving the cookie policy approval. Cookies are required to enable the User to take full advantage of the features of the Website and to navigate the site. Without these cookies, it is impossible to provide the services offered by the site to the User, they are essential for the functioning of the site.
  • Functionality cookies – Cookies that provide personalized and better user experience – collect information about the User’s habits on the Website (frequently visited pages, remembers language selection), and provide the ability to watch a video or perform different activities on the site. Cookies can be anonymized and do not store information about other site visits.
  • Preference and Statistics cookies – Cookies do not collect Personal data, the information is anonymous. Remembers User habits, such as the most visited pages and improves site performance, as well as analyzes usage and other activities.
  • Third party cookies – Any third party cookies, such as Google Analytics etc. cookies resulting from the use of third party provider services, which are needed to enable a third party full service to the Website owner.
  1. SUBCATEGORIES OF COOKIES AND EXPIRY

 Each cookie is given an expiry for the length of time it stores Personal data and processes it. The cookie may also not have a specific running time, such cookie categories can be further subdivided into session and persistent cookies, which describe the nature and time of the cookie:

  • Session –  session cookies are placed for the duration of the site visit and the information obtained is not stored longer than the site visit session.
  • Persistent – the information is placed and stored on the user’s computer even after the site visit. The expiry time of storing the information may vary for each cookie.
  1. WHAT TYPE OF COOKIES ARE USED IN THE WEBSITE www.hugo.legal/de?
Cookie name Provider Category Purpose Type Expiry
PHPSESSID hugo.legal Necessary Preserves the user’s session state across page requests. HTTP Session
language hugo.legal Necessary Saves the user’s preferred language on the Website. HTTP 1 year
wp-rest-enabled-ping hugo.legal Necessary Used in context with the Website’s WordPress theme. The cookie allows the Website owner to implement or change the Website’s content in real-time. HTTP 1 day
connect.sid hugo.legal Necessary The cookie is necessary for secure log-in and the detection of any spam or abuse of the Website. HTTP 1 day
_dc_gtm_UA-# hugo.legal Preference and Statistics cookies Used by Google Tag Manager to control the loading of a Google Analytics script tag. HTTP 1 day
_hjAbsoluteSessionInProgress hugo.legal Preference and Statistics cookies This cookie is used to count how many times a Website has been visited by different visitors – this is done by assigning the visitor an ID, so the visitor does not get registered twice. HTTP 1 day
collect google-analytics.com Third party cookies Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitor across devices and marketing channels. Pixel Session
ads/ga-audiences google.com Third party cookies Used by Google AdWords to re-en gage visitors that are likely to convert to customers based on the visitor’s online behaviour across websites. Pixel Session
tr facebook.com Third party cookies Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. Pixel Session
  1. GOOGLE ANALYTICS

In order to help OÜ HUGO better understand its visitors, OÜ HUGO uses the services of Google Analytics web analytics platform, which stores a Google Analytics cookie, which, in combination with the code embedded in OÜ HUGO Website, collects information about User visits and sends it to Google servers. In turn, OÜ HUGO accesses and analyzes the obtained statistics and uses it to customize the Website accordingly to create a better user experience for Users. The information collected is anonymised before Google stores it on its servers. The information which can be collected is:

  • Browser type / version,
  • operating system used,
  • Referrer URL (the previously visited page),
  • Host name of the accessing computer (IP address),
  • Time of the server request.

If the User does not wish Google Analytics to process their Personal data in question, the User may deny the placement and analysis of such cookies by installing an Google Analytics Opt-out Program on the Users‘ device. (Google Chrome Opt-out Tool available at:  https://tools.google.com/dlpage/gaoptout?hl=en)

  1. FACEBOOK PIXEL

This website uses „Facebook Pixel“ of the social network „Facebook“ for:

  • remarketing purposes. This allows us to display interest-based advertisements to users of the Website when they visit the social network „Facebook“ or other Websites also using this tool. In this way, we pursue the interest in displaying advertisements that are of interest to you in order to make our Website or offers more interesting for you.  
  • The purpose of ensuring that our Facebook Ads match the potential interest of users. With the help of the Facebook Pixel, we can track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our Website after clicking on a Facebook ad (measuring and analyzing „conversion“).

Due to the marketing tools used, your browser automatically establishes a direct connection with the Facebook server as soon as you have agreed to the use of cookies requiring your consent. Through the integration of the Facebook Pixel, Facebook receives the information that you have clicked or visited our Website from an advertisement. If you are a registered user on Facebook, Facebook can assign the visit to your account.

The processing of this data by Facebook takes place within the framework of Facebook’s data policy. Special information and details about the Facebook Pixel and its functionality can also be found in the Facebook help area.

The “Facebook Custom Audiences” function can be deactivated in the Cookie Settings and for logged in users at https://www.facebook.com/settings/?tab=ads#

18.DISABLING COOKIES

All cookies, except cookies that are required to ensure the functioning of the Website, can be controlled or deleted. Most Internet browsers can be set up to block the storage of cookies on your device. Note that you will then need to adjust individual settings every time you visit the site, and some services and features on the site may not work. For more information on disabling cookies, visit: https://www.aboutcookies.org/.

  1. EXERCISING OF DATA SUBJECT’S RIGHTS

The Data subject has the right to be informed about what Personal data is at OÜ HUGO disposal in relation to the processing of Data subject’s Personal data, and to request access to, correction, replenishment or deletion of their Personal data, to limit the processing, and to object to the processing of Personal data, including the processing based on the legitimate interests of OÜ HUGO, as well as to exercise the right to data portability, to the extent which OÜ HUGO is able to provide technically. The rights of the Data subject shall be exercised to the extent that they do not conflict with OÜ HUGO obligations under the regulatory enactments.

The Data subject may submit a request for the exercise of his rights by submitting a form for the implementation of Data subject’s rights  to the OÜ HUGO e-mail address: hugo@hugo.legal

OÜ HUGO shall send a reply to the Data subject’s electronic mail address within 30 days of the receipt of the Data Subject’s request by the person responsible for the processing of Personal data, or through postal services by signed-for mail. If there is a need to clarify the information or carry out a more detailed investigation before answering, the response may take longer than 30 days, depending on the content of the request, but not more than 60 days.

Disputes related to the processing of Personal data shall be resolved through negotiations between the Data subject and OÜ HUGO. If the Data subject considers that the processing of Personal data violates the person’s rights and interests in accordance with the applicable laws and regulations, the Data subject has the right to file a complaint to OÜ HUGO responsible person for processing Personal data by submitting a complaint, or by turning straight to the respective Data Protection Commissioner in the Federal Republic of Germany.