Bestnet AS (registration code: 10261109) and its subsidiaries (also referred to as Bestnet or Our) are companies belonging to the AVH Group, which are active in the metal industry, e.g. by manufacturing and selling trailers, providing trailer rental services.

The protection of your personal data is very important to Bestnet. This Privacy Notice (the ” Notice“) explains how we process (e.g. collect, use, protect) your personal data and what your rights are in relation to the processing of your personal data.

When processing your personal data, we comply with Estonian and European Union law, including Regulation (EU) No 2016/679 of the European Parliament and of the Council (hereinafter the General Regulation).

According to the Notice, the data controller is Bestnet, alone or in several companies.

In addition, in certain cases, the controller of personal data may be B2G Group or other

companies belonging to the AVH Group, but only if this is in accordance with the applicable legislation.

Bestnet processes your personal data only for the purposes for which we collected the data from you and to the extent necessary for the fulfilment of those purposes. If the purpose for which we process your personal data has been fulfilled and there is no other basis or obligation to process your personal data, we will delete your personal data. Notice will provide information, for example, when you use Bestnet products, services, applications, e-environments (e.g. an online shop on the internet that allows customers to make transactions) or visit Bestnet websites.

The Notice does not reflect the processing of data by other companies’ products, services, applications, websites, etc., even if it is possible to use them through our services or to access other websites or e-environments through Bestnet’s websites or e-environments.

Bestnet allows you to access the Notice at any time through Bestnet’s websites and at Bestnet’s office at Rae 4, Paldiski 76805 Estonia.

We will refer to, including allow access to, the Privacy Policy, for example when entering into a contract, when offering and selling a service or product, or when providing an e-service (including an online shop). This Notice is an information document and is not part of the contract with you.

We will do our best to keep the Notice up to date and available to you in the ways set out above. We will notify you of changes to the Notice through Bestnet’s websites or other reasonable means.

The AVH Group’s personal data processing policy and the list of companies belonging to the AVH Group can be found here.

Personal data is information about an individual or natural person (previously and hereinafter referred to as you or the Data Subject) by means of which the natural person is identified or identifiable, directly or indirectly. For the sake of clarity, we have divided your personal data into the following categories:

• Examples of personally identifiable information include: first and last name, personal identification number, date of birth, language of communication, identity document number (e.g. passport, ID card, driving licence), etc;
• Examples of contact details are: e-mail address, address, telephone number, etc;
• Examples of data relating to the offer or provision of a service and the offer or purchase of a product are: data relating to the performance of a contract, data relating to the consumption of a service, data relating to the purchase of a product, applications, enquiries, complaints, payment information, etc;
• Examples of financial data are: credit or debts or transactions, etc;
• Examples of communication data include: customer communications with Bestnet by telephone, data collected via email, data collected via social media, data transmitted via messaging, etc;
• Special categories of personal data include: racial or ethnic origin, political opinions, religious or philosophical beliefs or trade-union membership, ethical data, biometric data used to uniquely identify a natural person, health data or data concerning a natural person’s sex life or sexual orientation.

Bestnet does not aim to collect sensitive personal data, but it may become known to Bestnet inadvertently, e.g. if you send your sensitive personal data to Bestnet by e-mail and/or via the online shop.

Bestnet collects your personal information from various sources. The type of personal data collected will depend on, for example, the products you want to buy, the services you want to use or the e-environment you want to use (e.g. ordering from an online shop), and the personal data you need to use to provide them. Of course, it is also important to what extent you consider it necessary to transfer personal data to Bestnet and what consents you give to Bestnet to process your personal data.

We base our collection of personal data on the principles set out in the General Regulation (e.g. the principles of minimisation and purpose limitation).

For example, we collect your personal information in the following ways:

• When offering and/or buying a product (e.g. from an online shop);
• When using the Service;
• When subscribing to newsletters;
• Making requests for information (e.g. price enquiries), complaints, etc;
• We may also obtain your personal data from other sources, as necessary, should this prove necessary for the conclusion, performance, performance or enforcement of a contract or to comply with legal obligations.

The processing of personal data must be justified and comply with the principles relating to the processing of personal data. There are several legal grounds for processing personal data under the General Regulation, but in this case Bestnet processes personal data on the following grounds: for the performance of legal obligations, for the conclusion and performance of a contract, on the basis of Bestnet’s legitimate interest and with the data subject’s consent.

We therefore process your personal data on four different legal bases. Please note that different retention periods apply to the processing of these personal data and that you have different rights to influence the processing of your personal data. More information on this can be found in the text below.

Legislation, i.e. compliance with a legal obligation

Compliance with a legal obligation is the processing of personal data in a way that is required by applicable law and Bestnet is obliged to do so to the extent that Bestnet is required to do so by law. This data processing is not at Bestnet’s or your discretion, as it is a legal obligation that must be respected.

For example, the following objectives fall under this heading:

• Accounting data;
• Responding to queries and reporting infringements to public authorities, including supervisory authorities;
• Notifying individuals of a breach.

Conclusion and performance of the contract, including enforcement.

In this case, the processing of personal data is mainly because we offer and/or sell you products or services, and in order for Bestnet to be able to do so, it is necessary to process your personal data. As in other cases, we will keep the processing of your personal data to a minimum, i.e. we will process your personal data minimally for the purposes for which it is collected.

For example, in this case we process your personal data for the following purposes:

• Pre-contractual relations, e.g. making an offer;
• Identification of the person or data subject, including the identification of the data subject’s representative;
• Order management;
• Serving the person or data subject, e.g. sending reminders;
• Fulfilment of a contractual obligation, e.g. delivery of a product;
• Managing documentation related to contracts;
• Ensuring contractual quality;
• Billing, e.g. preparing invoices.

Processing of personal data based on consent

With your consent, we will process your personal data only to the extent and for the purposes for which you have given your consent.

For example, we ask for consent to process personal data for the following purposes:

• Marketing offers and notifications (SMS, MMS, e-mails, etc.)
• Transfer personal data for marketing processing to other companies in the AVH Group and to processors.

The consent given by the data subject is given voluntarily, knowingly and unambiguously. Consent can be withdrawn by the person at any time, in writing or in a format that can be reproduced in writing (e.g. by sending an email with a statement of withdrawal of consent and that meets the legal requirements). Consent is valid until it is withdrawn or until new consent is given. Withdrawal of consent does not have retroactive effect. Depending on the way consent is given and withdrawn, this may apply for a certain period of time. There may be a longer delay if you give or withdraw your consent on paper, in which case Bestnet will not be able to change it quickly in the database.

Legitimate interest

Legitimate interest means Bestnet’s interest in processing personal data in connection with Bestnet’s business activities in order to provide you with better services and products and thereby to improve them. In this case, we can provide you with the services, products, support, etc. that you expect from Bestnet. On the basis of legitimate interest, we will process your personal data if the processing is necessary and compatible with your rights and interests.

For example, we process your personal data on the basis of legitimate interest for the following purposes:

• Organising campaigns;
• For data exchange within the AVH Group, if necessary;
• To maintain a customer relationship, e.g. a conversation with Bestnet;
• Bestnet for the protection of property, e.g. video surveillance.

We consider it necessary to point out that the purposes for which we process personal data under the above legal bases are not exhaustive, but we will always process your personal data in accordance with the law. If you have any questions about the processing of your personal data, we are always happy to answer them. You can find our contact details at the end of the privacy notice, contact Bestnet.

Personal data may be processed by the companies of the AVH Group if it is necessary for the management and administrative decisions of the Bestnet company and in compliance with applicable legislation.

Bestnet’s partners are companies that process your personal data on Bestnet’s behalf. Under the General Regulation, they are processors of Bestnet. Processors will not use personal data for any purpose other than to carry out activities agreed with Bestnet, such as selling or supplying you with a product.

Authorised processors are companies located in Estonia, in the European Union, in the European Economic Area, but in individual cases they may also be located outside this area. In all cases, we have put in place measures to ensure the security of the processing of your personal data in these countries.

If a situation arises in which Bestnet’s cooperation partner is to be regarded as a co-responsible processor under the law, which means that in this case (e.g. when a product is sold) both we and the cooperation partner are responsible for your personal data, then in addition to Bestnet’s terms and conditions, the cooperation partner’s terms and conditions for the protection of personal data also apply.

For a list of Bestnet’s partners and companies belonging to the AVH Group, click here.

Bestnet may also disclose your personal data to competent public authorities (e.g. the courts, the police) if required to do so by law. We will therefore only transfer personal data in accordance with the law. We may disclose your personal data to whistleblowers, as long as we only do so in accordance with the law.

Anonymous data is not personal data as it does not allow the identification of a natural person. We may process such data for other purposes and for other persons. Also, if additional legal obligations apply to this data, we will comply with them.

We will retain your personal data for as long as it is necessary to achieve the purpose for which the personal data is processed or for as long as required by applicable law.

In certain cases, we will keep your personal data for longer than the period referred to in the list below, for example, we will not automatically apply an expiry date in the event of a debt or a dispute.

We consider it important to point out to you that the following list is not exhaustive, but for example, we keep your personal data as follows:

Video surveillance recordings (to be deleted after 1 month at the latest, unless otherwise provided by law); Quotation information, who does not enter into a contract (to be deleted after 2 years at the latest, unless otherwise provided by law);

Events relating to the data subject, e.g. counselling (to be deleted after 2 years at the latest, unless otherwise required by law);

Contractual performance information (e.g. in Estonia for the duration of the contract and for at least 3 years after expiry of the contract);

Accounting data (e.g. in Estonia, we delete after 7 years from the end of the financial year).

Bestnet uses the necessary IT and organisational security measures to ensure the security of the processing of personal data. Measures include, for example, protection of workers, office buildings, technical equipment. Bestnet employees are subject to data (including personal data) confidentiality requirements. In addition, they will receive training on personal data protection.

Bestnet’s cooperation partners, i.e. processors and companies of the AVH Group, are obliged to ensure up-to-date security measures when processing your personal data.

You can give Bestnet your consent to use your data for direct marketing purposes. If you have given your consent, it is possible to receive marketing offers and notifications from us and our partners via an e-channel (e.g. SMS, e-mail).

Consents to process data for direct marketing purposes will be taken separately from other terms and conditions of the contract, for example by ticking the box that you wish to receive offers. In case you only want to subscribe to Bestnet marketing offers or notifications, some Bestnet websites allow you to do so. To do this, you simply need to enter your email address on the website and then confirm in an email sent to the same email address that you agree to receive future marketing offers and communications. In this case, you will receive general Bestnet and partner offers.

You may withdraw this consent at any time by using the opt-out link at the end of the marketing offer or by sending an email to loobu@tiki.ee or by any other means we provide.

You, or your representative where you have given him or her the appropriate rights, have the following rights in relation to your personal data:

• The right to access your personal data (e.g. the sources and purposes of their use) in accordance with the applicable law and to the extent provided for in the applicable legislation;
• The right to request the modification and/or rectification of your personal data in accordance with the procedure and to the extent provided for by applicable law;
• The right to request the restriction or erasure of the processing of your personal data in accordance with the procedure and to the extent provided for by applicable law;
• The right to object to the processing of your personal data where we process your personal data on the basis of a legitimate interest.
• The right to request the transfer of data in accordance with the procedure and to the extent provided for in the applicable legislation. Please note that this right is limited by legislation on several grounds;
• The right to apply to Bestnet, the supervisory authority or the courts. If you would like more information about the processing of your personal data, you can always contact us via the contact details published on Bestnet’s website(https://www.tiki.ee/).

If you feel that the information you have received was not sufficient or you believe that the terms and conditions for processing your personal data have been breached, you can contact Bestnet’s Data Protection Specialist (andmekaitse@tiki.ee). You always have the right to seek the protection of your personal data by the Data Protection Inspectorate or a court. The Data Protection Inspectorate is the national supervisory authority that can be contacted for advice or assistance on personal data.

These rights are not necessarily absolute and are governed by existing European Union and national legislation.

Use of cookies

Cookies are small text files that are downloaded to the user’s computer when using a website, and as a result the browser can transmit cookie information each time the website is used. Cookies are designed to improve and simplify the visitor’s experience on the website.

You can choose to disable cookies from your browser devices. However, in some cases, it may, for example, slow down the browsing of a web page, reduce the functionality of a certain web page. At this time, Bestnet’s websites contain links to third-party websites and services and social media extensions (e.g. Facebook). These extensions are mainly designed for statistical or marketing purposes. Third party extensions on Bestnet websites are subject to the third party privacy policy. Therefore, we recommend that you familiarise yourself with the practices for the protection of such personal data.

For more information on how to use and manage cookies in the most common browsers, see:

Internet Explorer: http://support.microsoft.com/kb/278835

Chrome: https://support.google.com/chrome/answer/95647?hl=en

Firefox: http:%20Recent%

Opera: https://help.opera.com/en/latest/web-preferences/

Safari: http://support.apple.com/kb/PH5042

Bestnet AS authorised processors or cooperation partners

Bestnet AS’s partners process Employees’ personal data (hereinafter also referred to as the Data) on behalf of Bestnet AS and the partners do not use the Data for any purpose other than to carry out the activity or activities agreed with the controller, i.e. Besnet AS. Examples of such activities may include the provision of a service, the sale of products, the storage of contracts and many other activities that involve the processing of personal data.

Not all Bestnet AS’s partners always process all personal data, but process those data whose processing is necessary for the purpose.

Bestnet AS partners are the following companies:

LHV Bank AS
Business registration code: 10539549
Address: Tartu mnt 2, 10145 Tallinn, Estonia
E-mail: info@lhv.ee

ESTO AS
Business registration code: 14180709
Address: Tornimäe tn 2, 15010 Tallinn, Estonia
E-mail: info@esto.ee

Epicor Software Estonia OÜ
Business registration code: 10539549
Address: Tartu mnt 2, 10145 Tallinn, Estonia
E-mail: tteder@epicor.com

Synerto OÜ (Synergy)
Business registration code: 11557740
Address: Peetri tee 20c, Peetri alevik, 75312 Rae vald, Harjumaa
E-mail: info@synerto.eu

Taavi Tarkvara OÜ (Taavi)
Business registration code: 10265337
Address: Turu plats 5-17, 11611 Tallinn, Estonia
E-mail: info@taavi.ee

Sector Digital OÜ
Business registration code: 14091408
Address: Liivalaia 20a, 10118 Tallinn, Estonia
E-mail: info@sektordigital.com

This Policy was last modified on 31.03.2023.