PRIVACY POLICY

1. DEFINITIONS

1.1. Electricity Contract – a contract for the sale and purchase of electricity;
1.2. Electricity Seller –a seller of electricity licensed to operate on the territory of the Republic of Estonia;
1.3. Energy Portal – the totality of all of the internet files accessed through the domains and sub-domains of energiaturg.ee, including photos and php or html files;
1.4. Energiaturg – ENERGIATURG OÜ (Commercial Register code: 12253383, address: Tartu mnt 84a-M302, 10112 Tallinn, website: www.energiaturg.ee);
1.5. User – any person using the Energy Portal;
1.6. Conditions of Use – the conditions set out by Energiaturg for the use of the Energy Portal and the principles of data protection published on the Energy Portal (accessible at http://energiaturg.ee/ettevottest/kasutustingimused/) and additional conditions and directions for other services, which cover both consumers and any other visitors to the Energy Portal, including Electricity Sellers, except in cases where the provisions of the Conditions of Use apply only to the consumer and their use cannot be transferred to or authorised by any other party;
1.7. Service Contract – a contract signed between Energiaturg and the User for the use of the Services;
1.8. Services – all the services supplied by Energiaturg to the User through the Energy Portal. A User registered to use the Energy Portal can apply for price quotes from Electricity Sellers, compare offers from Electricity Sellers, and sign and terminate Electricity Contracts with Electricity Sellers.

2. MEANS OF ACCESSING DATA

2.1. Energiaturg gets data about the User in three ways:
2.1.1. The User transmits the data to Energiaturg, for example by entering a name, email address, postal address or telephone number, or by sending consumption data to Energiaturg or permission to request an offer from an Electricity Seller;
2.1.2. Energiaturg itself collects information about the behaviour of the User and the use of Services, such as the websites visited by the User and the device used to do this, or about the provision of Services, such as consumption data or offers.
2.1.3. Energiaturg gets data from a third party for the requests that the User has authorised Energiaturg or its partner to make, for example the User’s electricity consumption data received through Suletud Ring OÜ from the data warehouse managed by Elering AS.

3. TYPES OF DATA

3.1. Energiaturg gets the following data about the User:
3.1.1. personal data – data in any form about an identified or identifiable physical person, such as a name, email address, postal address, telephone number, IP address or consumption data;
3.1.2. traffic data – other data about how the User uses Services, such as the operating system used by the User, the browser used or the time and date of a visit to a website.
3.1.3. communication data – data on the communication between the User and Energiaturg and between the User and an Electricity Seller in the Energy Portal, such as the contents of messages and postings;
3.1.4. preference data – data on the preferences of the User in using the Energy Portal, such as the preferred language;
3.1.5. transaction data – data on the Services and the amounts of Services bought by the User and the amounts of electricity consumed under electricity contracts signed in the Energy Portal, such as who the User requested and received offers from, who the User has signed Electricity contracts with, and the signing or termination date and time and duration of electricity contracts.

4. FORM OF DATA

Energiaturg keeps the User’s data in such a way that they can be retrieved in written form, but can also make extracts from them in other forms.

5. THE PURPOSES OF DATA PROCESSING

5.1. Energiaturg uses the data:
5.1.1. in carrying out the Conditions of Use and Service Contracts, which may include:

(1.1.a) answering questions from the User, helping or advising the User in the Energy Portal, or collecting feedback from the User;
(1.1.b) providing the Services wanted by the User;
(1.1.c) identifying the User when the User is submitting approvals or statements of intent;
(1.1.d) informing the User of important changes in the Energy Portal;
(1.1.e) fulfilling other obligations or protecting rights under the contract.

5.1.2. for exercising legal rights or carrying out legal obligations, which may include:

(1.1.a) transferring Energiaturg’s assets in the form of rights, obligations, contracts or the company to another party, or transferring the User’s data to another party if Energiaturg merges with that party, who then must observe Energiaturg’s data protection principles;
(1.1.b) bookkeeping;
(1.1.c) resolving disputes and protecting rights that have been breached, for example by passing the data to legal representatives of Energiaturg;
(1.1.d) fulfilling other legal obligations or protecting legal rights such as passing data to investigating authorities, the Consumer Protection Board, the Competition Authority or others.

5.1.3. for other purposes, having first requested the User’s permission for personal data, which may include:

(1.1.a) sending the Energiaturg newsletter to the User if the User has signed up to the newsletter Service;
(1.1.b) collecting and analysing statistics about visits to the Energy Portal;
(1.1.c) increasing the security of the Energy Portal;
(1.1.d) segmenting the Users of the Energy Portal and personalising the Services;
(1.1.e) presenting new Energiaturg products to the User and making special offers that may be of interest to the User;

5.2. Energiaturg may only use personal data for purposes other than those listed in 5.1.3 with the agreement of the User or the permission of a competent authority.

6. TRANSMISSION OF DATA

6.1. Energiaturg does not transmit information received about the User to third parties without the agreement of the User, except in cases defined in these principles and the law.
6.2. Energiaturg may transmit information received about the User to the following parties:
6.2.1. Electricity Sellers, if the User has authorised Energiaturg in writing or in a form that can be converted into a written text to get sales offers from Electricity Sellers for the User;
6.2.2. network operators, Electricity Sellers and the data warehouse operator, if the User has authorised Energiaturg in writing or in a form that can be converted into a written text to request and receive the User’s consumption data and other measuring point data;
6.2.3. authorised processors such as Suletud Ring OÜ who process the User’s data on behalf of and with the authorisation of Energiaturg;
6.2.4. supervisory authorities such as the Consumer Protection Board and the Competition Authority;
6.2.5. Energiaturg’s legal counsel, auditors and bookkeepers.
6.3. Energiaturg may also use the electronic contact data of the User in organising joint bids for electricity by Users and may prepare and request from Electricity Sellers joint offers if the User has declared a willingness to participate in joint bids or offers. In this case Energiaturg ensures that when the User’s electronic contact data are first collected and again later at every occasion that those data are used for direct marketing, the User is given a clear and understandable chance simply and for free to refuse the use of the contact data in this way through the Energy Portal.
6.4. Energiaturg is not responsible if third parties use the User’s data for other purposes and in contradiction of these principles.

7. COOKIES

7.1. Cookies are small text files that are placed in the User’s computer by websites that the User visits.
7.2. The types of cookie used in the Energy Portal are:
7.2.1. Essential cookies – cookies that are important for navigating around the website and using its features. Without these cookies it is not possible to provide the Services that the User wants;
7.2.2. Statistical cookies – cookies that collect information about how Users use the Energy Portal, such as the pages they visit most often and the error messages they receive from the website. These cookies do not collect any information that can be used to identify the User and the information collected is aggregated and made anonymous. The purpose of these cookies is to improve the functioning of the Energy Portal;
7.2.3. Preference cookies – these cookies allow choices made by the User, such as text size or other alterable parameters on the website, and the User’s characteristics in the Energy Portal, such as username, language or geographical location, to be remembered, so that more personalised ways of using the Energy Portal can be proposed.
7.3. The majority of web browsers allow some control over cookies through the settings options. On top of this, Energiaturg asks Users separately for permission to use statistical and preference cookies. Energiaturg does not ask for permission to use essential cookies if the User has declared a willingness to use a Service that does not function without a cookie.
7.4. Energiaturg uses the following cookies:

Cookie name Is kept for Purpose of the cookie Additional information
 Google Analytics _utma  2 years  Statistical cookie

 Google Analytics cookies are used to record information about how Users use the Energy Portal, such as the time of visits to the Energy Portal, whether the User has previously visited a particular page, and from which website the User came to the Energy Portal. These cookies do not collect any information that can be used to identify the User. The purpose of these cookies is to analyse the usefulness of the Energy Portal for Users. Energiaturg does not ask for separate permission from the User to install statistical cookies.

http://www.google.com/analytics/learn/privacy.html

https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

 Google Analytics _utmb  30 minutes  Statistical cookie
 Google Analytics _utmc  until the end of the browser session Statistical cookie
 Google Analytics _utmz  6 months  Statistical cookie
 Energiaturg.ee icl_current_language  1 day  Preference cookie  Remembers the language choice of the User
 Energiaturg.ee et_distinct_id  30 days  Preference cookie  http://docs.trak.io/distinct_id.html
 Energiaturg.ee PHPSESSID  until the end of the browser session  Essential cookie  Remembers information about the User session
 Energiaturg.ee has_logged_in  30 days  Essential cookie  Tests whether the User has logged in

 

8. THIRD PARTIES

8.1. Energiaturg uses MailChimp for subscriptions and deliveries of notifications and newsletters and for collecting and analysing statistical information about subscribers. For more detailed information about the use of this information, see the MailChimp data protection principles at http://mailchimp.com/legal/privacy/
8.2. Energiaturg uses Google Analytics for analysing user traffic. For more detailed information about the use of this information, see the Google Analytics data protection principles at http://www.google.com/analytics/learn/privacy.html.

9. LINKS

9.1. Energiaturg may publish links to the websites of third parties in the Energy Portal. Energiaturg cannot guarantee the protection of the User’s data on websites owned by or maintained by third parties.
9.2. Third party websites may use data protection principles that are different from those of Energiaturg for collecting, transmitting and processing data, and Energiaturg has no control over the application of these principles. Energiaturg is not responsible for the content or operations of third party websites, nor for their practices, rules or principles.
9.3. The User must individually find out what the practices, rules and principles used on third party websites are.

10. VERIFICATION OF IDENTITY

10.1. Energiaturg requires Users to verify their identity when registering, logging in to a user account and making transactions in the Energy Portal by using a PIN 1 code with an ID card, Mobile ID or internet bank link.
10.2. Energiaturg does not see or save the User’s PIN 1 code.

11. RECORDING OF DATA

11.1. Energiaturg keeps the User’s data for as long as is reasonably necessary for operations for which Energiaturg has the right to process data. If the User terminates the Service Contract or the User’s user account has become inactive, then the data associated with it are deactivated and access to them is blocked. In general, Energiaturg keeps data about the User as follows:
11.1.1. personal data are kept for as long as the User’s agreement is in force, or if the personal data were collected under a Service Contract then for as long as that contract remains in force, with requests to the User from time to time to update the personal data and check they are still correct.
11.1.2. traffic data – in accordance with the table on cookies (see point 7.4);
11.1.3. communication data – 10 years after initial collection;
11.1.4. preference data – in accordance with the table on cookies (see point 7.4);
11.1.5. transaction data – 10 years after initial collection;

12. DATA PROTECTION

12.1. To ensure the integrity, availability and confidentiality of the User’s data, Energiaturg applies appropriate organisational, physical and information technological security measures such as:
12.1.1. ensuring that each Energy Portal user has access only to the data permitted to them for processing and to the data processing allowed to them;
12.1.2. preventing unauthorised access to equipment used for processing the data and preventing unauthorised reading, copying and changing of the Energy Portal or unauthorised removal of storage media;
12.1.3. ensuring that it is subsequently possible to ascertain which personal data were saved, changed or deleted in the Energy Portal, when and by whom, or which personal data were accessed in the Energy portal, when and by whom, and which personal data were transmitted, when and by whom.
12.2. A User who uses an ID card, internet bank link or mobile ID for authentication or for signing statements of intent or confirmations must observe all the security requirements and recommendations of the developer and manager of that service. We recommend reading further information on this at http://mobiil.id.ee/ and http://www.id.ee/.
12.3. Energiaturg treats the personal data of Users saved in the Energy Portal as confidential and undertakes to process the personal data of Users while observing the requirements of confidentiality, and obliges Electricity Sellers to do the same in the contracts signed with them.
12.4. Energiaturg does its best to ensure that the User’s data are correct and up to date, on the assumption that the User gives sufficient information for Energiaturg to be able to ensure this. If the User’s data change, the User must inform Energiaturg of this for the data to be kept up to date. A User who has created a user account in the Energy Portal can change, correct and add to their own data through the user account.
12.5. Energiaturg takes appropriate security measures against breaches of the Energiaturg security requirements and leakage of data and informs affected Users of such breaches or leaks as quickly as possible.
12.6. Energiaturg only uses the User’s data for sending notifications that are not related to the User’s use of the Energy Portal with the prior agreement of the User.

13. THE AGREEMENT OF THE USER

13.1. When starting to use the Energy Portal, the User gives their agreement for their data to be processed in the amounts and under the conditions set out in the data protection principles. Energiaturg may ask the User on each separate occasion to agree to their data being processed or transmitted to a third party.
13.2. By accepting the Conditions of Use and signing the Service Contract, the User agrees that Energiaturg’s operating partner Suletud Ring OÜ (Commercial Register code: 12378413) may search for the User’s consumption data in the database platform operated by the Elering AS data warehouse at http://andmeladu.elering.ee/consumer/home. The agreement of the User gives Suletud Ring OÜ the right:
13.2.1. to make searches in the database concerning the User’s place of consumption and consumption data, and to display the results for these to the User in the Energy Portal only for the purpose of providing the Services that the User wishes, for example requesting an offer to the User from an Electricity Seller or signing a contract. The agreement can be confirmed by logging in to the user account in the Energy Portal if at least 30 days have passed since the previous log in. The User has the right to withdraw this agreement at any time by informing Energiaturg of this decision by email to info@energiaturg.ee, requesting that processing of the User’s data cease and that all the data collected be deleted.
13.2.2. to make an automatic request once a month to the data warehouse for consumption data for that month about the User’s place of consumption, and to present the results of such requests in the Energy Portal to Energiaturg to confirm the amounts of electricity consumed under an electricity contract signed in the Energy Portal.
13.3. The User has the right to withdraw the agreement for the processing of personal data at any time and to request that the processing of personal data stop, the collected data be deleted and the user account closed, but this cannot be done retrospectively nor if the personal data are being processed under a contract with the User nor if it is prevented for legal reasons.
13.4. If the User does not give agreement for the data to be processed or only partly agrees, Energiaturg may refuse certain Services to the User if those Services cannot be provided due to the lack of agreement from the User.

14. RIGHTS OF THE USER

14.1. The User’s personal data are processed in accordance with the Personal Data Protection Act, the Electricity Market Act, the Electronic Communications Act and other laws that regulate the processing of personal data.
14.2. The User has the right:
14.2.1. to see the personal data held on them by Energiaturg;
14.2.2. to request that Energiaturg correct errors in the personal data;
14.2.3. to request that processing of their personal data cease, that access to their data be stopped and that the personal data collected be deleted or closed;
14.2.4. to contact the Data Protection Inspectorate or the courts if there is no other legal route for disputes.
14.3. Energiaturg publishes the personal data requested or explains its refusal to release personal data or information within five working days of receiving the application.

15. CHANGES IN THE DATA PROTECTION PRINCIPLES

15.1. Energiaturg has the right to change the data protection principles unilaterally under the same conditions as the Conditions of Use in response to the development of the Energy Portal.
15.2. If the User disputes changes to the data protection principles without which it is not possible to continue providing the Services, this will be considered as a termination of the Service Contract or an application to terminate the Services, and Energiaturg will have the right to close the User’s user account and refuse to provide the Services.
15.3. Where a refusal to accept the changes does not affect the use of Services, Energiaturg makes every reasonable effort to see that the changes are not applied to the User and that the User may continue using the Services under the previous data protection principles.

16. CONTACT

To use the rights relating to data processing and to fulfil the obligations, and to get additional information or make a complaint about Energiaturg, the User should contact Energiaturg using the contact details published in the Energy Portal.