Privacy Policy

1. General Conditions

This privacy policy, together with the terms of use, governs the use of the technocircle.ee website. The principles of the entire privacy policy operate in accordance with:

The General Data Protection Regulation (GDPR) of the European Union (2016/679), which can be found here: GDPR

The legislation established by the state of Estonia, including the Personal Data Protection Act (IKS).

2. PERSONAL DATA AND PURPOSES OF PERSONAL DATA COLLECTION

Technocircle collects and processes your personal data only if it is sufficient and necessary to fulfill the purposes of processing. Technocircle collects and processes your personal data to provide services and other functions according to the terms of use of the Technocircle website and your preferences and choices. Depending on the provided service, Technocircle may process the following personal data:

Personal Data Form and Contact Information

• Identification data: your first name, last name.
• Contact details: email address, phone number, residential address.
• Other data you provide by completing voluntary questionnaires: date of birth, gender, language preference, company name and details if you are communicating with Technocircle on behalf of a company, other data you provide to us about yourself.

How Technocircle obtains this data: when you place an order through Technocircle.ee and provide the necessary details for its fulfillment, contact us with a query, complaint, return, etc.

Purchase or Transaction Details

• Your order details: ordered products, quantity, prices, given discounts, used coupons, order date, and time.
• Delivery details: delivery method and address, main details about the recipient if you have designated a third party as the recipient.
• Shipping information: delivery method and address, main details about the recipient if you have designated a third party as the recipient.
• Order status and progress: whether the order is ready, shipped, delivered, return information, etc.
• Contact details: information about communication with you and communication about the order and its fulfillment, your feedback and ratings, other communication content.
• Payment information: payment method, date, and time, payment details (including, but not limited to, bank account number).
• Other information: a note that you have read the terms of use and privacy policy, the date and time of reading.

How Technocircle obtains this data: when you place an order on the Technocircle.ee website, make a payment for the order, contact us (or Technocircle contacts you) regarding the order, its fulfillment, or request for goods or money return. Data is generated during the fulfillment of the order or obtained from partners who assist us in fulfilling orders (e.g., information that the order has been paid for, the purchased goods have been shipped, delivered, etc.). Technocircle collects cookies and similar technologies if such information is necessary for the conclusion of a sales contract, order acceptance, and processing (for example, cookies are used to register that you have read the terms of sale).

Your Consents, Communication, and Service Management Options

• Consent and communication options: your consent to receive or opt out of marketing and other messages.
• Service choices: information about the Technocircle services you use, subscribe to, or unsubscribe from.
• Your cookie preferences.

How Technocircle obtains this data: obtained when you give consent or make choices for receiving or opting out of relevant notifications and services. This data is automatically recorded when making choices, including using cookies and other similar technologies.

Information About Your Browsing on the Technocircle Website

• Browsing data: viewed website pages, viewed products, viewing date and time, products added to cart or wish list, download date and time, banner clicks, other clicks and interest in content, information accessed by users.
• Technical details: IP address, session ID, used browser, device type, resolution.

How Technocircle obtains this data: automatically collected using cookies and similar technologies when you browse the Technocircle website. Data is also generated from the collected browsing data (e.g., your browsing statistics).

Other Data Arising from Your Use of Technocircle Services

• Data arising from your use of certain Technocircle services or features: for example, when you save products to a wish list, change product feature preferences (e.g., color, memory, or condition of a phone), save the website language.

How Technocircle obtains this data: obtained when you use the Technocircle website and services. Data obtained on the website is stored using automatic means, including cookies and similar technologies. Contact Details When you contact Technocircle for assistance, ask questions, give feedback, file complaints, etc., Technocircle processes the documents and copies you use for contacting, the documents and communications you provide, and the information Technocircle collects to verify the submitted request. How Technocircle obtains this data: from the data obtained when you contact Technocircle with a request, feedback, complaint, or other inquiry. Technocircle collects information about you that is already legally available to Technocircle or obtained from third parties (e.g., suppliers) if it is necessary to review and respond to your request.

Newsletter and Other Message Review

• Data collected when subscribing to the newsletter: name, email address.
• Other data: information that the message was delivered successfully, message information and opening, opening date and time, clicking on message links, email message information. Message delivery (recipient not known), information about message rejection (specific types of messages).

How Technocircle obtains this data: collected using cookies and other similar technologies when subscribing to the newsletter, delivering and receiving newsletters, and other notifications.

3. PROCESSING OF PERSONAL DATA Procurement of Goods and Order Fulfillment

Technocircle collects your personal data to accept, manage, and fulfill your goods orders, including (but not limited to) processing payments, delivering goods, accepting returns, invoicing, communicating with you regarding order fulfillment, processing orders, resolving order-related queries, etc. Processed personal data:

• Your personal and contact information.
• Data about your purchase.
• Communication data when and to the extent it relates to a specific order.

Legal basis: purchase agreement concluded or to be concluded between the customer and Technocircle. Data retention period: orders and related data and documents are retained for at least seven years from the end of the fiscal year in which the purchase agreement was concluded based on the order.

Content Personalization and Recommendations

To make browsing more convenient and offer content that meets your needs, Technocircle offers personalized content, recommended products, services, and features on the website. To get to know you better and provide you with truly relevant content, Technocircle processes the following information about you:

• Collected data:
  • purchase details.
  • details about your browsing behavior on the Technocircle website.
  • other data resulting from your use of relevant services.
  • Your consents, communication, and service management options.
  • Session ID.
  • Technocircle website browsing data stored during the session.

Data retention period: as long as you use the content personalization and referral service, and your consent is valid, but no longer than two years. If content and offer personalization is not relevant to you, you can opt out of this service at any time by selecting the appropriate settings in your self-service account. If you opt-out of the personalization and referral service, your data will no longer be collected or processed for this purpose. We emphasize that all browsing data is collected and processed solely for content personalization purposes, which does not allow the identification of a specific person. In some cases, the Technocircle system may identify you as a repeat user and associate data collected during the previous browsing session with new session data. However, even in such a case, Technocircle cannot identify you as a specific person because your browsing data is not linked to other personal data or identifying information. Legal basis: your consent to use services and the website and to confirm cookie choices. You can manage your consent and withdraw it at any time by changing your cookie settings as described below.

General and Personalized Marketing Messages

Through Technocircle, you can subscribe to newsletters, receive information about news, promotions, discount codes, and gifts, and receive offers tailored to your purchases and browsing history. To deliver such offers and information, Technocircle processes the following data about you:

• Your contact information (name, email address).
• Your purchase and browsing history if you have opted to receive specifically tailored offers.
• Newsletter and other message review details.

Legal basis: your consent, given when subscribing to the newsletter, to receive general or specially tailored messages and offers. Technocircle processes messages and other notifications based on legitimate business interests. Collecting and analyzing this data allows us to assess the relevance and effectiveness of direct marketing campaigns, ensuring that messages are interesting and relevant to you and that direct marketing is successful and meets its purpose. Data retention period: as long as your consent is valid. You can withdraw your consent to receive newsletters, general, and/or tailored messages and offers at any time by setting the appropriate message options in your account or clicking the unsubscribe link in the email, or by contacting Technocircle at info@technocircle.ee.

Other Online Marketing Activities

The Technocircle website offers services from Google and other internet advertising providers. Generally, advertisers, as independent data processors, collect data when you browse the Technocircle website, using cookies and similar technologies to provide you with relevant Technocircle internet advertising, on other websites, or other internet advertising channels (social media, mobile applications, internet searches, etc.). Your browsing data is collected and processed for advertising purposes on the Technocircle website based on your consent, which you can give or withdraw by agreeing or declining the use of targeted (commercial) cookies. You can learn more about Technocircle advertising partners and the cookies they use and manage your targeted (commercial) cookie settings in this section below.

Reviewing Inquiries and Other Requests

When you contact Technocircle for assistance, to ask questions, submit inquiries, feedback, complaints, product return requests, etc., you usually provide your personal data. Technocircle uses your personal data to thoroughly and objectively investigate your inquiry or other requests, provide you with necessary information, answer your questions, resolve your requests or claims. Technocircle may also use the data from your inquiries, claims, and other requests to protect your rights and legitimate interests if your request, claim, or other inquiry leads to a legal dispute or the likelihood of such a dispute arising. Technocircle processes:

• Your personal and contact information.
• Other data necessary to process your inquiry or request.

Legal basis: fulfilling the legal obligation to respond to customer inquiries and requests. The agreement concluded between the customer and Technocircle and its fulfillment if your request or inquiry is related to the agreement and its fulfillment. Also, Technocircle's legitimate and justified interest in protecting your rights and interests if you file a complaint or claim against Technocircle and a legal dispute arises. Data retention period: relevant information is collected and retained for two years after processing your inquiry or other request. If your inquiry, complaint, or other request leads or may lead to a dispute resolved by a dispute handler (consumer protection, court, or other competent authority), Technocircle may retain your data for a longer period until the expiration of the complaint filing deadline or the final court decision.

Analysis of Statistical Activities, Business Development, and Improvement

Technocircle strives to make website usage as easy and convenient as possible, ensuring that services are accessible, relevant, and useful to customers, and that the customer experience is as good as possible. Therefore, Technocircle continuously analyzes how customers use the website and manages various data for business development and improvement. Technocircle analysis and statistics process anonymous aggregated data and do not process your contact details or other data that could identify you. This means that analyses and statistics do not identify specific users, are not linked to other identified user's personal data, nor aggregated into specific user databases. Technocircle processes:

• Collected data on website browsing.
• Aggregated data on customer purchases.
• Summary reviews of newsletters and other reports.
• Summarized customer data associations.

Legal basis: Technocircle conducts analysis and statistics and collects and processes data for these purposes only with your consent. You can agree to or decline the use of analytical and statistical cookies at any time by adjusting your cookie preferences. Data retention period: Technocircle retains data until the purposes of processing are achieved. The Technocircle website may use Google Analytics and/or other website analysis service providers. Google Analytics and other analysis tools collect browsing data using cookies and similar technologies. Typically, Technocircle uses first-party Google Analytics cookies, i.e., cookies controlled by itself. Disclaimer: Analytical and statistical data on Technocircle website visits and usage are collected and used only with your consent to evaluate the effectiveness of services and marketing campaigns and to make important decisions about business development and improvement, such as product selection development, website improvement, etc. If you oppose setting analytical cookies, you can disable them in your web browser as described in the settings section below.

Profiling and Automated Decision-Making

To offer personalized content and recommendations, Technocircle uses automated data analysis and decision-making, including profiling. This means that relevant data types are collected and processed using automated tools to analyze and aggregate the collected data for personalizing the website for you and creating a profile. Such automated analysis, profiling, and decision-making enable the effective processing of customer information and the achievement of specific objectives mentioned above, i.e., customizing content, recommendations, and offers according to customer needs. These activities do not involve the processing of personal data and do not have significant effects or legal consequences for you.

CONSENTS, RESTRICTIONS ON PROCESSING AND USE OF PERSONAL DATA, AND DATA RETENTION

You have the right to withdraw your consent for personal data processing at any time if processing is based on your consent. For example, you may withdraw your consent for processing personal data for direct marketing purposes at any time. Withdrawal of consent does not affect the lawfulness of personal data processing before the withdrawal. You also have the right to object to the processing of your personal data at any time, depending on the specific situation, if processing is based on Technocircle's legitimate interests. In such cases, Technocircle will stop processing your personal data unless there is a compelling legitimate reason that outweighs your interests, rights, and freedoms (e.g., a legal dispute), or if there is another legitimate basis for processing. For example, if personal data is processed for the purpose of concluding or fulfilling a contract (e.g., an order) or providing the desired service, and you do not provide or allow the processing of the relevant personal data, you will not be able to use the service or conclude the contract.

RESTRICTION OF PERSONAL DATA PROCESSING AND RIGHT TO DATA PORTABILITY

You have the right to restrict the processing of your personal data. If you restrict the processing of your personal data, Technocircle will stop processing your personal data for any other purpose except storing personal data. You can restrict the processing of personal data in at least one of the following cases:

• Personal data is no longer needed for the purposes for which it was collected or otherwise processed.
• You withdraw the consent on which processing is based, and there is no other legal basis for processing.
• Your personal data is processed unlawfully.
• You have objected to the processing of personal data based on our legitimate interest, and in a specific case, your interests prevail.

Your personal data will not be deleted from the database if it is found that:

• Your personal data is necessary to achieve the purposes for which it was collected or processed.
• You have not withdrawn your consent to process your personal data if it is processed based on your consent.
• The processing of personal data is necessary for our legitimate interests, and your interests do not prevail.
• Your data needs to be processed for the presentation, implementation, or defense of legal claims.
• We are obliged to process your personal data in accordance with applicable European Union and national legislation.

The right to data portability means that you are allowed to obtain an overview of the personal data you have provided, processed in an automated manner, in a reproducible format. At your request and if technically possible, your data may be transmitted directly to another person designated by you. You can restrict the processing of personal data, request the presentation of personal data, or transmission in a structured form in the following ways:

• Sending us a request via email: info@technocircle.ee.
• Contacting Technocircle by phone at +372 502 2230.

4. PERSONAL DATA AND THIRD PARTIES

Your personal data may be shared with third parties to provide you with goods and services. Technocircle only shares your personal data if there is a legal basis for the transfer, intended for the proper fulfillment of your order, and the provision of the relevant service. Your personal data is transferred to service providers. Your personal data is shared with service providers, such as transport and courier companies, and other companies providing services related to Technocircle. These entities, acting as Technocircle's authorized processors, are carefully selected and must comply with the Technocircle data processing agreement or other instructions and requirements arising from legislation. In court proceedings and other cases prescribed by law, your personal data may be transferred to state authorities in accordance with the procedures established by the laws of the Republic of Estonia.

5. ACCESS, MODIFICATION, AND DELETION OF PERSONAL DATA You have the right to access the details of your personal data processing, submit requests regarding their use, and have access to your personal data. You have the right to modify your personal data or request that we stop processing and delete it in at least one of the following cases:

• Personal data is no longer needed for the purposes for which it was collected or otherwise processed.
• You withdraw the consent on which processing is based, and there is no other legal basis for processing.
• Your personal data is processed unlawfully.
• You have objected to the processing of personal data based on our legitimate interest, and in a specific case, your interests prevail.

Your personal data will not be deleted from the database if it is found that:

• Your personal data is necessary to achieve the purposes for which it was collected or processed.
• You have not withdrawn your consent to process your personal data if it is processed based on your consent.
• The processing of personal data is necessary for Technocircle's legitimate interests, and your interests do not prevail.
• Your data needs to be processed for the presentation, implementation, or defense of legal claims.
• Technocircle is obliged to process your personal data in accordance with applicable European Union and national legislation.

You can request access, modification, or deletion of your data in the following ways:

• Sending a request via email: info@technocircle.ee.
• Contacting Technocircle by phone at +372 502 2230.

If you believe that your rights have been violated during personal data processing, you can protect your rights by contacting the Data Protection Inspectorate. In Estonia, this is handled by the Data Protection Inspectorate. You can find the contact details of the Data Protection Inspectorate here: www.aki.ee. DATA RETENTION PERIOD Your personal data is retained as long as necessary to fulfill the specific purposes for which it is collected or has been collected. The data retention periods for individual data processing are described in detail in Chapter 3 of this privacy policy, "PROCESSING OF PERSONAL DATA". Personal data may be retained longer than specified in the Privacy Policy only if:

• Technocircle has reason to suspect that you have committed a violation and needs your information to investigate the possible violation.
• Your data is necessary for the proper resolution of a dispute or complaint.
• If the data is necessary to ensure the security of the Technocircle website, such as detecting suspicious activity by a visitor or customer.
• In other special reasons, conditions, or cases provided by law.

COOKIES

The technocircle.ee website uses cookies and similar technologies, such as pixel tags, web beacons, clear GIFs, etc. (hereinafter collectively referred to as "cookies"). Cookies help ensure the proper operation and functionality of the Technocircle website, provide services, collect analytical and statistical information about website navigation, personalize customer browsing experience, and marketing. Cookies are not viruses and do not harm the user's computer or other device. For more information about cookies and their use, see the cookie policy below.

COOKIE POLICY

The Technocircle website uses cookies and similar technologies, such as pixel tags, web beacons, clear GIFs, etc. (collectively referred to as "cookies"). Cookies help ensure the operation and functionality of the Technocircle website, provide services, collect analytical and statistical information about website navigation, personalize customer browsing experience, and marketing. Cookies are not viruses and do not harm the user's computer or other device.

Cookie Management

To comply with the law, user consent is required before using analytical and targeted (commercial) cookies. You can agree to or decline the use of analytical and targeted (commercial) cookies at any time by changing their choices accordingly below. To fully implement changes, you must delete the cookies stored based on the previous consent from your device. Cookies of other categories are set according to the law or Technocircle's legitimate interests, so your separate consent is not required.

Purposeful Use of Cookies

Cookies are classified according to their nature and purpose: functional cookies, analytical cookies, and targeted (commercial) cookies.

FUNCTIONAL COOKIES

Functional cookies ensure proper operation and are technically necessary for the Technocircle website, and help provide services. Functional cookies cannot be fully declined, as without them the website would not function as intended, or it would hinder Technocircle from providing you with the services you have chosen. Functional cookies:

• Help display website content.
• Ensure the secure operation of the website, preventing fraudulent activity.
• Save your communication preferences, acceptance or rejection of targeted (commercial) cookies.
• Retain proof of your adulthood before viewing products intended for adults.
• Help you load and save selected products in your shopping cart.
• Help personalize content and provide recommendations based on your browsing history if you browse as a registered customer and have not opted out of content customization and recommendation service.

Functional cookies are necessary to ensure the technical operation and security of the website and are automatically stored when you visit the website. These cookies do not collect your personal data and are set in accordance with the law. If you do not agree with the automatic use of these cookies, you may not be able to use the services offered by Technocircle. Detailed information on data collection and processing can be found in the privacy policy.

ANALYTICAL COOKIES

Analytical cookies collect statistical information about how customers use the Technocircle website. These are statistical data on website visits and usage. This data helps understand how customers use the website, evaluate the effectiveness of services and marketing campaigns, and continuously develop and improve the website and the services offered. Analytical and statistical cookies are stored only with your consent. You can agree to or decline analytical cookies at any time by changing their choices accordingly above. Analytical cookies collect and process analytical, depersonalized consistent data and do not process your contact or other individual data. Data collected by analytical cookies does not identify a specific person, are not linked to other data, and are not aggregated into user-specific datasets. Analytical cookies can be blocked by making the appropriate cookie preferences when entering the website or activating the "Do Not Track" function in your browser. Instructions on how to do this can be found on the official websites of popular browsers: Chrome, Firefox, Internet Explorer, Safari, Opera, etc.

TARGETED COOKIES

Targeted cookies are used to tailor your browsing experience, personalize content, and marketing offers based on your browsing history on the Technocircle website. Certain targeted (commercial) cookies are set by third-party advertising partners (third-party cookies), such as Google, Adform, and others. Targeted (commercial) cookies are stored only with your consent. You can agree to or decline the storage of targeted (commercial) cookies at any time by changing the above-mentioned cookie preferences accordingly. Targeted (commercial) cookies collect and analyze your browsing history on the website and use this data to:

• Personalize the content shown to you and provide recommendations when you browse as an unregistered customer.
• Provide you with marketing offers and display relevant advertising messages.

Some targeted (commercial) cookies are set by third-party advertising partners (third-party cookies), such as Google, Adform, etc. Advertising partners use cookies to collect data about your web browsing to provide you with relevant online advertising on the Technocircle website, other websites, or other online advertising channels (social networks, mobile applications, internet search engines, etc.).

Third-Party Content (Embeds)

Some pages on the Technocircle website offer and contain third-party content (embeds), such as YouTube, Facebook, Instagram, etc. Such third-party content is usually marked with the respective third-party logo on the website. When you use third-party content (e.g., watching a YouTube video, clicking the Facebook "share" link), the respective third party may set cookies and collect data at its discretion as if you were navigating the third-party website. Third parties act as independent data controllers on the Technocircle website and may use data collected through cookies for purposes and ways other than those set out in this cookie policy. Technocircle has no control or overview over this, so you should review the specific third-party's privacy documentation before using their content. Third-party content (embeds) can be disabled on the website by making the appropriate cookie preferences when entering the website.