Privacy Notice

Last updated June 15, 2024

1. Contact information for privacy cases

UGEM handle your personal data in accordance with current data protection legislation (including GDPR, E-Privacy directive and other relevant regulations such as national laws and regulations)

This Privacy Notice explains which categories of personal data we collect and process, why they are processed, and which rights you do have. You also receive information about your data privacy rights on [email protected]

If you have any questions regarding your personal data, feel free to contact us via [email protected].

2. Sources of your personal data

UGEM may collect and process information that:

  • you personally provided to us by email or through messengers to our representatives,
  • we generate internally during performance of a contract between you and UGEM,
  • you provide during interaction with our web sites, through cookies and web forms,
  • we obtain from third parties, integrated services or recruitment agencies,
  • we obtain from open sources, social media sources, public web sites or press releases.

UGEM will not process your personal data if such is prohibited by data protection laws or regulations.

3. Purposes of processing

UGEM processes your personal data linked to particular purposes and corresponding legal bases outlined below:

  • purposes to which you agree in a consent form;
  • for the fulfilment of the contract as further specified in our contracts with employees, clients and consultants;
  • in order to comply with legal obligations specified in a particular law or regulation;
  • legitimate interests pursued by UGEM, except where such interests are overridden by your interests or fundamental rights and freedoms.

In case UGEM is planning to change the purpose of processing to such that is incompatible with the original one, we will contact you to provide you with further information on purposes for processing prior to it taking place, at all times ensuring appropriate legal basis for processing, which may include asking for your additional consent.

4. Recipients of personal data

UGEM in this notice means DigitalRockets OU (Republic of Estonia)

Our full contact details are as follows:

  • Full name of company: DigitalRockets OU
  • Email address: [email protected]
  • Physical address: Harju maakond, Tallinn, Lasnamäe linnaosa, Paepargi tn 47-9, 11417

All your personal data will be kept strictly confidential and will not be disclosed to unauthorized third parties or made public without your prior notification by this notice or in person. UGEM will not transfer your personal data internationally without reasonably ensuring that the rights and freedoms of you as the data subject are protected.

We never sell your data or share it with other third parties in order to obtain financial gains.

5. UGEM stores your personal data

The data collected by UGEM is stored within the information in the cloud systems operated by well-known providers. After receiving personal data from you, a third party or a public source, UGEM will use all reasonable procedures and security measures to avoid unauthorised access, loss, disclosure or amendment of the personal data.

6. Storage period

We store your personal data for a limited period of time, which varies depending on type of data, the purposes of processing, legal requirements and duration of contractual relationship with UGEM.

To obtain information about the storage period of your personal data, please contact us via info [email protected].

7. Your rights

As a data subject you have the following rights:

right to obtain information in relation to your personal data
- You have a right of access that gives you the possibility to obtain a copy of your personal data, as well as other supplementary information.
right to access your personal data
- You have a right of access that gives you the possibility to obtain a copy of your personal data, as well as other supplementary information.
right to data portability
- you have a right to receive the personal data concerning you, which has provided to UGEM, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
  1. the processing is based on your consent or explicit consent;
  2. the processing is carried out by automated means.
right to withdraw the consent
- You have the right to withdraw your consent via google-form.
right to correct mistakes in your personal data
- You have the right to obtain from UGEM without undue delay the rectification of inaccurate personal data concerning you Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
right to stop the unwarranted processing
- You can request to limit the use of your personal data if:
  1. If the data about you is inaccurate;
  2. If the processing is unlawful, but you do not want the data to be erased and requests restriction (which is different from the right to be erased);
  3. we no longer needs data, but you want the data to be preserved so the legal claim can be exercised;
right to be forgotten (erase your personal data)
- You have the right to obtain from UGEM the erasure of personal data concerning you without undue delay where one of the following grounds applies:
  1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. you withdraw your consent and where there is no other legal ground for the processing;
  3. you object to the processing and there are no overriding legitimate grounds for the processing, or if you object to the processing in case of direct marketing
right to be aware of the existence of the automated individual decision-making and to object in this regard
- You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects you.;
right to lodge a complaint to a supervisory authority
- Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in the Member State of your habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to your infringes this Regulation. You can also submit a complaint to The Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at the place of the company’s main representative office in the EU:

Data Protection Inspectorate

Tatari 39, Tallinn 10134

+372 627 4135 [email protected]

8. How do we process your personal data

Web-Site Visitors

Types of information

UGEM collects and processes the following types of information:

Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Name e-mail, phone number (optional)
Consent
Start of possible provision of business services
No longer than 2 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
CRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Name e-mail, phone number (optional)
Consent
Subscription to company news and promotional offers
Until consent is withdrawn
Data subject
Company, cloud storage systems operated by well-known providers;
CRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Browser information about visit
Legitimate interest
To improve the quality of company services and visit analytics
For the lifetime of the cookie
Data subject
Company, cloud storage systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
IP address in case of leaving a request for communication with a company representative
Legal obligation
To determine the country of a potential client in order to exclude business interactions with customers from countries subject to international sanctions regime
For the lifetime of the cookie
Data subject
Company, cloud storage systems operated by well-known providers

During visiting our web-site UGEM may collect information directly entered by you in contact us forms or through cookies, beacons and other trackers. In this case, UGEM may process your personal data which include your IP, location, visited web pages on our web-site, and, if you filled your name, email, phone and country and information in text of the message.

Recipients

Your personal data may be wholly or partially disclosed to the following third parties:

  • email service provider if the data is transferred to us via email or “get in touch” form;
  • service providers supplying and servicing our internal system for customer relation management;

Representatives of Potential Clients

Types of information

UGEM collects and processes the following types of information:

Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
First name, last name, patronymic (if applicable), e-mail, phone number, contact messenger details, position
Contract
Identification of a potential client representative for communication
No longer than 2 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
CRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
First name, last name, patronymic (if applicable), e-mail, phone number, contact messenger details, position
Contract
Entering personal data into draft agreements to regulate business relations
No longer than 2 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
CRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
e-mail or messenger correspondence
Contract
Possibility of clarifying the details of negotiations to correctly offer the best service
No longer than 2 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
CRM systems operated by well-known providers

Representatives of Current or Former Clients

Types of information

UGEM collects and processes the following types of information:

Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
First name, last name, patronymic (if applicable), e-mail, phone number, contact messenger details, position
Contract
Identification of a client representative for communication
No longer than 2 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
CRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
First name, last name, patronymic (if applicable), e-mail, phone number, contact messenger details, position
Contract
Legal obligation
  1. Personal data of the client’s representative is stored in contracts concluded with the company in order to verify at any time the powers of the representative and the procedure for fulfilling the contract
  2. Fulfillment of the Company’s obligations to the authorities, during which the Company is obliged to transfer concluded contracts to government authorities
No longer than 5 years after the agreement expiration
Data subject
Company, cloud storage systems operated by well-known providers;
CRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
e-mail or messenger correspondence
Contract
Possibility of clarifying the details of negotiations to ensure the correct provision of services under agreemen
No longer than 5 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
CRM systems operated by well-known providers

In any cases we are not working with data of individuals under the age of 18

If you have any questions regarding your personal data, feel free to contact us via [email protected].