Last updated on 21 March, 2022
We truly respect your privacy and are committed to protecting your personal data. This Privacy Notice applies to the processing of personal data by hi Technologies Limited OÜ with its business address Vabaõhumuuseumi tee 4/1-66, Haabersti linnaosa, Tallinn, Harju maakond, 13522 Estonia and its affiliates (“hi”, “hi.com”, “The Company”, “we”, “us”, “our”) in connection with:
use of any of our products, services or applications (collectively the “Services” or the “Platform”),
visit or use of our websites hi.com (“Site”), web.hi.com (“Web App”) or mobile application (“App”).
Please note that our Services, Site and Apps are not intended for minors below the age of 18 years and we do not knowingly collect data relating to minors.
This Privacy Notice aims to give you information on why and how we collect and process your personal data. This Privacy Notice informs you about your privacy rights and how the data protection principles set out in the EU General Data Protection Regulation (“GDPR”) and the post-Brexit privacy law publicly known as the UK GDPR protect you.
It is important that you read this Privacy Notice together with any other notice or policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of why and how we are using your data. This Privacy Notice supplements other notices and policies and is not intended to override them.
The controller of your personal data is the legal entity that determines the “means” and the “purposes” of any processing activities that it carries out. When you engage us to provide services for you, we will be the “data controller” for your personal data.
Data Protection Officer
We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions or complaints related to this Privacy Notice or our privacy practices, or if you want to exercise your legal rights, please contact our DPO at firstname.lastname@example.org..
You have the right to make a complaint about the way we process your personal data to a supervisory authority. If you reside in an EEA Member State, you have the right to make a complaint about the way we process your personal data to the supervisory authority in the EEA Member State of your habitual residence, place of work or place of the alleged infringement. Information about your supervisory authority could be found here.
We would, however, appreciate the chance to deal with your concerns before you approach a data protection regulatory authority, so please feel free to contact us in the first instance.
Our duties and your duties in case of changes
We keep our Privacy Notice under regular review. This version was last updated on the date above written. Please check from time to time for new versions of the Privacy Notice. We will also additionally inform you on material changes of this Privacy Notice in a manner which will effectively bring the changes to your attention. It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information means any information that relates to an identified or identifiable living individual. This is a broad definition which includes the specific pieces of personal data which we have described below. It does not include data which cannot be used to identify an individual person, such as a company registration number.
A “data subject” is an individual who can be identified, directly or indirectly, by personal data. This is usually by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data. It does not include data where the identity has been removed (anonymous data). More information could be found here.
Depending on whether and how you use our Services, Site or App, we will collect, use, store and transfer different kinds of personal data about you which we have grouped in categories as follows:
|Category of Personal Data||Examples of specific pieces of personal data|
|Social Identity Data|
|Marketing and Communications Data|
If you refuse to provide personal data
We use different methods to collect information from and about you, including through:
Direct interactions. You may give us your Identity Data, Social Identity Data, Contact Data, Financial Data, Profile Data and Marketing and Communications Data by directly interacting with us, including by filling in forms, providing a visual image of yourself via the Service, by email or otherwise. This includes personal data you provide when you:
Automated technologies or interactions. As you interact with us via our Site or App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We will also collect Transactional Data, Investment Data and Usage Data . We may also receive Technical Data and Marketing and Communications Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We also obtain information about you, including Social Identity Data, from third parties or publicly available sources. These sources may include:
We will only use your personal data when the applicable legislation allows us to. In other words, we have to ensure that we have a lawful basis for such use.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose and/or activity||Categories of personal data||Lawful basis for processing|
|To register you as a new customer|
|To carry out and comply with anti-money laundering requirements|
|To process and deliver our Services and any App features to you, including to execute, manage and process any instructions or orders you make|
|To prevent abuse of our Services and promotions|
|To manage our relationship with you which will include asking you to leave a review, take a survey or keeping you informed of our company's business and product development|
|To keep our records updated and to study how customers use our products/services|
|To manage, process, collect and transfer payments, fees and charges, and to collect and recover payments owed to us|
|To ensure good management of our payments, fees and charges and collection and recovery of payments owed to us|
|To manage risk and crime prevention including performing anti-money laundering, counter terrorism, sanction screening, fraud and other background checks, detect, investigate, report and prevent financial crime in broad sense, obey laws and regulations which apply to us and response to complaints and resolving them|
|To enable you to partake in a prize draw, competition or complete a survey|
|To gather market data for studying customers' behavior including their preference, interest and how they use our products/services, determining our marketing campaigns and growing our business|
|To administer and protect our business, our Site, App(s) and social media channels including bans, troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting of data|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences|
|To make suggestions and recommendations to you about goods or services that may be of interest to you|
|To use the services of social media platforms or advertising platforms some of which will use the personal data they receive for their own purposes, including marketing purposes|
|To use the services of financial institutions, crime and fraud prevention companies, risk measuring companies, which will use the personal data they receive for their own purposes in their capacity of independent controllers|
|To record voice calls for compliance, quality assurance and training purposes|
We may use your Identity Data, Contact Data, Technical Data, Transactional Data, Investment Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us and consented to receive marketing communications, or if you have purchased from us and you have not opted out of receiving such communications. We will use your Marketing and Communications Data for our respective activities.
You can ask us to stop sending you marketing messages at any time by following the “unsubscribe” links on any marketing message sent to you.
Further, you can let us know directly that you prefer not to receive any marketing messages by emailing email@example.com.
Where you opt out of receiving marketing messages, this will not apply to service messages which are directly related to the use of our Services (e.g. maintenance, change in the terms and conditions and so forth).
The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We share your personal data with our third-party service providers, agents, subcontractors and other associated organizations, our group companies, and affiliates (as described below) in order to complete tasks and provide the Services and use of the hi.com App to you on our behalf. When using third party service providers, they are required to respect the security of your personal data and to treat it in accordance with the law.
We may pass your personal data to the following entities:
We share your personal data within our group. This will involve transferring your personal data outside the European Economic Area (EEA) or the UK.
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
the country to which we transfer your personal data has been deemed to provide an adequate level of protection for personal data by the European Commission;
a specific contract approved by the European Commission which gives safeguards to the processing of personal data, the so called Standard Contractual Clauses.
While there is an inherent risk in any data being shared over the internet, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, damaged, or accessed in an unauthorized or unlawful way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
Depending on the nature of the risks presented by the proposed processing of your personal data, we will have in place the following appropriate security measures:
We have put in place procedures to deal with any suspected personal data breach and will notify you and any relevant regulator of a breach where we are legally required to do so.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Here are some exemplary factors which we usually consider when determining how long we need to retain your personal data:
Please note that under certain condition(s), you can ask us to delete your data: see your legal rights below for further information. We will honor your deletion request ONLY if the condition(s) is met.
You have rights we need to make you aware of. The rights available to you depend on our reason for processing your personal data. If you need more detailed information or wish to exercise any of the rights set out below, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Period for replying to a legitimate request
The statutory period under GDPR for us to reply to a legitimate request is one month. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.
Please note that we may request that you provide some details necessary to verify your identity when you request to exercise a legal right regarding your personal data.
If you want any further information from us on privacy matters, please contact our privacy compliance team at firstname.lastname@example.org.