1.1. A Data Subject is a natural person, whose information Best Barf has or information that can identify a natural person. Data subjects include, for example, physical subjects, affiliates and employees whose personal data Best Barf has.
1.3. Personal data is any information about an identified or identifiable natural person.
1.4. Processing of Personal Data is any operation with Data Subject’s Personal Data. For example, collecting, storing, organizing, maintaining, modifying and disclosing the Personal Data, granting access, making inquiries and retrieving, using, transmitting, cross-using, merging, closing, deleting or destroying, or any combination of the above, irrespective of the method and means used.
1.5. Customer is any natural or legal person who uses or has requested to use the Best Barf Services.
1.6. The Agreement is a Service providing agreement or any other agreement between Best Barf and the Customer.
1.7. Website www.bestbarf.com is the website of Best Barf.
1.8. A visitor is someone who uses the Best Barf website.
1.9. A child is a person under the age of 13 in the context of the Processing of Personal Data in the Republic of Estonia.
1.10. Services are all of the services and products offered by Best Barf.
1.11. Cookies are the data files that are sometimes stored in settings under the Visitor’s Website.
1.12. The Best Barf Data Protection Officer is the person who applies the Best Barf Principles for the Processing of Personal Data and who can be contacted by the Data Subject in the event of a complaint.
1.13. Sales Channels are a means of communicating with the Data Subject, a tool created by Best Barf to sell goods and provide services. Including email, phone, public and social media, various chat lines, personalized and interactive ads, and similar tools on and off the Web.
1.14. The Product Portfolio are the Best Barf’s various products and Services. The list is available at www.bestbarf.com.
The terms used in this Privacy Statement, this Agreement, the General Terms and the communication between the parties should be addressed by the meaning given above.
2.1. Best Barf is a legal entity of Bestdog OÜ, registry code 14624036, located at Saaremaa, Muhu vald, Nautse küla, Jaani, 94728, Estonia.
2.2. Personal data may be processed by Best Barf:
2.2.1. determining, as controller, the purposes and means of the processing;
2.2.2. as a processor, under the instructions of the controller;
2.2.3. to the extent to which the Personal Data is transmitted.
2.3. The Privacy Terms apply to the Data Subjects, and all Best Barf employees and affiliates who have access to the Personal Data held by Best Barf are subject to the rights and obligations set forth in the Privacy Terms.
2.3.1. The Privacy Statements may supplement or they may be amended being published on the Website or on the Devices.
2.4 Bestdog OÜ is the chief processor of personal data, Bestdog OÜ forwards the personal data necessary for making payments to the authorized processor Maksekeskus AS.
3.1. Best Barf will always be guided by the interests, rights and freedoms of the Data Subjects when processing Personal Data.
3.2. The goal of Best Barf is the responsible processing of the Personal Data, based on best practices, bearing in mind that we are always ready to demonstrate that Personal Data Processing is fit for purpose.
3.3. All processes, instructions, actions and activities of Best Barf in connection with the Processing of Personal Data are based on the following principles:
3.3.1. Legality. There is a statutory basis for such processing of Personal Data, such as consent;
3.3.2. Justice. The processing of Personal Data is fair because the Data Subject has sufficient information and information on how the Personal Data is being processed.
3.3.3. Transparency. The processing of Personal Data shall be transparent to the Data Subject.
3.3.4. Purposefulness. Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes.
3.3.5. Correctness. Personal Data is accurate and, where necessary, up to date and every reasonable step has been taken to ensure that inaccurate Personal Data for the purpose of which the Personal Data is processed are erased or rectified.
3.3.6. Preservation Limit. Personal Data shall be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purpose for which the Personal Data is processed. This means that if Best Barf wishes to keep Personal Data for longer than necessary for the purpose for which it was collected, Best Barf will anonymize the data so that the Data Subject is no longer identifiable. In the case of data obtained by Best Barf through a Customer or similar relationship, Best Barf will retain, in accordance with best practice and with consent, the Data processed until consent is revoked.
3.3.7. Reliability and confidentiality. Processing of Personal Data shall be carried out in a manner that ensures appropriate security of the Personal Data, including protection against unauthorized or unlawful Processing and against accidental loss, destruction or damage, through reasonable technical and organizational measures. Best Barf has in-house instructions, employee policies, as well as individual contracts with each processor that provides best practices, ongoing risk assessment, and appropriate technical and organizational measures to process the Personal Data.
COMPOSITION OF PERSONAL DATA
4.1. Best Barf collects, among other things, the following types of Personal Data:
4.1.1. Personal Data (name, email address, postal address, telephone number) published by the Data Subject to Best Barf;
4.1.2. Personal Data resulting from normal communication between the Data Subject and Best Barf;
4.1.3. Personal Data obviously disclosed by the Data Subject (eg in social media);
4.1.4. Personal Data arising from your use of the Services (eg when purchasing from an Online Store);
4.1.5. Personal Data generated by your access to and use of the Website (eg, time spent on the Website);
4.1.6. Personal Data obtained from third parties;
4.1.7. Personal Information created and combined by Best Barf (communication and letters with customer service or order history).
THE COMPOSITION OF PERSONAL DATA, OBJECTIVES AND GROUNDS FOR PROCESSING
5.1. Best Barf Processes Personal Data solely by consent or by law.
5.2. Subject to consent, Best Barf will process Personal Data strictly within the limits, to the extent and for the purposes specified by the Data Subject. With regard to consents, Best Barf is guided by the principle that each consent must be clearly distinguishable from other matters, and in a comprehensible and easily accessible form, in clear and plain language. Consent may be given in writing, electronically or orally. The Data Subject gives their consent voluntarily, specifically, knowingly and unambiguously, for example, by marking a cell on the Website.
5.3. Legitimate Interest means Best Barf’s interest in managing and directing its business to provide the best possible Services on the market. On statutory basis Best Barf will process Personal Data only after careful consideration to determine that Best Barf has a legitimate interest in the processing of Personal Data necessary and in accordance with the interests and rights of the Data Subject. In particular, the processing of Personal Data on the basis of a legitimate interest may take place for the following purposes:
5.3.1. To ensure a trusting customer relationship, such as the processing of Personal Data strictly necessary to identify the actual beneficiaries or to prevent fraud;
5.3.2. Managing and Analyzing the Customer Database to improve the availability, choice, quality of Services and Products, and to make the best and most personalized offers to the Customer upon consent;
5.3.3. Identifiers and Personal Data is collected when you use websites, mobile applications, and other Services. Best Barf uses the data it collects for web analytics or analysis of mobile and information society services, for work, improvement, statistics, analysis of Visitor behavior and user experience, and for providing a better and more personalized Service;
5.3.4. Organizing campaigns, including personalized and targeted campaigns, conducting customer and visitor satisfaction surveys and measuring the effectiveness of the marketing activities performed;
5.3.5. Analyzing Customer and Visitor behavior in different sales channels, websites;
5.3.6. Measures for network, information and cybersecurity considerations such as anti-piracy, security of websites, back-up and storage;
5.3.7. For the preparation, filing or defense of legal claims.
5.4. To comply with your statutory obligation Best Barf processes Personal Data for the purpose of complying with your statutory obligations or for the purposes permitted by law. For example, there are legal obligations to process payments or to comply with money laundering rules.
5.5. In the event that the processing of Personal Data is for a purpose other than that for which the Personal Data was originally collected, or is not based on the consent of the Data Subject, Best Barf will carefully evaluate the permissibility of such new Processing.
DISCLOSURE AND / OR COMMUNICATION OF CLIENT INFORMATION TO THIRD PARTIES
6.1. Best Barf cooperates with persons to whom Best Barf may transmit data relating to the Data Subjects, including Personal Data, within the scope and for the purpose of such cooperation.
6.2. Such third parties may include advertising and marketing partners, customer satisfaction research companies, debt collection service providers, insolvency registers, IT partners, postal intermediaries or organizations, provided that:
6.2.1. the respective purpose and Processing is lawful;
6.2.2. Personal Data will be processed in accordance with Best Barf’s instructions and subject to the applicable agreement.
SECURITY OF PROCESSING OF PERSONAL DATA
7.1. Best Barf maintains Personal Data only for the minimum strictly necessary. Expired personal data will be destroyed in accordance with procedures established by Best Barf.
7.2. Best Barf has established guidelines and rules of procedure for ensuring the security of Personal Data, whether through organizational or technical measures.
7.3. In the event that any Personal Data incident occurs, Best Barf will take all necessary measures to mitigate the consequences and mitigate any future relevant risks. Among other things, Best Barf records all incidents and informs the Data Protection Inspectorate and the Data Subject directly, where appropriate.
PROCESSING PERSONAL DATA OF CHILDREN
8.1. Best Barf services as well as information society services are not aimed at children.
8.2. Best Barf does not knowingly collect information about anyone under the age of 13 (Children), and in the event of a conscious act of this, we will follow the wishes of the parent or guardian.
8.3. In the event that Best Barf discovers that it has collected Personal Data about a Child, Best Barf will do its best to terminate the processing of such Personal Data.
RIGHTS OF THE DATA SUBJECT
9.1. Consent Rights:
9.1.1. The Data Subject has the right to notify Best Barf of its wish to withdraw its consent to the processing of Personal Data at any time.
9.1.2. You can revoke the recipient’s consent to Best Barf newsletter using the link at the end of the newsletter.
9.2. The Data Subject also has the following rights when processing personal data:
9.2.1. The right to obtain information about the Personal Data collected about him or her.
9.2.2. Right to access the data, including the right of the Data Subject to receive a copy of the Personal Data being processed.
9.2.3. Right to correction of inaccurate Personal Data.
9.2.4. Right to erasure, e.g in some cases the Data Subject has the right to request that Personal Data be erased, for example, if the processing is carried out only with consent.
9.2.5. Right to Restrict the processing of Personal Data. This right arises, inter alia, if the Processing of Personal Data is not permitted by law or if the Data Subject disputes the accuracy of the Personal Data. The Data Subject has the right to request that the processing of Personal Data is limited to a period which allows the Controller to verify the accuracy of the Personal Data or if the processing of Personal Data is illegal, but the Data Subject does not request the deletion of Personal Data.
9.2.6. Right to ask the supervisory authority to check the lawfulness of the processing of the Data Subject’s personal data.
EXERCISE OF RIGHTS AND CLAIMS
10.1. Exercise of rights:
10.1.1. The Data Subject has the right to contact Best Barf via e-mail email@example.com in case of any question, request or complaint related to the processing of the Personal Data.
10.2.1. The data subject has the right to appeal to Best Barf, the Data Protection Inspectorate or the court if the Data Subject considers that his or her rights have been violated in the processing of the Personal Data.
10.2.2. Contact details of the Data Protection Board (AKI) can be found on the AKI website.
COOKIES AND OTHER WEB TECHNOLOGIES
11.1. Best Barf may collect and process information about the Visitors of the Websites and other information society services using Cookies (e.g., small pieces of information stored on the hard disk of the Visitor’s computer or other device by the Visitor’s browser) or other similar technologies (e.g. IP address, device information, location information).
11.2. Best Barf will use the information collected to enable the providing of the Service in accordance with the Visitor’s or Customer’s habits; to ensure the best quality of Service; inform the Visitor and the Client about the content and make recommendations; make ads more relevant and enhance marketing efforts; facilitate login and data protection. The collected data is also used to count Visitors and record their usage patterns.
11.3. Best Barf uses session, persistent and advertising cookies. The session cookie is automatically deleted after each visit; persistent cookies are retained when you use the Website repeatedly. Third party cookies are used by Best Barf partner sites. The occurrence of these cookies is not controlled by Best Barf, so you may obtain information about these cookies from third parties.
11.4. With respect to cookies, Visitors agree to their use on the Website, in Information Society service settings or the web browser.
11.5. Most web browsers allow cookies. Without the full acceptance of cookies, the Website features are not available to the Visitor. Enabling or disabling cookies and other similar technologies is controlled by the Visitor through his or her own web browser settings, information society service settings and such privacy enhancing platforms.
IMPORTANT DOCUMENTS, INSTRUCTIONS AND PROCEDURES
12.1.1. A Register of processing operations, which lists all the purposes, methods, types and categories of Personal Data to be processed and the respective bases of processing;
12.1.2. The Person’s online store account, through which the Data Subject accesses the Personal Data available on Best Barf; they may be repaired, modified and exercise any other rights they may have under the law and these Privacy Terms;
12.1.3. The Principles for the Use of Best Barf organizational and technical measures, which outline the various measures that Best Barf takes to keep personal information confidential and secure at all times.
12.1.4. All about cookies: Descriptions of cookies and other web technologies used by Best Barf.
CONTACT INFORMATION AND INFORMATION
13.1. Important contact details for the Best Barf Data Subject:
13.1.1. Best Barf can be contacted by email at firstname.lastname@example.org.