PROCEDURE OF PROCESSING PERSONAL DATA

The Landlord has the right to process personal data provided or disclosed under the Contract, as well as personal data that arise or lawfully become known in the course of the performance of the Contract, as described below.

Some personal data (such as name, personal identification number, date of birth, address, phone number, e-mail address, Rent payment records, records of payments for Related and Extra Services, other necessary data) is necessary for the conclusion and execution of the Contract and the Tenant cannot refuse to provide such personal data. The Tenant’s decision to provide additional personal data to the Landlord is voluntary.

Situations of processing of personal data related to the Contract are:

• Processing of the Tenant’s personal data necessary for the conclusion of the Contract;
• Processing of the Tenant’s personal data to ensure compliance with tax obligations and to fulfil the obligations of the Contract;
• With the separate written consent of the Tenant: publishing the names of the Tenants in the electronic information boards in the common areas of the Building and placing them on mailboxes for the information of visitors and other residents;
• Video surveillance of the Property for order and security purposes (Video surveillance is installed in the Property in the places specified in the House Rules);
• Processing of data of the Tenant for the provision of utility, management or management services, as well as for the management of access to and use of the Building and the Property;
• In the debt recovery process (including the fact and amount of the debt, the Tenant’s name, date of birth/personal identification number and contact details, the amount, the beginning and end of the accrual period) and for the purpose of using the debt recovery process in the event of improper performance of the Contract;
• Conducting searches on the Tenant and the persons occupying the Residential Premises as provided for in the Contract in publicly accessible registers, including solvency and credit registers, criminal records, court records, Register of Real Estate for the purpose of verifying the Tenant’s solvency and for the purpose to ensure the living environment objectives set out in Clause 5.4 of the Special Provisions.

The Landlord is the controller of the personal data to be processed under this Contract.

The processing of personal data is carried out on the following legal basis:

• Article 6 (1)(a) of the General Data Protection Regulation (“GDPR”) (“your consent”);
• Article 6 (1)(b) of the GDPR (taking measures before the conclusion and performance of a contract);
• Article 6 (1)(c) of the GDPR (compliance with a legal obligation);
• Article 6 (1)(f) of the GDPR (legitimate interests to ensure the proper management, observance and protection of the legitimate interests of the contract; in the case of video surveillance, also the protection of third party property).

The Landlord has the right to pass on and disclose certain personal data to the following persons: (i) companies belonging to the same group of companies for data management purposes (such personal data as name, personal identification number, date of birth, address, phone number, e-mail address, Rent payment records, records of payments for Related and Extra Services, other related data); (ii) any providers of management, utility, management or maintenance services to the Property and the buildings thereon, including Lumi Capital Haldus OÜ, a company registered in Estonia, registration number: 14575371 (such personal data as name, address, phone number, e-mail address, Rent payment records, records of payments for Related and Extra Services); (iii) professional legal advisers, debt collection and other debt management service providers (including credit registers) for debt collection purposes (such personal data as name, personal identification number, date of birth, address, phone number, e-mail address, Rent payment records, records of payments for Related and Extra Services, other related data); (iv) law enforcement authorities. Your personal data will not be transferred outside the EEA.

Personal data are kept only for as long as is necessary for the above purposes. If the law requires the storage of personal data, the Landlord will comply with the relevant provisions. Video surveillance recordings will be stored for a maximum of one month. In the case of incidents, video recordings may be kept until the completion of the action to be taken in order to protect the legitimate interests involved.

The Tenant and persons residing in the Residential Premises have the right to be informed about data processing, to access the personal data obtained about them and to request their completion, correction, updating or deletion, to request the restriction of processing or to object to the processing of personal data, to exercise the right to data portability under the GDPR by sending a request to the e-mail address of the Landlord specified in Clause 1.1. The right to avoid automated decision-making does not apply as the Landlord shall not make any automated decision-making in respect of the Tenant.

If the processing of personal data is based on consent, the Tenant shall have the right to withdraw his/her consent at any time. This will not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

The Tenant has the right to contact the State Data Inspectorate and lodge complaints in case of a possible violation of personal data protection requirements.