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RADICENTER OÜ Principles of Processing Client Data

The processor of customer data is Radicenter OÜ (hereinafter Radicenter) and authorized processors designated by Radicenter. Information about authorized processors is available on Radicenter’s website.

1. GENERAL DEFINITIONS

1.1. Client means any natural person or legal entity who has entered into a contract with Radicenter for the use of services;

1.2. Personal data – Information gathered by Radicenter during the provision of services to identified or identifiable natural persons.

1.3. Client Data – Any information that is known to Radicenter about the Client, including personal data and service data (e.g., name, personal identification code, contact information, communication language, etc.).

1.4. Processing of customer data is any process involving customer data, including the collection, storage, modification, access, making inquiries, use, transmission and destruction.

1.5. Authorized processors – Persons processing client data on behalf of Radicenter, such as domain registers and registration service brokers.

2. LEGALITY OF CLIENT DATA PROCESSING

2.1. Radicenter considers customer data confidentiality as very important part of Radicenter service and ensures the legality of the processing of customer data.

2.2. Processing of customer data in Radicenter is in accordance with the requirements of the Personal Data Protection Act, the Electronic Communications Act and customer data processing principles.

2.3. Authorized processors must comply with Radicenter’s customer data processing requirements.

3. CONSENT OF THE CLIENT

3.1. Radicenter processes customer data received through the provision of the service only with the consent of the client, unless the right or obligation to disclose such data arises from the law or an agreement between Radicenter and the client.

3.2. Upon entering into an agreement or with the entry into force of the General Terms and Conditions for the use of Radicenter services, the client gives consent to Radicenter to process its customer data in accordance with the User Agreement and the Principles of Processing Client Data.

4. SECURITY OF CLIENT DATA PROCESSING

4.1. Radicenter protects customer data in accordance with relevant security and confidentiality rules and has implemented the necessary organizational, physical and IT security measures to protect customer data.

4.2. Radicenter requires from individuals to whom customer data is transmitted under the Client Data Processing Principles to comply with security and confidentiality rules.

4.3. Radicenter will only allow access to customer data for appropriate training and authorized personnel. An employee has the right to process customer data only to the extent necessary for him to perform the tasks assigned by Radicenter.

4.4. The client must use the services, including the client account, securely. The Client commits to take all necessary steps to keep the customer account password and user ID secret and to prevent third parties from using them.

4.5. Radicenter is not responsible for the security of client data and is not responsible if the customer data is not protected due to not complying with obligations in section 4.4. (for example, the customer has given a password or user ID to third-party or it has been leaked through third party service used by client). In this case, the client is liable for the damage suffered.

5. OBJECTIVES FOR THE PROCESSING OF CLIENT DATA

Radicenter processes Client Data in order to:

5.1. Identify the client or his legal representative;

5.2. Complete an agreement between Radicenter and the client (eg billing, data transfer for registering domains, notification of technical changes in the service), or ensure that the contract is executed by the customer (sending notifications via email);

5.3. Offer Radicenter Services to the Client

5.4. Check and, if necessary, correct or supplement customer information provided by the customer;

5.5 Fulfill legal obligations (eg transfer of customer data to legal institutions like police or court);

6. COMPOSITION OF CLIENT DATA

Radicenter processes , among other things, following client information:

6.1. Personal data (e.g. name, personal identification code, date of birth, etc.);

6.2. Contact details (address, telephone number, e-mail address, etc.);

6.3. Information about the contracts concluded with the client (incl. Fulfillment of client’s rights and obligations, applications submitted, statements, etc.);

6.4. Billing information (invoices and received / received payments, payment frequency, billing method, etc.);

7. DISCLOSURE AND TRANSMISSION OF CLIENT DATA TO THIRD PARTIES

7.1. Radicenter discloses or provides clinet data:

7.1.1. authorized processors;

7.2. Radicenter shall disclose client data to third parties only to the extent necessary to achieve the objectives set forth in Clause 5 of the Client Data Processing Principles.

7.3. Radicenter is required to disclose client information in accordance with legal obligations (eg transfer of data to legal institutions, the Tax and Customs Board, Police etc).

8. STORING OF CLIENT DATA

8.1. Radicenter reserves the right to store all statements made by the client through a communication device (eg, computer), as well as other operations performed by the client, and, if necessary, to use such records for the purpose of verification, reproduction, or other other purposes specified in clause 3.

9. MODIFICATION OF CLIENT DATA AND ENDING PROCESSING OF CLIENT DATA

9.1. The Client is obliged to inform Radicenter without delay about any changes in client data specified in the contracts or other documents submitted to Radicenter.

9.2. Radicenter processes client data for as long as it is required to meet client data processing objectives or in compliance with a legally binding obligations.

10. PROTECTION OF THE CLIENT‘S RIGHTS

10.1. Client has the right to access the information collected by Radicenter and to obtain information on the use of such data in accordance with the legislation.

10.2. The client has the right to prohibit the use of his electronic contact information for the direct marketing of services through the electronic communications network (for example, Radicenter’s newsletters).

10.3. If the customer finds that Radicenter has violated his / her rights in the processing of client data, he / she has the right to appeal to the Radicenter to end the violation.

10.4. The Client has the right to contact the Estonian Data Protection

Inspectorate (website: www.aki.ee) if he/she

considers that Processing of his/her Personal data

infringes his/her rights and interests under

applicable law.

11. CHANGE OF PRINCIPLES FOR PROCESSING CLIENT DATA

11.1.Radicenter has the right to update these Client Data Processing Principles at any time on the basis of changes in legislation, telecommunication practice and Radicenter services.

Radicenter OÜ 2018