PRIVACY NOTICE

This privacy notice (hereinafter „notice“) explains how Matter Holding OÜ (hereinafter “we” or „us“) processes personal data of visitors (hereinafter “you” or the “data subject”) of our website https://matter-id.com/ (hereinafter “website”).

This notice describes the processing of personal data by us as a data controller. This means that we individually or along with others determine the purposes and means of the processing of personal data.

1. DATA CONTROLLER

Matter Holding OÜ

Registry code: 16768370

Address: Meistri tn 14 Haabersti linnaosa, Tallinn Harju maakond 13517

Email: info@matter-id.com   

Contact details of Data Protection Officer: privacy@matter-id.com

2. PERSONAL DATA WE PROCESS

”Website visit data” – this includes the personal data which is processed upon visiting and using our website. Depending on the particular cookie we use, the types of personal data may include online identifiers, including cookie identifiers, IP addresses, device identifiers, client identifiers and session ID. 

Please see more information regarding cookies and other tracking technologies in Section 7 of this notice. 

3. THE PURPOSES AND THE LEGAL GROUNDS FOR THE PROCESSING OF PERSONAL DATA

   1.  Consent

We process your personal data based on your consent for the purposes described below. You always have the right to withdraw the consent by changing your preferences via website. Withdrawal of the consent does not affect the legality of the processing of your personal data prior to withdrawal.

2.  Legitimate interests

We process your personal data based on our legitimate interests for purposes described below. You have the right to ask clarifications regarding the processing based on the legitimate interests. You also have the right to send the objection, if you find that processing of your personal data for the purposes provided below prejudice your rights. Please see Section 1 of this notice for our contact details.

4. CATEGORIES OF RECIPIENTS OF PERSONAL DATA AND TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

In some cases, we may transfer your personal data to certain recipients who are categorized as follows:

1. Partners who provide the services to us, and who process the personal data on our behalf (data processors), e.g.:

   1. Providers of ICT services (including providers of website hosting services and other providers of cloud services).

   2. Various contractors (IT development, support).

2. Public authorities and supervisory bodies, e.g., court, law enforcement authorities, Data Protection Inspectorate. We transfer your personal data to public authorities and supervisory bodies only if the law requires it. 

Unless necessary for the provision of services, we do not transfer your personal data outside of the European Union (EU) or the European Economic Area (EEA), nor to such third country or international organization, the level of data protection of which the European Commission has not considered adequate. If your personal data is transferred outside of the EU or EEA, such transfer of personal data will take place only upon appropriate legal basis, and we will take appropriate protective measures.

You have the right to get additional information about the transfer of your personal data by sending us the relevant request at info@matter-id.com.   

5. RETENTION OF PERSONAL DATA

We keep your personal data for the period necessary for the achievement of purposes stated in this notice or until the law requires it. You can get acquainted with cookie retention periods in Section 7 of this notice.

Specific terms of retention can be exercised by accessing your personal data. Please see the explanation in the section “Your rights regarding the personal data”.

6. YOUR RIGHTS REGARDING THE PERSONAL DATA

Right of access to your data: you have the right to know, whether personal data concerning you are being processed or not, what is the purpose of processing and what are the categories of personal data. Besides, to whom the personal data is disclosed (especially the recipients in third countries), for how long the personal data is retained and what are your rights concerning rectification, erasure and restriction of the processing.

Right of rectification: you have the right to demand rectification of the personal data concerning you if the data are inaccurate or incomplete.

Right of erasure: in some cases, you have the right to demand erasure of the personal data concerning you, for example in case when you withdraw your consent and there are no other legal grounds for the processing of the personal data.

Right to restrict the processing: in some cases, you have the right to restrict processing of the personal data concerning you for a certain time (e.g., if you have objected the processing of personal data).

Right to object: you have the right to object the processing of personal data, which is processed based on the legitimate interest, including profiling. Upon objection, we will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.

Right to data portability: if processing of your personal data is based on your consent or the contract with us and the data processing is carried out by automated means, then you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to claim to transmit those personal data to another service provider if it is technically possible.

Right to turn to us, supervisory authority, or a court: if you want to exercise the above-mentioned rights, please send us an email at privacy@matter-id.com. If you find that your rights have been breached, you have the right to turn to the Data Protection Inspectorate (Andmekaitse Inspektsioon) and/or court. The contact details of the Data Protection Inspectorate are available at www.aki.ee. 

7. COOKIES AND OTHER WEB TECHNOLOGIES

We use all the cookies, except the “essential” technical cookies, with your prior consent. You always have the right to withdraw the consent by changing your preferences via our website. Should technical cookies process your personal data, we rely on our legitimate interests in processing of such data (see the section above that explains our legitimate interests).

We use first-party cookies (i.e., the cookies which belong to us), but also third-party cookies (i.e., the cookies that belong to third-party service providers, such as Google). 

We may use both session cookies and persistent cookies. Session cookies or non-persistent cookies are cookies that exist only temporarily while you browse our website. Your web browser should delete these cookies when you close your browser. On the other hand, persistent cookies that we use expire at a specific date or after a specific length of time set by the third-party or us.

For your convenience, we have categorized the cookies we use on our website by their purposes as follows:

Hereunder we have listed all the cookies used on our website. You will find the information regarding their purpose, retention period and whether it is a first-party or a third-party cookie.

8. AMENDMENT OF THIS NOTICE

We have the right to amend this notice unilaterally. We will notify of amendment of this notice on our website, by email or in other manner.