Data Ethics Plan

The document explains how Creativity Lab OÜ processes personal data and how it applies data protection principles. It is an official signed document that is published on our website, www.creativitylab.ee, and which we communicate both within the organisation and to our cooperation partners.

Our data processing principles are rooted in seven general principles for privacy: (1) Lawfulness, fairness, and transparency; (2) Purpose limitation; (3) Data minimisation; (4) Accuracy; (5) Storage limitations; (6) Integrity and confidentiality; (7) Accountability.

1. Introduction

This is an overview of how your personal data is processed (including web cookies) when you use the website www.creativitylab.ee.The controller of your personal data is the Creativity Lab OÜ, registry number 12590320, address Laevastiku 3 (Naked Island), Tallinn 10313.

If you have any questions, you can write to the Data Protection Officer at the address via Laevastiku 3 (Naked Island), Tallinn 10313 or to the email: info@creativitylab.ee 

2. How do we process your data?

We receive your personal data when you provide it to us, in particular by participating in any surveys we may conduct. In addition, we can use cookies on the www.creativitylab.ee website, which helps the site to function technically and ensure user-friendliness.

3. What personal data do we process and why?

We will process the following data:

  • Browsing data. When you connect to our system, this will automatically record the information that your device sends us. This information may relate to the content loaded, the steps taken, the IP address from which you are connecting, the operating system and the language of your device, the date and time of your connection, your position and your browser’s “User-Agent” string.

  • Contact information and communications. When you send us your contact details (email, etc.) and an email or other communication, we will record your contact details and communication.

  • Social network activity. There may be “social-media apps”. These are applications tied to specific social networks that offer specific services and require you to explicitly grant permission to access your personal data stored in the social network. Such permission is granted by interacting with the social network, to whose terms and privacy policy you will agree before proceeding.

  • Cookies. When you use our services, we can send to your device one or more cookies (small text files containing a string of alphanumeric characters):

    • technical cookies, that is, navigation or session cookies, strictly necessary for the operation of the site or to allow you to enjoy that content and the services that you requested;

    • functionality cookies, that is, cookies used to activate specific functionalities of the site and a number of selected criteria (for example, the language or your preferences on the use of cookies) in order to improve the service;

    • profilation cookies, that is, cookies that store (an anonymised form of) the browser’s IP address, the screen size of the client, the client device type, and the language preferences in order to better understand visitors’ browsing habits;

    • third-party cookies, that is, cookies of sites or web servers other than the one hosting our service, used, with your consent, for own purposes of such third parties.

You can control and/or delete the cookies as you like - to learn more, please visit the website http://www.allaboutcookies.org/

Your personal data will be processed for the following purposes:

  • to provide you with our services according to point (b) of Article 6(1) of the Regulation,

  • to evaluate and improve our services and develop new ones, pursuing this legitimate interest according to point (f) of Article 6(1) of the Regulation,

  • to protect the technical functioning of our system, pursuing this legitimate interest according to point (f) of Article 6(1) of the Regulation,

  • to fulfil legal obligations and/or comply with orders from public authorities, including the judicial authorities, according to point (c) of Article 6(1) of the Regulation,

  • to process and diffuse statistics and graphic representations but only in aggregate and anonymous form, pursuing this legitimate interest according to point (f) of Article 6(1) of the Regulation.

We will also process your personal data to inform you about our services and news on our site, pursuing this legitimate interest according to point (f) of Article 6(1) of the Regulation.

4. Transfer of personal data

We may communicate your data:

  • to third parties to comply with legal obligations, to comply with orders from public authorities, including the judicial authorities, and/or to protect our or third parties rights under the law,

  • to third parties in the case of scientific research and studies.

There are currently no plans to transfer your data outside the EU.

5. Ensuring the security of personal data

To ensure the security of all data, we implement technical and organisational security measures. We guarantee the protection of your personal data in case of intentional or unintentional destruction, alteration, undue access or any other unlawful processing.

6. Retention and deletion of personal data

The retention periods of personal data depend on the purpose and legal basis for which we process it. For example, we may be subject to a legal or contractual obligation to retain data for a certain period of time. It may also be based on your and our legitimate interest or your consent.

7. Rights of the person

According to the data protection regulation, you have certain rights in relation to the processing of personal data.

  1. Right of access. You have the right to know who, how, from what sources and what personal data is processed.

  2. Data transfer. You have the right to request the personal data collected about you in a machine-readable format for transfer to another service provider whose services you wish to use, for example, in the future.              

  3. Erasure of data/right to be forgotten. You have the right to request the deletion of your personal data if you no longer want it to be processed and the controller has no legitimate reason to use it.

  4. Restriction/objection to data processing. You have the right to restrict and prohibit the processing of your personal data under certain conditions. You also have the right to object, if there is a good reason, to the use of your data for processing on the basis of a legitimate interest.

  5. Correction of data. You always have the right to rectify or supplement your personal data if it is not accurate and if the inaccuracy may have an impact on you.

  6. The right to withdraw consent. If you have given consent to the processing of your personal data, you always have the right to withdraw it.

To exercise the above rights related to the processing of personal data, please contact us at info@creativitylab.ee. We will answer you within 30 days.

If you have any questions about the processing of your personal data, please contact us at info@creativitylab.ee 

The announcement was last updated in January 2024.