Hallwil Privacy Notice

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Last Updated: March 20, 2023

This website available at www.hallwil.com (the “Website”) is provided by Hallwil OÜ (“we”, “us”).

In this Privacy Notice, we explain which types of personal data we hold on you, how we collect and process such data, how long we keep it, and other relevant information about your personal data being processed in connection with your access to and use of the Website.

Personal data or personal information means any information directly or indirectly identifies you as an individual. In this Privacy Notice we use “personal data” and “personal information” as synonyms.

We process your personal data in accordance with this Privacy Notice and we endeavour to comply with the applicable data protection legislation, which includes the General Data Protection Regulation, also known as the GDPR (the “Applicable Legislation”).

If you have any questions regarding processing of your personal data, do not hesitate to contact us.

What data we collect

When you access and use the Website, we may collect the following data:

Contact Data

If you contact us, request a call or fill in a request form, you may provide us with some of your personal data, such as your name and email address.

Automatically-Collected Data

Certain personal data may be collected when you access and browse the Website:

Google. When you access and use the Website, certain data may be collected automatically via solutions provided by Google, such as Google Analytics, Tag Manager, Doubleclick. More information regarding Google solutions is available here.

The information gathered by Google includes the following: (i) Internet Protocol (IP) address, (ii) the type of device used, (iii) the device operating system, and (iv) the browser used. After collecting the personal data, Google creates reports about the use of the Website, which contain the aggregated information where we do not see any data pertaining to a particular person. In other words, we cannot identify you from the other users. For better understanding, IP address means an “online address” of a device, which may help to identify your approximate location (e.g, country, city or region, ZIP code). The IP addresses are expressed as a set of numbers, for example: 194.150.2.33. Please note that according to Google’s documentation, the IP address is anonymised (masked), so neither we nor Google can identify the IP address and precise location of a particular visitor. We gather the information by means of placing cookies. Cookies are a feature of the software that allows web servers to recognise the device used to access the Website. A cookie is a small text file that the Website saves on your device when you visit thereof. They allow the Website to remember your actions and preferences over a period of time to improve the Website.

In addition to the above, by using the tools provided by Google, we collect certain information regarding the use of the Website, for instance, when you clicked a certain button or made some input. This information is also aggregated and we cannot identify your actions from the actions of other users. 

Google solutions are operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and its affiliates including Google LLC, 1600, Amphitheatre Parkway, Mountain View, CA, 94043, USA.

To our knowledge, the data collected via Google solutions is not anonymised (with the exception of the IP address) and will be transmitted to, processed and stored by Google in the United States. You can learn more about how Google processes personal data in Google’s privacy policy. Note that competent US state authorities may have access to the personal data collected via Google solutions.

With respect to the personal data collected via Google solutions, Google acts as our data processor. However, Google may use this personal data for any of its own purposes, such as profiling and cross-platform tracking. In this case, Google acts as an independent data controller. You can learn more about Google tools here.

Meta. The Website uses the so-called Meta Pixel provided by Meta for the following purposes:

  • Meta Custom Audiences. We use the Meta Pixel for the remarketing purposes to be able to contact you again within 180 days. This allows us to display interest-based advertisements (Meta Ads) to the Website visitors when they visit Meta products or other third-party websites also using the Meta Pixel tool. In this way, we pursue the interest in displaying advertisements that are of your interest in order to promote us and make the Website or its content more interesting for you.
  • Meta conversion. We also use the Meta Pixel to ensure that our Meta Ads match the potential interest of users and are not irritating. With the Meta Pixel, we can track the effectiveness of the Meta Ads. This is necessary for statistical and market research purposes by seeing whether users were redirected to the Website after clicking on the Meta Ads.

Your browser automatically establishes a direct connection with the Meta server as soon as you have agreed to the use of the Meta Pixel cookies. Through the integration of the Meta Pixel, Meta receives the information that you used our Website or clicked on an advertisement from us. If you are registered with any of Meta products, Meta can assign the visit to your respective account.

The Meta Pixel tool is operated by Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, and its affiliates, including Meta Platforms, Inc., 1 Hacker Way, Menlo Park, CA, USA.

The terms of the Meta Pixel data processing by Meta and us are established in the Data Processing Terms. The transfer of data to Meta is conducted pursuant to the European Data Transfer Addendum. Meta will transfer the data collected via the Meta Pixel to the United States of America, which jurisdiction does not ensure the same level of data protection as in the EEA, UK, or Switzerland. Therefore, the transfer is conducted on the basis of the Standard Contractual Clauses adopted by the European Commission, which are incorporated in the European Data Transfer Addendum.

Meta processes the data received from the Meta Pixel tool in accordance with their Meta Privacy Policy. Additional information regarding the Meta Pixel may be found in the Meta Pixel Help Center.

Meta are joint controllers (i.e. jointly responsible with us) for the following data processing activities in connection with the Meta Pixel:

  • creation of individualised or suitable ads, as well as for their optimization;
  • delivery of commercial and transaction-related messages.

The following data processing activities are not covered by the joint controllership:

  • the process that takes place after the collection and transmission is within the sole responsibility of Meta;
  • the preparation of reports and analyses in aggregated and anonymised form is carried out by Meta as a processor and we act as a data controller.

We have concluded a corresponding agreement with Meta for joint controllership. This agreement defines the respective responsibilities for fulfilling the obligation under the data protection legislation with regard to joint controllership. In particular, we have agreed with Meta that Meta can be used as a contact point for the exercise of your data protection rights regarding the data collected by the Meta Pixel tool.

How do we use your data

Contact Data

The Contact Data is collected when and if you would like to reach out to us. From the legal standpoint, we collect and process the Contact Data to take steps at your request prior to entering into a contract and further to perform such a contract, if and to the extent you wish to enter into a contractual relationship with us. We may also process your Contact Data based on our legitimate interest to answer to your request or to follow you up on a matter that might be of your interest.

Automatically-Collected Data

The Automatically-Collected Data helps us to analyse the use of the Website and provide a better user experience by improving the Website user flow and interface. We also use the Automatically-Collected Data to conduct a targeting advertising campaign towards the Website visitors. From the legal standpoint, we collect and process the Automatically-Collected Data on the basis of your consent. You may provide or withdraw your consent at any time on the Website.

How long do we process your data

We keep personal data as long as it is necessary for the purposes it was collected. We may process certain personal data longer than outlined below, if it is necessary (i) to meet our legal obligations under the applicable laws, (ii) in relation to anticipated or pending legal proceedings, or (iii) to protect our rights and legitimate interest or those of third parties.

We store the Contact Data as long as we cooperate or communicate with you and for further 5 years. 

The Automatically-Collected Data is stored as follows:

  • The data collected by Google is stored for up to 2 years. You may find specific timelines here.
  • The data collected by Meta is stored for up to 180 days after last interaction with the Meta Pixel.

How do we share your data

We do not sell or rent out your data. However, we may share your personal data in accordance with this Privacy Notice, the Applicable Legislation, or with your consent, in each case for the purposes of and if it is reasonably necessary (i) to provide you with access to the Website and perform our undertakings with you, (ii) for compliance with the applicable laws, and (iii) for our legitimate interest to maintain, improve and develop the Website. Given the purposes outlined above, your personal information is shared with the following categories of recipients:

  • analytical solution providers, such as Google and Meta;
  • support and technical teams;
  • hosting service providers;
  • third-party solutions integrated within the Website, for instance solutions to book a call or fill in a form;
  • government authorities, upon their request or if necessary to comply with a legal obligation;
  • another entity if we sell or otherwise transfer the Website.

Your rights

According to the Applicable Legislation, you may have the following rights:

  • right to access your personal data. This enables you to ask us whether we process your personal data and, if we do process your data, you may request certain information about the processing activity and/or a copy of the personal data we hold about you, and check that we are lawfully processing it;
  • right to rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you completed or rectified, though we may need to verify the accuracy of the new data you provide to us;
  • right to erasure of your personal data (commonly known as a “right to be forgotten”). This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal or technical reasons which will be notified to you, if applicable, at the time of your request;
  • right to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
  • right to restrict the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data’s accuracy, (ii) where our use of the data is unlawful but you do not want us to erase it, (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
  • request the transfer of your personal data to you or to a third party (commonly known as a “right to the data portability”). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
  • right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent;
  • not to be subject to a decision based solely on automated processing of data, including profiling, which produces legal effects concerning you or similarly significantly affecting you;
  • right to file a complaint with a relevant supervisory authority in case we violate your rights or obligations imposed on us under the Applicable Legislation. The relevant supervisory authority will particularly depend on where you are located.

The details of the Estonian data protection supervisory authority:

Estonian Data Protection Inspectorate

Website: https://www.aki.ee/en

Address: 39 Tatari St., Tallinn, 10134, Estonia

Phones: +372 627 4135

E-mail: info@aki.ee.

In order to exercise your rights as a data subject, we may request certain information from you to verify your identity and confirm that you have the right to exercise such rights.

Children data

The Website is not intended for the use of children (under 18 years old or older, if the country of your residence determines a higher age restriction). We do not knowingly market to, solicit, process, collect, or use personal data of children. If we become aware that a child has provided us with personal information, we will use commercially reasonable efforts to delete such information from our systems. If you are the parent or legal guardian of a child and believe that we have collected personal information from your child, please contact us.

Changes to this Privacy Notice

We keep our Privacy Notice under regular review and may update it at any time. If we make any changes to this document, we will change the “Last Updated” date above.

Contact details

Our contact details are:

Name: Hallwil OÜ

Address: Estonia, 10152, Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-201

Email: legal@hallwil.com

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