Information about the processing of personal data of the ENVYme customers for direct marketing and analytics purposes

• 1. We use the electronic contact information you provide to send you information and special offers on topics you choose to promote ENVYme business. The legal basis for the processing of your personal data is your consent (Article 6(1)(a) of the General Data Protection Regulation (hereinafter “GDPR”)).
• 2. We use the electronic contact information you provide to send you information and special offers on topics you choose to promote ENVYme business. The legal basis for the processing of your personal data is your consent (Article 6(1)(a) of the General Data Protection Regulation (hereinafter “GDPR”)).
• 3. If you agree to this, then the information and special offers will be personalized, i. they will be sent to you based on our understanding of your interests and behavior. When making such offers, we may contact you based, for example, on your use of ENVYme services (for instance, if you prefer certain drinks in ENVYme bars, we may inform you that such drinks have become available in other establishments; if you previously participated in certain activities or offers, we may offer them to you again, we may also present special offers to users, etc.). Through these activities, we want to get to know you better so that we can encourage you to use our services. In doing so, we use both profiling and automated decision-making. Automated decisions are usually made without human intervention. However, they do not have any legal effect on you and do not have any significant impact on you. The worst possible situation could be that we send you offers that you are not interested in. We strongly encourage responsible entertainment and relaxation. You have the right to use human intervention in decision-making, to express your opinion about such decisions, and challenge such decisions. The legal basis for the processing of your personal data is your consent (Article 6(1)(a) GDPR).
• 4. We will process your personal data for the above purposes until you withdraw your respective consent(s) and from time to time we will ask you to update your preferences.
• 5. We will also provide you with information and special offers over the phone or when you visit the ENVYme bar. Such offers are usually personalized, ie. they will be sent to you based on our understanding of your interests and behavior as described above. The legal basis for the processing of your personal data is our legitimate interest in promoting the ENVYme business (Article 6(1)(f) GDPR). We have concluded that in such a case, given the circumstances, your interests or fundamental rights requiring the protection of personal data do not override our legitimate interest. You have the right to object to such processing at any time by contacting us, the contact details are provided below. In this case, your personal data will no longer be processed for direct marketing purposes.
• 6. We use the personal data that you have provided to us, or that has been generated based on your use of the ENVYme services, at an aggregate level for analytics, i.e. to better understand our customers, their needs, and behavior so that we can make better marketing and commercial decisions. For example, we do this to understand which ENVYme services are popular and should be available; in what locations should the bars be placed to increase their popularity; which ENVYme events are popular; what are the characteristics of customers who are active only online or offline, or both, etc. Although such analytics may initially be based on some of your personal data, such data is aggregated, and no personal data is not used in any reports. The legal basis for the processing of your personal data is our legitimate interest in making better marketing and commercial decisions and in promoting the ENVYme business (Article 6(1)(f) GDPR). We have concluded that in such a case, given the circumstances, your interests or fundamental rights requiring the protection of personal data do not override our legitimate interest. You have the right to object to such processing at any time in relation to your situation by contacting us at the contact details provided below. In such case, we will no longer process your personal data for analytics purposes unless we demonstrate compelling and reasonable grounds for such processing that overrides your interests, rights, and freedoms.
• 7. We will process your personal data for the above purposes until you object to such processing and we have the right to continue such processing, or until an agreement between you and any of us is in force.
• 8. You have all data subject rights under the GDPR, including the following:
• • The right to withdraw consent at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of consent prior to its withdrawal.
  • The right to obtain confirmation of whether personal data concerning you are being processed or not, and to receive a copy of such data.
  • The right to have inaccurate personal data concerning you corrected, including the right to have incomplete personal data completed.
  • The right to delete your personal data.
  • Right to restrict processing.
  • The right to receive your personal data that you have provided to us in a structured, commonly used, and machine-readable format, as well as the right to transfer such data to another controller without any obstruction on our part.
  • The right to lodge a complaint to a supervisory authority in the EU Member State where your main place of residence or place of work is located, or to the Estonian Data Protection Inspectorate (www.aki.ee).
  • Please note that not all of the above rights are absolute and that they may be limited for the purposes permitted under the GDPR. You are able to exercise some of your rights by visiting the ENVYme bar reception or by logging into your ENVYme account, or in any case by contacting us using the contact details below.
• 9. Please note that our other personal data processing practices are described in our respective Privacy Policies, which are available on our respective websites (the ENVYme website – www.envymeclub.com). The ENVYme Privacy Policy is also available at the ENVYme bars. Please note that withdrawal of consent(s) or refusal to process personal data for marketing and analytics purposes does not prevent us from processing your personal data for other purposes described in the Privacy Policy.
• 10. Contact details for more information: Data Protection Officer Alexander Kuznetsov, estonia@envymeclub.com.

Information about the processing of personal data of the ENVYme clients

• The main processor of personal data is BALTIC VA ENTERTAINMENT GROUP OÜ (hereinafter: the company), at the address Nurga 4, Maardu, 74113, Estonia, +37256889223, estonia@envymeclub.com
• You have an opportunity to contact the company's Personal data protection officer at the email address estonia@envymeclub.com or the company's public telephone number - +37256889223.
• The client has the right to receive information about whether the company is processing their personal data and, if processing, to receive a copy of this data.
• The client has the right to demand that incorrect data relating to them be changed.
• If the processing of data takes place on the basis of the consent of the client, then the client has the right to withdraw their consent at any time. The withdrawal of consent does not affect the lawfulness of data processing before the withdrawal of consent.
• The client has the right to object to the processing of data processed for direct marketing purposes at any time. Such refusal does not affect the lawfulness of the processing of previously processed data.
• The client has the right to demand the deletion of their personal data. The company is not under an absolute obligation to delete personal data. The Company may delete those personal data that are processed on the basis of consent or legitimate interest if the interests of the Company do not outweigh the interests of the Client. The right to delete does not apply to data that is processed in order to fulfill a statutory obligation or on the basis of a contract, as long as such statutory or contractual obligation exists.
• The client has the right to object to the processing of their personal data (primarily justified processing) and to restrict the processing of their personal data if it is justified.
• The client has the right to receive the personal data submitted by them in a structured and machine-readable form (if it is technically possible) to provide them to another service provider.
• During the data processing, the Company transfers personal data relating to the client to third parties if this is necessary for the performance of obligations arising from legal acts or contracts. Data can be received by government agencies, oversight agencies, and service providers such as firms that provide databases of politically exposed (PEP) as well as sanctioned persons; website software providers; SMS or email service providers; providers of customer feedback register service; online survey service provider.
• In order to provide the service, the company has the right to provide the personal data of customers to other companies of BALTIC VA ENTERTAINMENT GROUP OÜ.
• The client has the right to submit a complaint about the use of data to the Data Protection Inspectorate by writing to info@aki.ee or by coming to the Data Protection Inspectorate (Tatari 39, 10134, Tallinn).
• Descriptions of the processing of personal data:
• • Registration of such additional personal data of the client as gender and language of communication The basis for processing: Justified interest Data Retention: 5 years from the last customer visit
  • Adding a customer photo to their account The basis for processing: Justified interest Data Retention: 5 years from the last customer visit
  • Saving recordings from surveillance cameras to assess the quality of service The basis for processing: Justified interest Data retention: 30 days
  • Compilation of quality of service surveys based on CCTV footage The basis for processing: Justified interest Data retention: 3 years
  • Issuance of an ENVYme club card The basis for processing: Membership Card Agreement In case of refusal to provide personal data, the Club Card is not issued Data Retention: 5 years from the last customer visit
  • Accrual of bonus coins when paying in bars with a Club Card The basis for processing: Membership Card Agreement Data Retention: 5 years from the last customer visit
  • Accrual of bonus coins to the Club Card as a result of payment in bars or marketing campaigns The basis for processing: Membership Card Agreement Data Retention: 5 years from the last customer visit
  • Analysis of the turnover of bonus coins in order to determine the level of the client's club card The basis for processing: Membership Card Agreement Data Retention: 5 years from the last customer visit
  • Payment for bar products with bonus coins or other complementary coins The basis for processing: Membership Card Agreement Data Retention: 5 years from the last customer visit
  • Calculation of discounts on bar products for Club Card holders The basis for processing: Membership Card Agreement Data Retention: 5 years from the last customer visit
  • Gifts for clients The basis for processing: Justified interest Data Retention: 5 years from the last customer visit
  • Participation in marketing campaigns for paper tickets The basis for processing: Consent of the client Data retention: 3 months after the end of the campaign
  • Winning in marketing campaigns with paper tickets The basis for processing: Consent of the client Data retention: 7 years
  • A client's power of attorney giving the right to take part in the giveaway of a marketing campaign to another person The basis for processing: Consent of the client Data retention: 1 year
  • Data collection of potential customers at public events The basis for processing: Consent of the client Data retention: Until the customer's consent is withdrawn
  • Sending marketing information about the games of the event to customers by e-mail or SMS The basis for processing: Consent of the client Data retention: 1 year
  • Purchase and use of entertainment packages The basis for processing: Sales contract Data Retention: 5 years from the last customer visit
  • Providing, registering, and processing customer feedback The basis for processing: Consent of the client In case of refusal to provide personal data, the company does not have the opportunity to provide a response Data retention: 1 year
  • Conducting customer satisfaction surveys via the website The basis for processing: Consent of the data subject Data retention: Data is deleted at the end of the use of the service
  • Calculation of the client's debt to the enterprise in case of damage to the property of the enterprise by the client The basis for processing: Implementation of the contract for the payment of damages in installments Data retention: 7 years
  • Processing of the User's personal data in the VAG database in order to make direct marketing offers The basis for processing: Justified interest Data Retention: 5 years from the last customer visit
  • COVID certificate verification The basis for processing: Decree of Government of the Republic Order No 282 'Measures and restrictions necessary for preventing the spread of COVID-19' paragraph 20'18 3) Data saving: Data is not saved
  • Storing the COVID certificate in the Client’s account The basis for processing: Consent of the client Data Retention: 5 years from the last customer visit
  • Using surveillance footage to create and defend claims/legal proceedings The basis for processing: Justified interest Data retention: Until compensation for damages
  • Transfer of information about damage to the insurance company due to destruction of the company's property by the client The basis for processing: Justified interest Data retention: Until compensation for damages.