MyDello

Last updated on: 19.04.2021

This Privacy Policy describes the privacy principles and practices adopted by MyDello and shall apply to all relationship between MyDello and the Client related to the use of the Portal by the Client and the provision of Services by MyDello ordered by the Client through the Portal. By placing the Order in the Portal, the Client confirms that he/she has read the Privacy Policy and has acknowledged the terms for processing of his/her Personal Data disclosed during registration and use of the Portal in accordance with the Terms and Conditions.

Unless defined in this Privacy Policy, the terms used in Privacy Policy are used in the meaning given to them in MyDello Terms and Conditions for MyDello Services, available at https://mydello.com/terms-of-service/ and/or in the meaning given to them in Article 4 of the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”).

DEFINITIONS

“Data subject”	Natural peson who uses MyDello Services or whose Personal Data is processed by MyDello.
“Data Controller” or “Controller”		Natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data. For the purposes of this Privacy Policy, MyDello is the data controller of its Clients’ Personal Data.
“Data Processor” or “Processor”		Natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller. For example, Carriers, as defined in the Terms and Conditions are Data Processors for MyDello.
“GDPR”		Defined in the preabmle.
“MyDello”		is MyDello OÜ, a company incorporated in Estonia, with the registry code 14582031, address Punane tn 73, Tallinn 13619, Estonia, e-mail address info@mydello.com, phone number +372 53307900;
“Personal Data”		Any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular on the basis of such a record as the name, personal identification code, place of location information or network identifier, or on the basis of one or more physical, physiological, genetic, mental, economic, cultural or social identities.
“Processing”		Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

WHY WE PROCESS PERSONAL DATA AND WHAT PERSONAL DATA DO WE PROCESS?

When you have opted to use MyDello Services, we need to process your Personal Data to enable the Services to you (data subject) via our Portal.
We process Personal Data that is submitted to us directly by you in the course of using our Portal.
We also process Personal Data that is submitted to us when you contact us with a query or question via Portal or via any other channel (by sending an e-mail, for example). In such a case we process your Personal Data included in the inquiry to the extent that is necessary to respond to you.
Personal Data we process about you in the course of using our Portal may include following data about you:
general personal information: first name; last name; client type (natural person or legal person); ID document;
contact details: email address that you disclose to us when you order any Services though Portal; the data of the company of sender and the recipient of the Consignment; the data of the authorized recipient of the Consignment with whom to contact if necessary to deliver the Consignment (name, email, telephone number or other appropriate means of communications)
data related to the ordered Service: any data you disclose to us as through our Portal when you order any Services though Portal, for example information about the Consignment (incl. confirmation that the delivery does not include Dangerous Goods, for example); Pick up Point; Delivery Point; name and contact details of the authorized recipient of the Consignment;
payment data: information concerning the payment for the Services, including the payment methods used to carry out necessary payments; such data may include your account number, sent payments and other information related to payments;
technical data – to ensure smooth provision of our Services, we may process technical data, which may include your device’s Internet Protocol address (IP address), browser information, information about your device’s operating system, settings, language, date of device and other necessary information which may also be acquired through the use of cookies in our Portal.

IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We process your Personal Data to provide Services to you (please read MyDello Terms and Conditions). Legal basis for such data processing is GDPR Article 6-1-(b), i.e. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
In certain situations, we might process your Personal Data when processing is necessary for compliance with a legal obligation to which we are subject, for example for accounting purposes under applicable accounting legislation. Legal basis for such data processing is GDPR Article 6-1-(c).
In certain specific situations we might also process your Personal Data where processing your Personal Data is necessary for the purpose of our legitimate interests pursued by us. Legal basis for such data processing is GDPR Article 6-1-(f). In such a case we shall ensure that processing is proportionate and that we have carried out legitimate interest impact assessment. For example, for the purpose of our legitimate interest we analyse how our Services and Portal are used by our Clients so we can provide better service; when processing is necessary in connection with an investigation of suspected or actual fraudulent or other illegal activity or in connection with corporate sale, merger, reorganization, dissolution or similar event.
More specifically, we process the following Personal Data for the following purposes:

Personal data	Purpose of processing	Legal basis
First name, last name, client type (natural person/legal person), e-mail address, data about the Consignment (inc. information on Dangerous Goods), Pick up Point, Delivery Pont, Payment data; ID document	Enabling provision of the Services in accordance to Terms and Conditions	GDPR Art. 6 (1) (b)
Accounting related data such as invoices	Fulfilling uur legal obligation arising from accounting laws to process supporting documents of the transactions	GDPR Art. 6 (1) (c)
Technical data	Our legitimate interest to ensure security, continuity and/or improvement of the Portal	GDPR Art. 6 (1) (f)

WHEN DO WE SHARE YOUR PERSONAL DATA?
To the extent this is necessary for the provision of our Services, we may share your Personal Data with certain third parties.
Upon ordering Services via Portal, we share your Personal Data with the specific Carrier who will transport your Consignment. The following Personal Data is shared with the Carrier: your name (first name and last name); data about the Consignment (incl. information on Dangerous Goods), Pick up Point, Delivery Pont.
We may also share your Personal Data with third party suppliers providing services to us, e.g. IT suppliers, web server service providers or other service providers. MyDello shall select service providers who confirm to process Personal Data in accordance with the applicable privacy regulations and this Privacy Policy. MyDello will never sell or otherwise exploit the Personal Data of our Clients contrary to out Terms and Conditions.
We may also transfer your Personal Data to third countries, i.e. countries outside the EU/EEA area, for the purposes explained in this Privacy Policy. When transferring your Personal Data to third countries, we will ensure that the transfer is subject to appropriate safeguards under GDPR and that your rights are protected.

HOW LONG IS YOUR PERSONAL DATA RETAINED?

MyDello does not retain Personal Data longer than it is necessary for the purposes of processing Personal Data or pursuant to applicable law.
Personal Data related to contracts can be retained during the term of the contract and based on our legitimate interest pursuant to Article 6 (1) (f) of the GDPR until the end of the statutory limitation periods under applicable law. Accordingly, as a general rule MyDello retains your Personal Data as long as it is necessary for the provision of the Services during the term of the contract concluded between you and MyDello and for 3 years after the term of the contract.
Pursuant to the Accounting Act, we retain accounting documents for 7 years.
Technical data collected by the use of the cookies, are retained as indicated in the section “Cookies”.

HOW DO WE PROTECT YOUR PERSONAL DATA?

To protect your Personal Data from unauthorized access, unlawful processing or disclosure, accidental loss, modification or destruction, we use appropriate technical and organisational measures that comply with applicable laws. These measures include but are not limited to the implementation of appropriate computer security systems, protection of paper and electronic format files by technical and logical means, controlling and limiting access to documents and buildings.

COOKIES

Our Portal uses cookies. This section incorporates our cookie policy (the Cookie Policy) that applies when you use Portal.
Cookies are small data files stored on your hard drive by a website. Cookies help us monitor and improve the functionality and usage of our Portal and your experience on Portal. We can use cookies to see which areas and features are popular and to count visits to our Portal to recognise you as a returning visitor and to tailor your experience of the Portal according to your preferences. We may also use cookies for targeting or advertising purposes.
We may use the following type of cookies on our Portal:
Strictly necessary cookies, that are essential in order to enable you to navigate and use the features of the Portal.
Functional cookies, that record information about choices you have made that allow us to tailor Portal to your needs. Functionality cookies remember choices you make.
Statistics cookies, that record information about the way our Portal is used, to acquire knowledge on how often our Portal is visited, where on our Portal our visitors spend the most time, how often they interact with a page or part of a page, this allows us to make the structure, navigation, and content of our Portal as user-friendly as possible.
Advertising cookies and third party cookies that allow advertisers to track your use of the Portal to target advertising and content that might interest you the most.
The specific cookies that Portal uses are the following:

Name	Purpose	Retention period
_ga	Registers a unique ID that is used to generate statistical data on how the visitor uses the website	2 years
_gat	Used by Google Analytics to throttle request rate	1 day
_gid	Registers a unique ID that is used to generate statistical data on how the visitor uses the web site	1 day
_hjid	Sets a unique ID for the session. This allows the web site to obtain data on visitor behaviour for statistical purposes	1 year
_hjid	Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes	Persistent
_fbp	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers	3 months
_hjIncludedInSample	Determines if the user’s navigation should be registered in a certain statistical place holder.	Session
ads/ga-audiences	Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor’s online behaviour across websites	Session
cid	Optimises ad display based on the user’s movement combined and various advertiser bids for displaying user ads	2 months
fr	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers	3 months
tr	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers	Session
uid	Registers a unique user ID that recognises the user’s browser when visiting web sites that use the same ad network. The purpose is to optimise display of ads based on the user’s movements and various ad providers’ bids for displaying user ads	2 months
_hjTLDTest	To check whether user’s browser has cookies enabled	Session

You can delete or block cookies on Portal through your browser settings at any time. However, some cookies might be necessary for the functionality of Portal. Therefore, you understand that when blocking or deleting the cookies some features of Portal might not function correctly.
For more general information about cookies including the difference between session and persistent cookies please see www.allaboutcookies.org.
In case you have any question concerning the use of cookies, you may contact us via contact details provided below.

YOUR RIGHTS

MyDello is dedicated ensuring that all data subject rights arising under applicable law are always guaranteed to you. In particular, any data subject has:
the right to access the Personal Data that MyDello processes about you;
the right to request that MyDello rectifies any inaccurate Personal Data about you;
the right to request MyDello to erases your Personal Data and/or restricts of processing of your Personal Data if we do not have valid legal basis for processing;
the right to receive your processed Personal Data in a structured, commonly used and machine-readable format and have the right to transmit your Personal Data to another Controller;
the right to object to the processing of your Personal Data.
If you believe that your rights have been infringed, you may contact and lodge a complaint to the supervisory authority applicable for your jurisdiction (Data Protection Inspectorate in Estonia address Tatari 39, Tallinn 10134, info@aki.ee or other competent authority in your jurisdiction – you can find your data protection authority on the following website: https://edpb.europa.eu/about-edpb/board/members_en).

GOVERNING LAW AND JURISDICTION

This Privacy Policy shall be governed by the laws of the Republic of Estonia. Any disputes arising from these Privacy Policy shall be settled in the Harju County Court in the Republic of Estonia, unless you have a right to turn to the court of your residence pursuant to statutory law.

CONTACTs

If you have any questions about this Privacy Policy or Cookie Policy or if you have any concerns about how we use your personal or if you want to exercise your rights as described above, you may contact us via e-mail or in writing using the following contact information:

MyDello OÜ

e-mail: info@mydello.com
address: Punane tn 73, Tallinn 13619, Estonia
phone: +372 53307900

Privacy policy