Privacy Policy EE

1.1   Data Subject is a natural person about whom Triniti has got information or data enabling to identify the natural person. Data Subjects are, for example, the Clients, Visitors and cooperation partners, as well as the employees who are natural persons and whose personal data are held by  Triniti.

1.2   Privacy Policy is this text which sets out the principles for Personal Data Processing by Triniti.

1.3   Personal Data is any information concerning an identified or identifiable natural person.

1.4   Personal Data Processing is any operation or set of operations which is performed on the Personal Data of a Data Subject.

1.5   Client is any natural or legal person that uses or has expressed a desire to use the Services of Triniti.

1.6   Agreement is the Service Agreement or any other agreement entered into between Triniti and the Client.

1.7   Terms and Conditions set forth the general terms and conditions applied to the Visitors of Triniti Website.

1.8   Website means the websites of Triniti , the list whereof is available here: https://triniti.ee/ , https://triniti.lv /, https://triniti.lt/ , https://triniti.eu/ and other connected Triniti’s websites, not including links to third-party websites (such as social media platforms).

1.9   Visitor is any person using the Website of Triniti.

1.10 Child is a person who is under 13 years of age in the context of Personal Data Processing in the Republic of Estonia.

1.11  Services are legal services and products provided by Triniti, including Information Society Services and products offered by Triniti.

1.12  Cookies are the data files sometimes recorded in the device of a Visitor of the Website.

1.13  Triniti’s Person responsible for data protection is the person who monitors the implementation of the Personal Data Processing principles at Triniti and who can be contacted by the Data Subject in case of a complaint.

1.14  Communication Channels are the means used by Triniti  for communicating with a Data Subject, devices created for selling the goods and providing the services, including e-mail, telephone, public and social media, various chat lines, individualised and interactive advertisements and other tools on the Websites and elsewhere.

1.15  Client Account is an account based on a specific project of a natural person or a legal entity or a specific project of the Client, which provides access to Triniti’s digital products and through which the Client identifies himself.

The above words and expressions are used in the meanings set out above in the Privacy Policy, Agreement, Terms and Conditions and in the communication between the parties.

2.1  Triniti is the legal person (private limited company) Triniti Attorney’s Office, registry code 11984324, registered address City Plaza, 15. floor Tartu mnt 2, 10145 Tallinn.

2.2  Triniti may process Personal Data as:

(1)   a controller, while determining the purposes and means of processing;
(2)   a processor in accordance with the instructions from the controller; and
(3)   a recipient to the extent to whom the Personal Data are transferred.

2.3  This Privacy Policy of Triniti constitutes an inseparable part of the Agreement entered into between Triniti and the Client; for Visitor Terms and Conditions apply together with this Privacy Policy.

2.4  The rights and obligations set out in the Privacy Policy shall be followed by all the employees and cooperation partners of Triniti who come into contact with the Personal Data that are in the possession of Triniti.

2.5  The Privacy Policy may supplement the privacy statements published on the Website or in the devices, and the Privacy Policy may also be amended and supplemented by the same.

3.1  Triniti shall always take into account the interests, rights and freedoms of Data Subjects. The objective of Triniti is to Process Personal Data responsibly, based on the best practice, with the aim of always being prepared to demonstrate the conformity of Personal Data Processing to the established purposes.

3.2  All the processes, guidelines, operations and activities of Triniti that are related to Personal Data Processing are based on the following principles:

(1)   Lawfulness. There is always a legal basis for the Processing of Personal Data, i.e. consent;
(2)   Fairness. Personal Data Processing shall be fair, while providing a Data Subject with sufficient information and communication on how the Personal Data are Processed;
(3)   Transparency. Personal Data Processing shall be transparent for the Data Subject;
(4)   Purposefulness. Personal Data shall be collected for legitimate purposes that have been established precisely and clearly, and shall not later be processed in any manner which is in conflict with these purposes. A Data Subject will always be able to examine the established purpose of Processing for a specific purpose;
(5)   Minimisation. Personal Data shall be adequate, relevant and limited to what is necessary for the purpose of Processing the given Personal Data. Triniti  shall be guided by the principle of minimum Processing in Personal Data Processing, and as soon as the Personal Data are no longer necessary or are no longer needed for the purposes for which they were collected, the Personal Data shall be deleted or archived;
(6)   Accuracy. Personal Data shall be correct and shall be updated as necessary, and all reasonable measures shall be taken to ensure that Personal Data which are incorrect in the light of the purpose of Personal Data Processing shall be deleted or corrected without delay;
(7)   Limit of storage. Personal Data shall be stored in the format enabling the identification of Data Subjects only as long as it is necessary to achieve the purpose for which the Personal Data are processed. It means that in case Triniti wishes to store the Personal Data for a longer period of time than necessary for the purpose of collecting the data, Triniti shall anonymise the data in such manner that the Data Subject shall no longer be identifiable. Triniti shall store the data that have been received by Triniti via a client relationship or any other similar relationship, in accordance with the law and guidelines of Estonian Bar Association. The data processed under the basis of consent will generally be retained by Triniti until consent is withdrawn The storage periods regarding different purposes of Processing are set out in the Privacy Policy;
(8)   Reliability and confidentiality. Personal Data Processing shall be carried out in the manner ensuring the adequate security of Personal Data, including their protection against unauthorised or unlawful Processing and against accidental loss, destruction or damage, by taking reasonable technical or organisational measures. Triniti has internal guidelines, rules for the employees, and separate agreements with every processor, stipulating the best practices, on-going risk assessment and adequate technical and organisational measures for Personal Data Processing;
(9)   Data protection by design and by default. Triniti shall ensure that all the systems used shall meet the required technical criteria. The suitable data protection measures have been planned upon the renewal or design of every information or data system (e.g. the information systems and business processes are constructed using pseudonymisation and encryption).

3.3  Upon Personal Data Processing Triniti shall act with the purpose of always being capable of evidencing the conformity to the aforesaid principles and additional information regarding the conformity to these principles can also be requested from the Person responsible for data protection.

4.1  Triniti collects, inter alia, the following types of Personal Data:

(1)   the Personal Data disclosed to Triniti by the Data Subject;
(2)   the Personal Data generated as a result of the day-to-day communication between the Data Subject and Triniti;
(3)   the Personal Data manifestly made public by the Data Subject (e.g. in social media);
(4)   the Personal Data generated upon consumption of Services (e.g. in the use of the online shop of Triniti);
(5)   the Personal Data generated as a result of visiting and using the Website (e.g. the time spent on the Website);
(6)   the Personal Data received from third persons (e.g. data provided by the employer for registering the employee’s to Triniti’s event);
(7)   the Personal Data created and combined by Triniti (electronic correspondence or order history in the context of a client relationship).

5.1  Triniti shall Process Personal Data only on the basis of consent or on a legal basis. Legal bases for Processing of Personal Data include but are not limited to legitimate interests, Bar Association Act or an Agreement between the Data Subject and Triniti.

5.2  Triniti shall Process Personal Data on the basis of consent precisely within the limits, to the extent and for the purposes determined by the Data Subject. As for consents, Triniti shall follow the principle that every consent shall be clearly distinguishable from other matters, in an intelligible and easily accessible form, using clear and plain language. Consent may be given in writing or by electronic means or as an oral statement. A Data Subject shall give the consent freely, specifically, informedly and unambiguously, for example by ticking a box on the Website. On the basis of Consent, Triniti Processes Personal Data, for example if the Data Subject wishes to subscribe to the newsletter, such Consent is for an indefinite period and is valid until the Data Subject has withdrawn it.

5.3  Upon entry into and performance of an Agreement, Personal Data Processing may be additionally provided for in the specific Agreement, but Triniti may Process Personal Data for the following Purposes:

(1)  in order to take steps at the request of the Data Subject prior to entering into the Agreement;
(2)   to identify the Client to the extent required by due diligence;
(3)   to perform the obligations to the Client regarding the provision of its Services;
(4)   to communicate with the Client;
(5)   to ensure the performance of the payment obligation of the Client;
(6)   to submit, realise and defend claims.

An Agreement may be entered into on behalf of the Data Subject, or in the name of the Data Subject, by a legal entity.

When processing on the basis of the Agreement, depending of content of the Agreement we will retain Personal Data after the expiry of the Agreement for 3 years or until the deadlines specified in the law and the guidelines for keeping documents of Estonian Bar Association.

5.4   For the entry into an employment agreement, the Processing of the Personal Data of a job applicant by Triniti based on the entry into the agreement and legitimate interest shall include:

(1)   Processing of the data submitted by the job applicant to Triniti for the purpose of entering into an employment agreement;
(2)   Processing of the Personal Data received from the person indicated as the referee by the job applicant;
(3)   Processing of the Personal Data collected from state databases and registers and public (social) media.

In case a job applicant is not selected, Triniti shall store the Personal Data collected for the entry into an employment contract for two years in order to make a job offer to the job applicant in case a suitable position becomes vacant. When two years have passed after the submission of a job application, the Personal Data of the job applicant who was not selected shall be deleted.

5.5   Legitimate interest means the interest of Triniti in the management and direction of its business in order to be able to offer the best possible Services on the market. Triniti shall Process Personal Data on a legal basis only after careful consideration in order to ascertain the legitimate interest of Triniti, based on which the Personal Data Processing is necessary and is in compliance with the interests and rights of a Data Subject (after carrying out the so-called three-step test). In particular, Personal Data Processing may take place on the basis of a legitimate interest for the following purposes:

(1)   on the basis of the Bar Association Act § 41, according to which a sworn advocate is competent to process Personal Data obtained under a contract or law, including sensitive Personal Data of a person who is not the client without the consent of such persons, if this is necessary for the provision of legal services;
(2)   for ensuring a trust-based relationship with a client, for example Personal Data Processing that is strictly necessary to determine the ultimate beneficiaries or to prevent fraud;
(3)   for the administration and analysing the client base to improve the availability, selection and quality of Services and products, and to make the best and more personalised offers to the Client upon the Client’s consent;
(4)   for the identifiers and Personal Data collected upon the use of websites, mobile applications and other Services. Triniti shall use the collected data for web analysis or for the analysis of mobile and information society services, for ensuring and improving the functioning, for statistical purposes and for analysing the behaviour and using experience of Visitors and for providing better and more personalised Services;
(5)   for the organisation of campaigns, including organisation of personalised and targeted campaigns, carrying out Client and Visitor satisfaction surveys, and measuring the effectiveness of the performed marketing activities;
(6)   for analysing the behaviour of the Clients and Visitors on Websites;
(7)   for network, information and cyber security considerations, for example for fighting against piracy and for ensuring the security of the Websites, as well as for the measures taken for making and storing backup copies;
(8)   for corporate purposes, in particular for the financial management and for transferring Personal Data within the group for internal administrative purposes, including the Processing of the Clients’ or employees’ Personal Data. Such Processing of Personal Data takes place, in particular, with the exchange of data between offices in Triniti Estonia, Triniti Lithuania and Latvia;
(9)   for the establishment, exercise or defence of legal claims.

Generally, Triniti retaines data in accordance to deadlines set by law  and the deadlines specified in the guidance documents of the Estonian Bar Association, for example, we will keep court judgments for up to 30 years.

5.6  For performing a legal obligation, Triniti shall Process Personal Data to perform the obligations set forth by law or to exercise the uses permitted by law. Legal obligations derive, for example, from adhering to the rules of payment processing and prevention of money laundering.

5.7  In case Personal Data Processing is carried out for a new purpose, different from those for which the Personal Data were originally collected, or is not based on the consent given by the Data Subject, Triniti shall carefully assess the permissibility of such new Processing. The new purposes of processing are always thought through. In order to determine whether the Processing for the new purpose is in compliance with the purpose for which the Personal Data were originally collected, Triniti shall take into consideration, inter alia, the following:

(1)   any link between the purposes for which the Personal Data were collected and the intended further purposes Processing;
(2)   the context of collecting the Personal Data, in particular regarding the relationship between the Data Subject and Triniti;
(3)   the nature of the Personal Data, in particular whether any special categories of Personal Data, or Personal Data related to criminal convictions and offences are processed;
(4)   possible consequences of the intended further processing for the Data Subjects;
(5)   existence of appropriate protection measures.

6.1  Triniti cooperates with persons, to whom Triniti may transfer data regarding the Data Subjects, including their Personal Data, in the context and for the purposes of co-operation.

6.2  Such third persons may be courts, other law firms and public authorities (such as the Prosecutor’s Office); also advertising and marketing partners, companies carrying out client satisfaction surveys, debt collection agencies, credit registers, IT partners, persons, authorities and organisations intermediating or providing (electronic) mail services, provided that:

(1)   the respective purpose and the Processing are lawful;
(2)   the Personal Data Processing is carried out in accordance with the guidelines of Triniti and on the basis of a valid agreement.

6.3  Triniti’s maintains a list of the co-operation partners, but due to the obligation to professional secrecy, is not disclosed on this website.

6.4   Triniti shall transfer Personal Data to outside the European Union only if there is sufficient protection in the respective country; if protection measures have been agreed upon (e.g. binding internal rules of the group or standard data protection clauses); the Data Subject has given a clear and informed consent for such transfer; the transfer is clearly required by an agreement entered into with the Data Subject; the transfer is not repeated, it concerns only a limited number of Data Subjects; it is necessary for protecting the legitimate interests of Triniti  which are not overridden by the interests, rights or freedoms of the Data Subject, and if all the circumstances related to the transfer have been assessed and suitable protection measures  have been established to protect the Personal Data, or if there is some other legal basis therefor. Triniti shall inform the Data Protection Inspectorate of the transfer based on a legitimate interest.      

7.1  Triniti has established guidelines and procedural rules for ensuring the security of Personal Data by both organisational and technical measures. For the same purpose Triniti follows corresponding guidelines of Estonian Bar Association

7.2  In case of an incident related to Personal Data, Triniti shall take all necessary measures to mitigate the consequences and hedge any relevant risks in the future. Inter alia, Triniti shall register all the incidents and shall inform the Data Protection Inspectorate and the Data Subject directly (e.g. by email) or in public (e.g. via the news) in prescribed cases.

8.1  The Services of Triniti, including the information society services, are not targeting Children.

8.2  Triniti does not knowingly collect any information on persons under 13 years of age, i.e. Children, and in case of any respective informed activity we shall act on the basis of the requests of a parent or guardian (including consent to send products to the name of a Child).

8.3  In case Triniti finds out that it has still collected Personal Data from a Child or regarding a Child, Triniti shall use its best efforts to discontinue the Processing of the respective Personal Data.

9.1  Rights related to consent:

(1)   A Data Subject will always be entitled to inform Triniti about his or her wish to withdraw the consent for the Personal Data Processing.

(2)   You will be able to view, change and withdraw your consents given to Triniti on the User Account or by contacting Triniti. The contact details are set out in section 13 of this Privacy Policy.

9.2  Data Subject also has the following rights, but in view of the obligation to maintain professional secrecy, Triniti assesses at all times whether and how the Data Subject’s rights are exercised. In general, the data subject has the following rights:

(1)   Right to receive information i.e. the right of a Data Subject to receive information regarding the Personal Data collected about him or her.
(2)   Right of access to data which, inter alia, includes the right of a Data Subject to a copy of the Processed Personal Data.
(3)   Right to rectification of inaccurate Personal Data. A Data Subject will be able to correct inaccurate data by contacting triniti@triniti.ee.
(4)   Right to erasure of data i.e. in certain cases a Data Subject will be entitled to demand the deletion of Personal Data, for example if the Processing is carried out only on the basis of a consent.
(5)   Right to demand restriction of Personal Data Processing. This right is created, inter alia, in case the Personal Data Processing is not permitted under law or if the Data Subject challenges the accuracy of the Personal Data. A Data Subject will be entitled to demand the restriction of the Personal Data Processing for a period enabling the processor to check the accuracy of the Personal Data or if the Personal Data Processing is unlawful but the Data Subject does not request the deletion of the Personal Data.
(6)   Right to data portability i.e. a Data Subject shall have, in certain cases, the right to receive the Personal Data in a machine-readable format, and to take these data along or transfer them to another controller.
(7)   Rights related to automated Processing mean, inter alia, that a Data Subject will have the right to object, on grounds relating to his or her particular situation, at any time to Processing of Personal Data concerning him or her, based on automated decision-making. For the avoidance of doubt – Triniti AS may Process Personal Data for automated decision-making promoting its business (i.e. for segmentation of Visitors in marketing context, and for sending them personalised messages, in the context of commencement of an employment relationship, and in order to ensure that our employees shall adhere to our internal security regulations). Automated Processing may include also data collected from public sources. Triniti does not create individual profiles for Data Subjects as a result of the use of the Website. You have the right to avoid any decisions based on automated Personal Data Processing if they can be classified as profiling;
(8)   Right to the assessment of a supervisory authority on whether the Processing of the Personal Data of the Data Subject is lawful;
(9)   Compensation for damage, if the personal data processing has caused damage to the data subject.

10.1  Filing of complaints:

(1)   A Data Subject will be entitled to address Triniti using the contact details set out in section 13 in case of any question, request or complaint related to Personal Data Processing. A Data Subject will be entitled to address a complaint to Triniti and the Person responsible for data protection of Triniti, to the Data Protection Inspectorate or to a court if the Data Subject is of the opinion that his or her rights have been infringed in Personal Data Processing.
(2)   The contact details of the Data Protection Inspectorate are available on the website of the Data Protection Inspectorate: http://www.aki.ee/.

11.1  Triniti may collect data regarding the Visitors of the Websites and other information society services by using Cookies for this purpose (i.e. small pieces of information stored by the Visitor’s browser on the hard disk of the computer of any other device of the Visitor) or other similar technologies (e.g. IP address, equipment information, location information) and process these data.

11.2  Triniti uses the collected data to enable the provision of the Service in accordance with the habits of a Visitor or Client; to ensure the best Service quality; to inform the Visitor and Client about the contents and give recommendations; to update advertisements and make marketing efforts more efficient; and to facilitate logging in and protection of data. The collected data shall also be used for counting the Visitors and recording their using habits.

11.3  Triniti uses session Cookies, persistent Cookies and advertising Cookies. A session Cookie is deleted automatically after every visit; persistent Cookies shall remain upon repeated use of the Website, and advertising Cookies and third party Cookies are used by the Websites of the partners of Triniti which are connected with the Website of Triniti. Triniti does not control the generation of those Cookies, therefore information on these Cookies can be obtained from third persons. Further information on Cookies is available in the explanatory materials (see section 12: Important Guidelines and Procedures).

11.4  As to the Cookies, Visitors agree with the use of Cookies on the Website, in information society service devices or the web browser.

11.5  Most of the web browsers allow Cookies. Without fully allowing Cookies, the functions of the Website are not available to a Visitor. The allowing or prohibiting Cookies and other similar technologies shall be under the control of a Visitor via the settings of the Visitor’s own web browser, settings of the information society service and platforms for making such privacy more efficient (see section 12: Important Guidelines and Procedures).

12.1    Following guidelines are important while implementing Triniti’s Privacy Policy:

(1)   All About Cookies (in English): Descriptions of cookies and other web technologies used by Triniti;
(2)   Your Online Choices; About Ads; Network Advertising,   (in English): the platform of controlling and monitoring of cookies and other web technologies, where Data Subjects themselves can change and control how their Personal Data are used and collected.

13.1  Regarding Personal Data issues, Triniti can be contacted by e-mail triniti@triniti.ee and by phone +372 6 850 950.

14.1  Triniti will be entitled to unilaterally amend this Privacy Policy. Triniti shall inform Data Subjects about amendments on the website of Triniti, by e-mail or by other means.

14.2  The latest amendments and entry into force of the Privacy Policy: