Here you can find all the information regarding the data processing principles of Triniti.
The objective of Triniti is to be a reliable partner that will respect your rights in the processing of personal data,
and lead the way for the others on the market.
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.
1.3 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.
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;
|Here you find the principles that are always followed by Triniti while Processing your Personal Data.||3. PRINCIPLES
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;
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.
|Here you find information on how we collect Personal Data.||4. COMPOSITION OF PERSONAL DATA
4.1 Triniti collects, inter alia, the following types of Personal Data:
(1) the Personal Data disclosed to Triniti by the Data Subject;
|Here you find out for which purposes and under which bases we can Process your Personal Data.||5. COMPOSITION, PURPOSES AND BASES FOR PROCESSING OF PERSONAL DATA
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;
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;
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;
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;
|Here you find information on when we may transfer your Personal Data to our cooperation partners.||6. DISCLOSURE AND/OR TRANSFER OF CLIENT DATA TO THIRD PERSONS
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;
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.
|Here you find a description of how we will protect your Personal Data and where you can find information on the storage periods of Personal Data.||7. SECURITY OF PERSONAL DATA PROCESSING
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.
|The Services of Triniti are not targeting Children.||8. PROCESSING OF THE PERSONAL DATA OF CHILDREN
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.
|Your Personal Data belong to you, and here you find information on the rights you have in protecting your Personal Data.||9. RIGHTS OF DATA SUBJECTS
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.
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.
|Here you find information on how to receive explanations or how and to where a complaint should be filed.||10. EXERCISING OF RIGHTS AND FILING OF COMPLAINTS
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.
|Here you find information on the types of Cookies or other technologies we use and how you can control the use of such technologies.||11. COOKIES AND OTHER WEB TECHNOLOGIES
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).
11.5 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).
|Here we set out all the guidelines through which you can exercise your rights.||12. IMPORTANT GUIDELINES and PROCEDURES
(1) All About Cookies (in English): Descriptions of cookies and other web technologies used by Triniti;
|Here you find our contact details.||13. CONTACT DETAILS AND INFORMATION
13.1 Regarding Personal Data issues, Triniti can be contacted by e-mail email@example.com and by phone +372 6 850 950.