NOTIFICATION ON PROCESSING OF PERSONAL DATA

Data controller

Sorainen offices in Estonia, Latvia and Lithuania (Sorainen) shall be the joint controllers of personal data transferred by you, including data of prospective clients.

Data Protection Officer
E-mail: privacy@sorainen.com

Purpose and legal basis of data processing

Personal data of the Client if the Client is a natural person, prospective clients and other natural persons (representatives, employees, etc) will be processed by Sorainen for the following purposes and under the following legal grounds:

  • Lawful processing of data for the purposes of conclusion and compliance with this Agreement shall be based on the necessity and legal duty to fulfil the Agreement duly, fairly and efficiently or the necessity for Sorainen to exercise the rights arising out of this Agreement. Article 6(1)(b) and (c) of the Regulation
  • Legal basis of individual personal data processing operations may also be compliance with legal obligations to which Sorainen is subject (such as tax returns, avoidance of conflict of interests, the Client’s due diligence, sanction check in respect of the Client etc.). Article 6(1)(c) of the Regulation
  • Lawful use of direct marketing tools (such as newsletters, invitations, notices) shall be based on legitimate interests of Sorainen to develop its business. Article 6(1)(f) of the Regulation
  • Lawful preparation and analysis of statistics shall be based on legitimate interests of Sorainen to monitor and improve its business. Article 6(1)(f) of the Regulation

Categories of received and processed personal data

Sorainen can receive and process the following data:

  • name, surname, date of birth, personal identification number, VAT number, including copies of identity documents;
  • contact details (telephone, e-mail, address);
  • position held, employer, contact details of the employer;
  • details of authorisation (representation) including personal identification numbers and addresses of representatives, copies of documents;
  • correspondence with Sorainen;
  • data, provided in Forms for Anti-Money Laundering and International Sanctions purposes;
  • other data collected or configured during the term of this Agreement with Sorainen depending on the nature of legal services provided (document signing, inquiry submission, entries in registers, marital status, etc);
  • language;
  • indications of political vulnerability and persona non grata.

Data processed by Sorainen can be received or accessed by:

  • Sorainen representatives responsible for services provided to you, Sorainen staff providing services to these representatives;
  • Third parties providing services to Sorainen including marketing companies, IT service providers, providers of information system support services, providers of business intelligence and business planning services, audit firms and others to the extent necessary for the exercise of such functions;
  • State Tax Inspectorate;
  • banks;
  • other public authorities and entities to the extent necessary for the provision of services to you (exercise of legal claims);
  • other data processors engaged by Sorainen and persons related to fulfilment of this Agreement;
  • entities, assisting in exercise of Sorainen’s rights arising from the provisions of the Agreement (entities, providing debt collection and recovery services, consultants, courts, etc).

Data retention period

For the purposes of this Agreement and legal obligations, data shall be processed throughout the entire term of this Agreement and stored for the statute of limitations period.

Data shall be processed for the purposes of direct marketing until you exercise your right to object to such data processing and in any event no more than 2 years after your last interaction with Sorainen communications, ie opened the contents of the communications for review, regardless of whether or not they used the information provided in the communications.

For the preparation and analysis of statistics data shall be processed for 5 years from the moment it was collected.

Processing of Prospective Client Data

In some cases, we process limited personal data of individuals who contact us regarding our services or who we may reach out to during business development. This may include contact details and information shared during communications. Such processing is based on our legitimate interest in responding to inquiries and promoting our services, and the data is retained only for as long as necessary to fulfil these purposes, in accordance with applicable data protection laws.

Rights of data subject

You are entitled to ask Sorainen to give access to your personal data and rectify or erase them or restrict processing as well as, where applicable, enable to exercise the right to data portability and right to object. You can contact the Data Protection Officer of Sorainen for matters related to the exercise of your rights.