Privacy Policy
This Privacy Policy applies for personal data processing activities carried out by MTÜ Solid World DAO (registered in Estonia under the registry code 80612616 and with its seat at Pärnu mnt 15, 10141 Tallinn, Republic of Estonia; hereinafter Solid World, us or we). In respect of the personal data processing activities outlined in this Privacy Policy, the data controller is Solid World.

1. Introduction

We are strongly committed to protecting personal data. This Privacy Policy describes why and how we collect and process personal data and provides information about individuals’ rights. We may use personal data provided to us for any of the purposes described in this Privacy Policy or as otherwise stated at the point of collection.

Personal data is any information relating to an identified or identifiable natural person. Solid World processes personal data for numerous purposes, and the means of collection, lawful basis of processing and retention periods for each purpose may differ.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

2. Legal basis for processing your personal datar

Legal bases for each processing activity are specified in the relevant sections below.

When we process personal information for our legitimate interests, we make sure to consider and balance any potential impact on a data subject (both positive and negative), and the data subject’s rights under data protection laws. Our legitimate business interests do not automatically override interests of the data subjects - we will not process personal data for activities where our interests are overridden by the impact on the data subject (unless we have the consent or are otherwise required or permitted to by law).

3. Our data processing activities

You are a contractor that offers or provides services to Solid World or a representative of a contractor that offers or provides services to Solid World (service providers and representatives of service providers)In the meaning of this Privacy Policy, ‘service providers’ refers to physical or legal persons who have made an offer to provide services to Solid World and/or provide services to Solid World. ‘Representatives of service providers’ are the legal representatives, the contact persons and employees of the service provider, who are involved in the provision of the services or are otherwise related to the service agreement.

We process the following personal data related to service providers and representatives of service providers, which we have received from yourself or from the service provider:
  • personal details (name, date of birth or personal ID code or passport number);
  • copy of a passport or other ID;
  • contact details (address, email, telephone number);
  • data related to qualifications (for example, information about the acquired education and/or professional qualifications);
  • data about employment history (for example, previous employers, previous positions, the number of years of previous professional experience);
  • payment details (for example, bank account number, tax details);
  • other data which you have decided to communicate to us in your CV, recommendation letter or otherwise.
We process your personal data for the following purposes:
  • to verify you and the personal data you have submitted to us (on the basis of your passport or other ID);
  • to contact the service provider;
  • to assess the competence of the service provider in order to decide with whom we should conclude service agreements with;
  • to conclude contracts;
  • to exercise the rights and fulfil obligations arising from the contract with the service provider.
The legal basis for such processing is the necessity to takes steps prior to entering into a contract and/or to perform the contract. If you are a representative of a service provider, the legal basis for processing your personal data is our legitimate interest to receive services from the service provider and to administer the relationship. We believe that as you are professionally connected to the service provider, in such circumstances our business interest overrides your interests and fundamental rights and freedoms.

We retain your personal data until it is necessary depending on the purposes for which we collected the data. We may retain your personal data longer, if it is necessary for the protection of our interests or the fulfilment of our obligations deriving from the law. For instance, we store personal data necessary for the fulfilment of our accounting obligations for at least 7 years from the end of the relevant financial year, and the data necessary for filing claims or defending ourselves against claims for 1o years after the end of the contract.

3.2 You are a representative of our corporate client

We process the following personal data related to representatives of corporate clients, which we have received from yourself or from the corporate client:
  • personal details (name, date of birth or personal ID code or passport number);
  • copy of a passport or other ID;
  • contact details (address, email, telephone number);
  • data related to qualifications (for example, information about the acquired education and/or professional qualifications);
  • data about employment history (for example, previous employers, previous positions, the number of years of previous professional experience);
  • payment details (for example, bank account number, tax details).
We process your personal data for the following purposes:
  • to verify you and the personal data you have submitted to us (on the basis of your passport or other ID);
  • to contact the corporate client;
  • to assess the competence of the service provider in order to decide with whom we should conclude service agreements with;
  • to conclude contracts;
  • to exercise the rights and fulfil obligations arising from the contract with the corporate client;
  • to develop our businesses and services (such as identifying client needs and improvements in service delivery;
  • to comply with any requirement of law or regulation. As with any provider of professional services, we are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.
The legal basis for such processing is the necessity to takes steps prior to entering into a contract and/or to perform the contract. If you are a representative of a corporate client, the legal basis for processing your personal data is our legitimate interest to provide services to the client and to administer the relationship. We believe that as you are professionally connected to the corporate client, in such circumstances our business interest overrides your interests and fundamental rights and freedoms.

We retain your personal data until it is necessary depending on the purposes for which we collected the data. We may retain your personal data longer, if it is necessary for the protection of our interests or the fulfilment of our obligations deriving from the law. For instance, we store personal data necessary for the fulfilment of our accounting obligations for at least 7 years from the end of the relevant financial year, and the data necessary for filing claims or defending ourselves against claims for 1o years after the end of the contract.

3.3 You are a job applicant

In the meaning of this Privacy Notice, ‘job applicants’ include all people who have expressed their wish to be employed by Solid World and made their personal data available for Solid World to assess their suitability for working for Solid World.

We process the following personal data related to job applicants, which we have received from yourself:
  • personal details (name, date of birth, nationality/citizenship);
  • contact details (address, email address, telephone number); data
  • related to qualifications (for example, information about the
  • acquired education and/or professional qualifications); data about
  • employment history (for example, previous employers, previous
  • positions, the number of years of previous professional
  • experience); data collected through qualification and knowledge
  • tests; other data which you have decided to communicate to us in
  • your CV, motivation letter, at the interview or otherwise.
We may also collect your personal data from your recommenders (for example, your previous employers), if you have consented to that. By giving us the name and the contact details of your recommender, we assume that you have given your consent to contact them.

We process your personal data for the following purposes and on the following legal bases:
  • to find the most suitable candidates for us and to decide with whom to conclude employment contract with;
  • if necessary, for filing claims and for defending ourselves against claims.
The legal basis for such processing is either your consent that you give us by applying to a respective position or our legitimate interest to find the best candidate for a vacant position or to protect our rights. Where the legal basis for processing is our legitimate interest, we have concluded that our legitimate interest overrides your interests and fundamental rights and freedoms in a given situation.

If we choose someone other than you to fill the vacant job position, we retain your personal data up to 1 year from making the recruitment decision. We may retain your personal data longer, if it is necessary for the protection of our interests or the fulfilment of our legal obligations. If we conclude an employment contract with you, subsequent processing of your personal data by us will be carried out in accordance with separate processing rules that will be presented to you before signing of the contract.3.4 You are applying to be a member of Solid World (membership applicants) In the meaning of this Privacy Policy, ‘membership applicants’ include all natural persons who themselves have applied for membership to Solid World or are representatives of such applicants.

We process the following personal data, which we have received from yourself or from the applicant that is a legal entity:
  • personal details (name, surname, date of birth);
  • contact details (address, email address, telephone number);
  • data retrievable from the CV (for example, information about the acquired education and/or professional qualifications, previous employers, previous positions, the number of years of previous professional experience);
  • description of previous activities relating to Solid World’s activities;
  • motivation letter;
  • copy of an ID document.
We process your personal data for the following purposes and on the following legal bases:
  • to identify you or the organisation you are representing or related to;
  • assess whether you or the organisation you are related to, fulfil the requirements we have stipulated for Solid World membership.
The legal basis for such processing is either your consent that you give by applying or our legitimate interest to find members that share our goals and suit our organisation or to protect our rights. Where the legal basis for processing is our legitimate interest, we have concluded that our legitimate interest overrides your interests and fundamental rights and freedoms in a given situation.

If we decide not to grant you the membership, we will delete your application data after 1 year from making the decision. If we accept you as a member, subsequent processing of your personal data by us will be carried out in accordance with clause 3.5 (You are a member of Solid World) of this Privacy Policy.3.5 You are a member of Solid World‘Members of Solid World’ are the natural persons who are themselves members or related to the legal entities that are members of our non-profit association within the meaning of our articles of association.
We process the following personal data, which we have received from yourself or from the applicant that is a legal entity:
  • all the personal data that you have submitted to us during the membership application process (see above);
  • information on your activities as a member of Solid World (for example, your candidacy and activities in our organs, participation in events, etc.);
  • your participation, statements and voting during general assembly;
  • other relevant data about your membership that you yourself have submitted to us or we have gathered ourselves.
We process your personal data for the following purposes and on the following legal bases:
  • for administrative and archiving purposes;
  • to exercise our obligations under our articles of association;
  • to fulfil our legal obligations;
  • to identify you or the organisation you are related to.
The legal basis for such processing is usually performance of contract, our legitimate interest or our legal obligation. Within the meaning of GDPR we perceive our articles of association to be a contract between you and Solid World.

We retain your personal data until it is necessary depending on the purposes for which we collected the data. Some of your data we will retain for as long as you are a member of Solid World and at least 10 years after you have left our organisation
This section describes how Solid World handles personal information collected through the sites at https://www.solid.world/ and any other Solid World sites that link to this Privacy Policy (collectively, Sites).By using the Sites and providing personal information to us, you acknowledge you have read this Privacy Policy, and, to the extent your consent is necessary and valid under applicable law, you consent to the collection, use and disclosure of such personal information by us and any third party recipients in accordance with this Privacy Policy.
Third Party Links
The Sites may link to third-party sites not controlled by Solid World and which do not operate under our privacy practices. When you link to third-party sites, our privacy practices no longer apply. We encourage you to review each third-party site’s privacy policy before disclosing any personally identifiable information.Collection of personal information through the Sites
When you use our Sites, we collect information about you and your use of the relevant site, including through cookies and analytics tools. We may collect personal information about you, such as your name, job title, company name, address, email address and telephone number, either directly from you or by combining information we collect via the Sites with personal information we collect and maintain through other channels (such as client relationship management systems or identification and access management systems, including IP addresses) or as we may lawfully collect from social media or other third-party sites.
Below are examples of how you may provide personal information to us via Sites:
  • searching and browsing for content;
  • subscribing to or ordering newsletters and/or publications;
  • participating in join our mailing list initiatives;
  • participating in bulletin boards, discussion or message forums;
  • registering for events and conferences;
  • submitting resumes or work history information;
  • contacting us for further information;
  • visiting our Sites while logged into a social media platform; and/or
  • providing us with business cards or other contact information.
We do not intend to collect sensitive information through the Sites unless we are legally required to do so. Examples of sensitive information include race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and criminal records. We ask that you do not provide sensitive information of this nature when using the Sites. If you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent, where such consent is necessary and valid under your local law, for us to collect and use that information in the ways described in this section of this Privacy Policy or as described at the point where you choose to disclose this information.
We also do not actively seek demographic information from visitors to the Sites. However, you may choose to provide such information (including for example when visiting our Site from a social media site, submitting a resume, or responding to an online job application). If you choose to provide demographic information to us, the act of doing so constitutes your explicit consent, where such consent is necessary and valid under applicable law, for us to collect and use that information in the ways described in this section of the Privacy Policy or as described at the point where you choose to disclose this information.
It is our policy to collect only minimum personal information required. If the Sites seek non-mandatory personal information about you, you will be notified of this at the point of collection. If you believe a Site has collected excessive information about you, please contact us to raise any concerns.
Some pages on the Sites may permit you to send emails to us. Messages sent via the Sites will contain your screen name and email address.
Use of personal information
When you provide personal information to us through Sites, we may use it for any of the purposes described in this section of the Privacy Policy or as stated at the point of collection (or as obvious from the context of collection), including:
  • to administer and manage the Sites, including to confirm and authenticate your identity and prevent unauthorised access to restricted areas of the Site;
  • to personalise and enrich your browsing experience by displaying content that is more likely to be relevant and of interest to you;
  • to sort and analyse user data (such as determining how many users from the same organisation have subscribed to or are using the Sites);
  • to determine the company, organisation, institution, or agency that you work for or with which you are otherwise associated;
  • to develop our businesses and services;
  • to conduct benchmarking and data analysis including, for example, regarding usage of the Sites and demographics analyses of their users;
  • to conduct quality and risk management reviews;
  • to understand how people use the features and functions of our Sites in order to improve the user experience;
  • to monitor and enforce compliance with applicable terms of use, including acceptable use policies; and/or
  • any other purposes for which you provided the information to Solid World, including any of the purposes given in the ‘Collection of personal information’ section above.
  • Our Sites do not collect or compile personal information for sale to non-Solid World parties for consumer marketing purposes.
    If you would like to find out more about the different categories of information we collect on the Sites, please review the ‘Collection of personal information’ section above.
    Cookies and BeaconsPlease see our Cookie Policy.
    Data retentionn
    We will retain your personal information on our systems only for as long as we need it, given the purposes for which it was collected, or as required to do so by law. We keep mailing list information until a user unsubscribes from our mailing lists. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may honor your request.
    Marketingn
    Where we are legally required to obtain your explicit consent to provide you with marketing materials, we will only provide you with such marketing materials if you have provided consent for us to do so.
    If you opt into any subscriptions, you will receive automated emails when content is updated. If you opt into any newsletters, you will receive curated emails known as newsletters. If you select any preferences such as issues, topics, subjects or industries, you may receive email communications related to those self-selected topics.
    Disclosure of personal information
    Unsubscribe
    If you want to unsubscribe from mailing lists or any registrations, you should look for and follow the instructions we have provided within the appropriate area(s) of the Sites or in the relevant communications to you.
    If you do not wish to receive emails or marketing communications from us, you can at any time contact us to request that such communications cease. If you wish to unsubscribe or no longer receive only certain communications, please identify such communications in your request.
    If you choose to unsubscribe from any or all mailings, we may retain information sufficient to identify you so that we can honour your request.
    Access to data
    We are committed to providing reasonable and practical access that allows visitors to the Sites to identify and correct any inaccuracies in the information we collect about them.
    When we keep personal information about you, we are responsible for keeping an accurate record of the information that you have submitted to us. We do not assume responsibility for verifying the ongoing accuracy of your personal information.
    If you have questions about the accuracy of identifying information you previously submitted to Solid World, or want to have outdated information removed, please contact us. When requested, and provided that it is practical and commercially feasible to comply with the request and there is no legal or regulatory need for us to keep the information, we will delete identifying information from current operational systems.

4. When and how we share personal data and locations of processing

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
Personal data held by us may be transferred to:
4.1 Data Processors
In the meaning of this Privacy Policy, ‘data processors’ are our service providers who process your personal data in Solid World’s name. Solid World remains responsible for the processing activities carried out by our data processors.
We use in our activities the following categories of service providers who may get access to your personal data (data processors):
  • e-mail service providers;
  • IT management and storage providers;
  • consultants, service providers and other advisors.
We only use data processors who provide sufficient guarantees that they apply appropriate technical and organizational measures in order to ensure the protection of your personal data. We have concluded appropriate data processing agreements with the service providers and shall remain responsible for their actions in respect of the processing of your personal data.
Should you require more detailed information as regards the data processors we use (for example, their names and location) please contact us on the contact details below.
4.2 Third partiesWe may also transmit your personal data to the following third parties who act as independent controllers with regard to your personal data:
  • upon request, to our contractors, in which case the legal basis for transmission is either the performance of our contract or our legitimate interest to the extent which in our assessment overrides your interests and fundamental rights and freedoms depending on our relationship;
  • to third parties who protect our legal rights (for example, our legal consultants), in which case the legal basis for the transmission of personal data is our legitimate interest to the extent which in our assessment overrides your interests and fundamental rights and freedoms;
  • to third parties who provide us with audit services to verify our accounts, in which case the legal basis for transmission is either the performance of our contract or our legitimate interest to the extent which in our assessment overrides your interests and fundamental rights and freedoms depending on our relationship;
  • to third parties to whom we are obligated to transmit personal data in accordance with law or other legal acts (for example, supervisory authorities), in which case the legal basis for transmission is the fulfilment of our obligations arising from law.
We only share your personal data with third parties if stipulated in this Privacy Policy, if required under the applicable law (for example, when we are obligated to share personal data with the authorities) or under your consent.
4.3 Transmission of personal data outside the European Economic Area
In respect of personal data being regulated by EU legislation please note that: cross border transfers may include countries outside the European Economic Area (EEA) and countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EEA are done lawfully. Where we transfer personal data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EEA, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here.

5.1 Security

We take the security of all the data we hold very seriously. We adhere to internationally recognised security standards. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
You have certain rights in relation to the personal information we hold about you. In particular, you have a legal right to:
  • obtain confirmation as to whether we process personal data about you, receive a copy of your personal data and obtain certain other information about how and why we process your personal data;
  • request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your address) and to have incomplete personal data completed;
  • delete your personal data in the following cases:
    • the personal data is no longer necessary in relation to the purposes for which they were collected and processed;
    • our legal ground for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
    • our legal ground for processing is that the processing is necessary for legitimate interests pursued by us or a third party, you object to the processing and we do not have overriding legitimate grounds;
    • you object to processing for direct marketing purposes;
    • your personal data has been unlawfully processed; or
    • your personal data must be erased to comply with a legal obligation to which we are subject.
  • restrict personal data processing in the following cases:
    • for a period enabling us to verify the accuracy of personal data where you contested the accuracy of the personal data;
    • your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
    • your personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data is required by you to establish, exercise or defend legal claims; or
    • for a period enabling us to verify whether the legitimate grounds relied on by us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.
  • object to the processing of your personal data in the following cases:
    • our legal ground for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or
    • our processing is for direct marketing purposes.
  • data portability
    • The right to receive your personal data provided by you to us and the right to send the data to another organisation (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.
  • withdraw consent
    • Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis).
  • submit a complaint or request to us in relation to the processing of your personal data and, absent a satisfactory resolution of the matter, file a complaint in relation to the processing of your personal data with the Estonian Data Protection Inspectorate (www.aki.ee; [email protected]).

Changes to this Privacy Policy

We recognise that transparency is an ongoing responsibility so we will keep this Privacy Policy under regular review. We may update this Privacy Policy at any time by publishing an updated version in our website. The new modified or amended Privacy Policy will apply from that revision date. Therefore, we encourage you to review this Privacy Policy periodically to be informed about how we are protecting your information.

8 Applicable law

Solid World is a non-profit association registered in the Republic of Estonia and the processing of your personal data is therefore subject to the laws of the Republic of Estonia.