Privacy Policy

Last updated: January 1, 2024

BALTIC RESTAURANT SERVICES OÜ PRIVACY POLICY

In this privacy policy (“Privacy Policy”), we describe how Baltic Restaurant Services OÜ

(“Company”) processes the personal data of its employees, customers, or individuals

otherwise collaborating with the Company, and the measures we implement to protect personal data.

Personal data is processed in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679)

and other national and European privacy laws and regulations (collectively, “Data Protection Law”).

  1. SCOPE

This Privacy Policy applies to all personal data that we process as the data controller.

The Company processes, for example, the personal data of employees, temporary workers,

sole proprietors, job applicants, supplier contact persons, customers, guests, and other partners.

  1. PURPOSE

The purpose of this Privacy Policy is to explain what personal data we process and how and why

we do so. Additionally, this Privacy Policy describes our obligations and responsibilities regarding data protection.

This Privacy Policy does not provide an exhaustive account of our data protection activities;

specific rules and guidelines are established in various areas—such as security—

and we communicate these internally to a reasonable extent. DEFINITIONS

In this privacy policy, the following terms are used with the meanings specified below:

EEA – European Economic Area

GDPR – the EU General Data Protection Regulation (Regulation (EU) 2016/679),

which became applicable on 25 May 2018.

Personal data – any data and information relating to a natural person (an individual) that

allow that person to be identified. A person is identifiable if their identity can be determined

from the data within a reasonable scope and without disproportionate effort. Identification may be

based on, for example, a name, personal identification code, location data, an online identifier,

or a physical, physiological, genetic, mental, economic, cultural, or social characteristic,

or a combination of such characteristics.

Special categories of personal data – personal data revealing a person’s racial or ethnic origin,

political opinions, religious or philosophical beliefs, or trade union membership, as well as

genetic data, biometric data used for the unique identification of a person,

health data, or data concerning a natural person’s sex life and sexual orientation. Personal data breach – a security breach leading to the accidental or unlawful destruction, loss,

alteration, unauthorized disclosure of, or unauthorized access to, personal data transmitted, stored,

or otherwise processed.

Client – ​​a natural person to whom the company provides services and/or

offers goods in the course of its business activities.

Third party – a natural or legal person, public authority, agency, or body other than

the data subject, the controller, or the processor, and persons who may process personal data

under the direct authority of the controller or the processor.

Cooperation partner – a natural person who is a supplier to the company or an

employee/representative/contact person of a cooperation partner that is a legal entity.

Profiling – any form of automated processing of personal data consisting of the use of personal data

to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict

aspects concerning that natural person’s work performance,

economic situation, health, personal preferences, interests, reliability, behavior, location, or

movements. Processing – an operation or set of operations performed on personal data, such as collection,

documentation, organization, structuring, storage, adaptation and alteration, retrieval,

consultation, use, disclosure by transmission, dissemination or otherwise making available,

alignment or combination, restriction, erasure, or destruction. Processing may

take place manually or by using automated systems, such as IT systems.

Contractor – a natural person (i.e., not a company) with whom the company has concluded a contract for

services (service provision agreement); this also includes members of the company’s management bodies.

Controller – the person who decides why and how (i.e., for what purposes and by what means) personal data

are processed. Answering the following questions may help in identifying the controller:

  • Who decides which personal data are stored?
  • Who decides for what purposes personal data are used?
  • Who decides how personal data are processed?

If a person decides on the processing of personal data in their possession and is responsible for them,

then they are the controller.

Processor – a person who processes personal data on behalf of the controller. If personal data are

in a person’s possession or are being processed by them, but they do not have the authority to decide on the processing—i.e., they are processing

them in accordance with the instructions of the controller,