Direct Marketing and Personal Data Processing

Haapsalu Linna Spordibaasid OÜ (hereinafter HSB) processes the personal data provided by clients only for the purposes necessary for service provision and as obtained in the course of a contractual relationship.

HSB transmits personal data necessary for payment processing to an authorized processor – the Montonio payment platform.

Dispute Resolution

If a client has any complaints regarding the activities of HSB, they should be submitted via email to spordikeskus@hsb.ee or by calling +372 472 5060.

If the client and HSB are unable to resolve the dispute amicably, the client may contact the Consumer Disputes Committee.

Personal Data Processing Principles

The processing of personal data by HSB is based on the Personal Data Protection Act, applicable Estonian legislation, and HSB’s internal data processing principles.

Controller and Processor of Personal Data

HSB is the data controller, who forwards necessary personal data for payment processing to the authorized processor – Montonio.

General Information

These data processing principles define the conditions and procedures under which HSB processes client data.
By becoming a client of HSB, registering for training, or participating in training sessions, the client consents to the processing of their personal data in accordance with these principles.

HSB reserves the right to unilaterally update its data processing principles in accordance with applicable legislation. Clients will be notified of changes via the website.

Definitions

  • Client – any natural person who uses or has used HSB services
  • Personal data – any information obtained by HSB in connection with service provision
  • Client relationship – a legal relationship between the client and HSB
  • Data processing – any operation performed on personal data, including collection, storage, transmission, modification, etc.
  • Third party – a person who is neither HSB nor an authorized processor
  • Services – all services offered by HSB
  • Authorized processor – a party that processes personal data on behalf of HSB

Core Principles

  • Personal data is collected only for defined and legitimate purposes
  • All data processing is carried out on a lawful basis
  • Legal, physical, and technical safeguards are applied to protect data
  • Access to personal data is restricted to HSB employees whose job duties require it

Types of Data Processed

HSB processes only the data necessary to provide its services, including:

  • Name and contact details (email, phone)
  • Information related to transactions and corresponding rights/obligations
  • Data required by law (e.g., tax records)

Purposes of Data Processing

Personal data may be processed for the following purposes:

  • Customer service and communication
  • Service delivery and development
  • Creating customer segments
  • Market and satisfaction surveys
  • Contract fulfillment and legal protection
  • Tailored offers for clients
  • Organizing promotional campaigns and sweepstakes
  • Statistical and financial analysis

Data Disclosure to Third Parties

Personal data may be disclosed to:

  • Payment and IT service providers
  • Partners (e.g., customer card producers)
  • Law enforcement agencies where required by law
  • Companies within the HSB group for the purpose of customer service

Marketing and Direct Communication

Personal data may also be used for direct marketing and behavioral analysis.
Direct marketing offers may be based on automated profiling.

The client can opt out of receiving marketing messages at any time by sending a request to spordikeskus@hsb.ee.
General information (e.g., price list updates, payment reminders) is not considered marketing material.

Data Retention and Deletion

Personal data is retained only as long as necessary under applicable laws or contracts.
Security cameras may record activity on the premises for safety reasons.
Recordings may be used to protect rights or in legal proceedings.

A client may request the deletion of their data, if permitted by law. If the client has outstanding debts to HSB, deletion may be restricted.

Client Rights

Clients have the right to:

  • Access their data – including details on processing purposes and recipients
  • Request correction of inaccurate or incomplete data
  • Request deletion of data based on legal grounds
  • Restrict processing temporarily (e.g., during a dispute)
  • Object to processing based on HSB's legitimate interest
  • Transfer data to another service provider, where technically feasible

Protecting Client Rights

If a client believes that HSB has violated their rights, they may contact:

  • HSB via email: spordikeskus@hsb.ee
  • The Estonian Data Protection Inspectorate
  • A competent court