Privacy policy

TKM Grupp AS privacy policy

The privacy policy of TKM Grupp AS establishes the principles, on the basis of which TKM Grupp AS and the subsidiaries thereof (hereinafter the Group) process the personal data of their customers. The privacy policy of the Group applies to all customers and users who are natural persons and who purchase the goods, products, and services offered by the companies included in the Group and visit the stores and websites of the companies of the Group. The companies of the Group use your personal data to serve you in the best possible way and for the proper performance of all obligations arising from contractual relationships and the law.

TKM Grupp AS

TKM Grupp AS is a group that mainly includes retail and wholesale companies, such as Kaubamaja AS, Selver AS, OÜ Kulinaaria, SIA Selver Latvia, AS TKM King, Viking Security AS, OÜ TKM Beauty, OÜ TKM Beauty Eesti, TKM Auto OÜ, KIA Auto AS, AS VIKING MOTORS, SIA Forum Auto, SIA Verte Auto, UAB KIA Auto, Tallinna Kaubamaja Kinnisvara AS, OÜ Tartu Kaubamaja Kinnisvara, SIA TKM Latvija, and UAB TKM Lietuva.

The contact details of the data controllers of the personal data of the customers of the Group’s companies are:

• TKM Grupp AS – address Kaubamaja 1 Tallinn 10143, e-mail dpo@kaubamaja.ee
• Kaubamaja AS – address Gonsiori 2 Tallinn 10143, e-mail kaubamaja@kaubamaja.ee
• Selver AS – address Pärnu mnt 238 Tallinn 11624, e-mail selver@selver.ee
• OÜ Kulinaaria – address Taevakivi tn 7b Tallinn 13619, e-mail info@kulinaariatoit.ee
• AS TKM King – address Betooni 14 Tallinn 11415, e-mail info@tkmking.ee
• Viking Security AS – address Pärnu mnt.186, Tallinn 11314, e-mail info@vikingsecurity.ee
• OÜ TKM Beauty Eesti – address Gonsiori 2 Tallinn 10143, e-mail ilu@ilu.ee
• OÜ TKM Beauty – address Gonsiori 2 Tallinn 10143, e-mail ilu@ilu.ee
• KIA Auto AS – address Ülemiste tee 2 Tallinn 11415, e-post dpo@kia.ee
• AS VIKING MOTORS – address Tammsaare tee 51 Tallinn 11316, e-mail viking@vikingmotors.ee
• SIA Forum Auto – address Karla Ulmana gatve 101 Marupe Marupes nov. LV-2167 Latvia, e-mail info@forumauto.lv
• UAB KIA Auto – address Perkūnkiemio 2 Vilnius 12126 Lithuania, e-mail info@kiavilnius.lt
• Tallinna Kaubamaja Kinnisvara Aktsiaselts – address Gonsiori 2 Tallinn 10143, e-mail kinnisvara@nginvest.ee
• osaühing Tartu Kaubamaja Kinnisvara – address Riia 1 Tartu 51013, e-mail kinnisvara@nginvest.ee

Any questions regarding the processing of personal data by the companies of the Group can be addressed to any of the contact details of the companies of the Group provided above or to the Data Protection Officer of the Group by e-mailing dpo@kaubamaja.ee.

The scope of the privacy policy

The privacy policy is applicable to all customers and users who are natural persons and who purchase the goods, products, and services provided by the companies of the Group or visit the stores and websites of the companies of the Group.

In addition to the privacy policy, special terms and conditions apply to the processing of personal data with respect to the online stores of Kaubamaja, Selver, Selveri Köök, and I.L.U., which are included in the Group, as well as to the Partnerprogramm, the common loyal customer programme of the stores of Selver, Kaubamaja, ABC King, SHU, I.L.U., and L´Occitane, which are included in the Group. The terms and conditions of processing personal data by the online store of Kaubamaja can be read here. The terms and conditions of processing personal data by the online store of Selver can be read here. The terms and conditions of processing personal data by the online store of Selveri Köök can be read here and the terms and conditions of processing personal data by the online store of I.L.U. can be read here. The terms and conditions of processing of the personal data collected for the Partnerprogramm can be read here.

Which personal data is collected by the companies of the Group?

The companies included in the Group may collect personal data in the extent required for the purposes of providing services in the best possible manner, including, but not limited to your name, personal identification code, e-mail address, postal address, telephone number, preferred language, direct marketing preferences, and technical information received from digital devices (e.g. cookies and other similar technology). The companies included in the Group may also process other required personal data within reason for the purposes required to ensure the best customer services for the purposes, to the extent, and in a manner of which you will be notified in advance.

The companies of the Group may refuse to transfer the goods or provide services if the provision of the service is not possible without processing of personal data.

How is personal data collected by the companies of the Group?

The companies of the Group collect your personal data with your consent in the beginning of and during your customer relationship when you purchase and use products and services from the companies of the Group. The companies of the Group only collect your personal data if such data is provided by you voluntarily.

For which purposes is personal data processed by the companies of the Group?

The companies of the Group process your personal data for the following purposes:

• administration of customer relationships and communication with the customer
• entry into and performance of the contract entered into with the customer
• responding to the customer’s inquiries
• development and analysis of customer relationships
• provision of products and services
• direct marketing
• legitimate interest
• solvency and creditworthiness (financial soundness)
• researching consumer habits
• administration and development of services
• using and complementation of the website
• organising competitions and surveys
• drawing up sales statistics
• protection of persons and property
• proceedings of legal claims
• fulfilling legal obligations.

How is your personal data protected by the companies of the Group?

The companies of the Group use modern, sufficient, technical, and organisational security measures in the collection, storage, and processing of your personal data, which protect the personal data saved in the customer databases and on the websites of the companies of the Group from unauthorised access, amendment, disclosure, or destruction. Only authorised persons can access, amend, and process the personal data.

Forwarding of your personal data

The companies of the Group may use third party service providers in processing your personal data that provide services required by the Group (such as software development, sending direct marketing messages, providers of payment and postal services etc.). Contracts are entered into for the protection of personal data and ensuring the confidentiality of the forwarded data with all third-party service providers whom personal data is forwarded to by the Group. The third-party service providers can be found on the websites of companies included in the Group as well as on the website of the Partnerprogramm in the list ‘Data processors’ or by contacting the respective company of the Group by using the contact details specified above. In addition to the above, the companies of the Group may forward personal data to supervision, investigation, and law enforcement agencies and other third parties in the cases provided for in legislation.

Period of processing your personal data

The companies of the Group may only process your personal data as long as this is required for fulfilling the customer relationship between the company of the Group and you or for fulfilling another similar relationship until your consent for processing of the personal data is withdrawn or for taxation and legal purposes for the duration of the periods provided for in the legislation.

Direct marketing and satisfaction surveys

The companies of the Group may use the personal data provided by you with your consent to send you information about deals, campaigns, and offers and to organise satisfaction surveys. If you would like to stop receiving direct marketing offers, you may withdraw your consent to processing of your personal data at any time by following the directions provided in a direct marketing message or by contacting directly the company of the Group, the direct marketing messages of which you would like to stop receiving.

Use of cookies

The websites of the companies of the Group use cookies. A cookie is a tiny text file, which is automatically saved by the browser in the device used by the user. Cookies are used to collect information about how the website is used by the user with an aim to provide a better user experience.

Websites use the following cookies:

• session cookies with an aim to enable the use of the website;
• permanent cookies with an aim to remember the customer’s preferences on the website;
• first and/or third party cookies with an aim to display appropriate advertising and offers to the customer;
• third party analytics cookies with an aim to optimise marketing communication.

The user may delete the cookies saved in the user’s device and/or block the saving of cookies by changing the respective settings of their browser. In the event of refusing to use cookies, the website may not function as planned and/or some functionality may not be available for the users.

In addition to the analytics cookies, websites also use pixels (pixel tags, web-beacons), which are used to monitor the use of the website. This does not include processing of personal data that would enable identifying the person.

Processing of non-personal data

Upon visiting the websites of the companies of the Group, the companies of the Group may collect non-personal data from you, such as the date and time of visiting the website, the information downloaded from the website, information about the name of your browser and your operation system, your internet service provider, and other similar information. This data is processed anonymously by the companies of the Group and the data is used for the purposes of improving the functionality of the website.

Video recordings

The stores and showrooms of the companies of the Group are equipped with video surveillance with an aim to protect persons and property. The data controller of the video recordings generated as a result of the video surveillance and the personal data processed on the video recordings is the member of the Group that owns the surveillance cameras.

All video recordings can only be accessed by the persons who are authorised to be acquainted with the video recordings based on their duties.

The video recordings are saved for up to 30 calendar days, except in cases a longer period is necessary for the ongoing proceedings regarding protection of persons and property or a longer period is provided for in the legislation.

Forwarding personal data to countries outside of the European Union or the European Economic Area

The companies of the Group may forward personal data to third countries (countries that are not among the countries of the European Union or the European Economic Area) only with a lawful reason. The companies of the Group may use international service providers or cooperation partners in processing personal data and, in that case, it is ensured by the companies of the Group that there is a lawful reason for forwarding the personal data and that the data is protected in compliance with the applicable legislation.

Profiling

The companies of the Group may use your personal data and statistical data of your purchases to perform profile analyses in order to better understand your expectations and to thereby offer you better goods and services. No decisions of legal significance concerning you are made by the companies of the Group as a result of such profiling.

Your rights in connection with the processing of your personal data

You may inquire about your personal data from the company included in the Group that you have submitted your personal data to at any time, to request amendment or transmit of the personal data, or request the deletion of your personal data.

Please submit any requests concerning processing of your personal data electronically to the Data Protection Officer of TKM Grupp AS by e-mailing dpo@kaubamaja.ee or to the company of the Group that you have provided your personal data to by using the contact details specified above. In order to ensure the security of processing your personal data, your application must be digitally signed.

The companies included in the Group may reject your request if your identity cannot be verified or if the personal data cannot be transmitted securely. The Group may refuse to satisfy your request for deletion of the personal data if the obligation to process the personal data arises from a valid contract, applicable law, or if it is required for the preparation, submission, or defence of legal claims in connection with the protection of persons or property.

Amendment of the privacy policy

The Group may amend or complement the privacy policy at any time. The valid version of the privacy policy is always available on the websites of the companies of the Group.

Submission of claims

If you find that a company of the Group is violating your rights in processing the personal data, you may always contact the respective company of the Group by using the contact details above, or the Data Protection Officer of TKM Grupp AS by e-mailing dpo@kaubamaja.ee, as well as the Data Protection Inspectorate (www.aki.ee) or a court.