Principles of customer data processing
This document defines the processing of customer data at the disposal of Hertwill OÜ, its objectives, composition and confidentiality.

Who is the customer?
A person who has entered into a contractual relationship with Hertwill OÜ.

What is customer data?
Customer data is any information that Hertwill OÜ knows about its customer (e.g. customer's name, contact information, transaction data).

What is customer data processing?
Processing of customer data is any operation performed on customer data (including collecting, storing, organising, storing, modifying, disclosing, granting access to customer data, making, using, transmitting, cross-sharing, merging, closing, deleting and destroying customer data).

Who is a data controller?
The chief processor of customer data is Hertwill OÜ (reg. Code 16216305, Laulupeo pst 7-4, Tartu 51006, Estonia).The authorized processors of customer data are: - Parcel service providers in order to deliver the ordered goods to the customer;
- Advertising service providers, including social media service providers, to whom we provide only the information necessary to inform customers about new products and special offers and to analyse customer behaviour on our websites;
- Companies providing information technology support in order to ensure the operation and development of Hertwill OÜ websites and other IT solutions;
- Payment providers.

Hertwill OÜ may collect the following data:
- first and last name/company name;
- registry code of the company;
- residence / location;
- contact information;
- transaction data (customer purchases data);
- habits, preferences, and satisfaction data (e.g., activity usage, service and customer satisfaction data, and complaints)
- all previously unspecified customer data transmitted by the customer to Hertwill OÜ by means of communication (eg telephone and computer network) on its own initiative, incl. Hertwill OÜ has the right to store all orders given by the customer by means of communication.On the bases provided by law, Hertwill OÜ has the right to process customer data that is not mentioned in this document.

What are the purpose and legal basis of the processing of customer data?
Hertwill OÜ processes customer data in order to:
Fulfill our contract with the customer based on:
- when performing the contract or implementing pre-contractual measures at the request of the client;
- in fulfillment of a legal obligation;
- in the legitimate interest of Hertwill OÜ.

Provide ancillary services, conduct customer satisfaction surveys and market analysis, and generate statistics based on:
- with the consent of the client;- in the legitimate interest of Hertwill OÜ to improve the services and products of Hertwill OÜ;
- Improve the customer experience and develop new products and services.

Protect your violated or disputed rights (e.g., transferring data to court) based on:
- With the consent of the Client;
- when performing the contract or implementing pre-contractual measures at the request of the client;
- in fulfillment of a legal obligation;
- in the legitimate interest of Hertwill OÜ to prevent, restrict and investigate the misuse or illegal use of the services and products of Hertwill OÜ.

Comply with legal obligations (eg transmission of data to an investigative body) based on:
- during the performance of the contract or the implementation of pre-contractual measures at the request of the client;
- in fulfillment of a legal obligation;
- Hertwill OÜ’s legitimate interest in sound risk management and corporate governance.

In which cases does Hertwill OÜ publish customer data?
Customer data is confidential, will not be released and will not be accessible to third parties without the customer's prior consent, except in cases prescribed by law.

Who is Third Party?
A third party is a natural or legal person who is neither a customer nor a processor of customer data.

Where is customer data processed?
Customer data are generally processed within the European Union and the European Economic Area (EU / EEA), but in some cases, they are transmitted and processed in countries outside the EU / EEA.The transfer and processing of customer data outside the EU / EEA may take place provided that there is a legal basis, such as the fulfillment of a legal obligation or the consent of the customer, and that appropriate safeguards are in place.

The appropriate safeguard is:
- an existing agreement containing standard contract terms developed by the EU;
- there is an adequate level of data protection in the non-EU / EEA country where the recipient is located, as decided by the European Commission;
- the receiver is certified under the Privacy Shield (applicable to receivers in the United States).

Upon request, the customer will receive more detailed information on the transfer of customer data to countries outside the EU / EEA.

How does Hertwill OÜ use customer data when offering services?
Hertwill OÜ may send offers and surveys from Hertwill OÜ to Hertwill OÜ customers. Hertwill OÜ may process customer data to improve the user experience of digital services, for example, adapting service views to the device used and creating personal offers for the customer. Such marketing may be based on what services and how the customer uses them.

What are the client's rights?
The customer has the following rights in connection with the processing of customer data:- request the correction of your customer data if they are insufficient, incomplete or incorrect;
- object to the processing of your customer data if the use of the customer data is based on a legitimate interest, including profiling for direct marketing purposes (eg receiving marketing offers or participating in surveys);
- request the deletion of your customer data, for example, if they are processed with the customer's consent and if the customer has withdrawn the consent. Such a right shall not apply if the customer data to be deleted are also processed on other legal grounds, such as for the performance of a contract;
- restrict the processing of its customer data on the basis of applicable law, for example at a time when Hertwill OÜ is assessing whether the customer has the right to delete its data;
- to receive information on whether Hertwill OÜ processes its customer data and, if it does, to access the aforementioned data;
- receive self-submitted customer data that is processed on the basis of consent or for the performance of the contract, in writing or in a publicly available electronic format, and, if technically possible, transfer this data to another service provider (data transferability);
- withdraw its consent to the processing of customer data;
- submit complaints about the use of customer data to the Estonian Data Protection Inspectorate (website:, if the customer finds that his / her customer data processing infringes his rights and interests under the applicable law.

How do I change my customer information and request that it be stopped?
The customer has the right to get acquainted with his/her customer data via e-mail If the customer data has changed or is incorrect for any other reason, the customer must notify by e-mail hello@hertwill.comThe customer has the right to demand the termination of the processing of his/her data and/or the deletion of the collected data, if the respective right arises from the Personal Data Protection Act or other legislation.

If you want a more detailed explanation of the processing of your customer data, write to us at the e-mail address