1.- User Information

The information on the website is based on the policy of respect for the protection of the personal data of the client and the client in the area of ​​navigation of the website.

For the purposes of this Regulation, the personal data referred to in section 1 will be replaced by the following information: Final data on the data: the commercial relationship with the United States. These operations are performed on the basis of the following measures:

• Correction of commercial communications by email, fax, SMS, MMS, social networks and other electronic means, such as making commercial communications.

For the production of whey, the group of powders REDLATERAL OÜ. and relational with products and services, or with those of its collaborators or suppliers with whom it has reached a promotion agreement. On the other hand, there are several personal accesses.

• Process orders, requests of the type of requests that are made for use in the form of contact with the form of contact with provision.

• Send newsletter of the website. Data conservation criteria: For the purposes of personal data, the conservation of the interested party will only be due to the suspension of the data used in the application of the legal basis. Destinations of aid: No community aid has been granted. Rights of the interested parties:

• Right to withdraw consent at any time.

• Compatibility, rectification, deletion, data portability and data opposition, including the use of individual automation decisions. Contact details for the following: The debt is identified as an attorney and is clearly defined.

• Post Office: Pudisoo küla , Männimäe/1 – 74626 Harju maakond TALLINN, ESTONIA • Electronic Address: lopd@redlateral.com

2.- Information provided by us These menus have been issued on the web for 18 months. The Users, entering the data in the contact form, presenting the form of the letter of summons, which is not the subject of the request with the request, in the case of the inclusion of data voluntarily remaining fields. We guarantee that the personal data will be available and will be subject to the necessary modifications. This data is also available on the web for the first time under the auspices of User. In the absence of such provision, said information and service will be guaranteed in accordance with the requirements of this Regulation.

3. Personal data processing principles of REDLATERAL

REDLATERAL processes your personal data pursuant to the principles set out in this privacy policy.

3.1 Transparency

REDLATERAL processes your personal data in a fair and transparent manner, and only if we are permitted to process your personal data by legislation.

3.2 Purpose limitation

REDLATERAL collects your personal data for specified, explicit and legitimate purposes. We do not process your personal data in a way incompatible with these purposes. If your personal data is processed for a purpose other than the initial purpose of processing personal data, we shall rely on the legal basis arising from law (e.g. when processing the inquiries of courts and other judicial authorities, REDLATERAL does not process your personal data anymore for the purposes of grants, guarantees or for the provision of other services) or we will ask for your prior consent to process your personal data for a purpose other than the initial purpose of processing personal data.

3.3 Data minimisation

REDLATERAL is committed to ensuring that the personal data processed by REDLATERAL are adequate, relevant and limited to what is necessary for the purposes for which they are processed. We do not collect excessive data or data that is unnecessary for REDLATERAL. If a data subject forwards personal data to REDLATERAL that exceed the necessary extent, we shall take all reasonable measures to avoid the further processing of excessive personal data and to minimise the volume of processed personal data.

3.4 Accuracy

We aim to ensure that your personal data is accurate and up-to-date, if necessary. REDLATERAL will take every reasonable step to ensure that personal data that is inaccurate is erased or rectified without delay. If the personal data is inaccurate, REDLATERAL will allow you to rectify and/or delete the data. We do not correct and cannot allow the deletion of such personal data which we are committed to maintaining unchanged for compliance with a legal obligation (e.g. for the fulfilment of requirements arising from the Accounting Act).

3.5 Storage limitation

REDLATERAL will keep your personal data in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed and for compliance with legal requirements. REDLATERAL processes personal data for no longer than it is required under applicable legislation with binding contracts or binding legal obligations.

3.6 Integrity and confidentiality

REDLATERAL ensures the protection of your personal data and processes your personal data in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing. REDLATERAL makes every reasonable effort to avoid accidental loss, destruction or damage of data.REDLATERAL uses technical and organisational measures to increase security during the processing of personal data. To raise awareness and increase knowledge in REDLATERAL about the protection of personal data, privacy training is organised for the REDLATERAL personnel who process your personal data. In addition, the protection of personal data is ensured through the obligation of confidentiality applicable to the REDLATERAL personnel, arising from the nature of the provided services (e.g. banking secret).

Processing of special categories of personal data (sensitive data, such as data revealing racial or ethnical origin, political views, religion or philosophical beliefs) is not the core activity of REDLATERAL. REDLATERAL only processes such data, if there are legal grounds for this, for example, where we are committed or permitted to process this type of personal data by law. Also, if this is determined by the terms and conditions of a service. For example, we offer private individuals a housing loan guarantee, the special target group of which includes veterans of the Defence Forces and the Defence League who have participated in a foreign mission or have been injured during their service in Estonia (health-related data). In addition, REDLATERAL processes special categories of personal data when providing the home grant service to families with many children and when the data subjects forward such data to REDLATERAL during the provision of any other service by themselves.

3.7 Data protection by design and by default

When designing the services related to processing personal data, REDLATERAL takes account of the right to the protection of personal data and privacy of the data subject. In the processes concerning the processing of personal data and in developing these, REDLATERAL gives consideration to the state of the art and implements measures to minimise the risks that are presented by personal data processing pursuant to the state of the art as far as possible. In the processes relating to the processing of personal data, their protection shall be ensured based on the nature, extent, context and purposes of processing the personal data.

4. Purposes, categories and legal bases for the processing of personal data and storage of personal data in REDLATERAL

REDLATERAL processes all personal data, which during the communication with the data subject, have become known and have been disclosed to REDLATERAL. REDLATERAL only processes and stores the personal data within a determined period of time and after that the data will be deleted or destroyed. The personnel of REDLATERAL only has the right to process the personal data to the extent that is necessary for the performance of the assigned tasks and that are required for the achievement of the purpose of processing the personal data. REDLATERAL processes the personal data for the compliance of legal obligations arising from legislation (national law, regulations and EU legislation), for the performance of the concluded contracts and preparing the conclusion of a contract (e.g. for processing the submitted application) and in restricted cases, also on the basis of consent (to send the newsletter of REDLATERAL).

REDLATERAL mainly processes the personal data for offering loans, guarantees, venture and private capital investments, to enable grants and implement the Startup Estonia programme activities. In order to obtain guarantees and grants, the data subject is required to previously fill in the respective forms, the records contained in which are used for deciding on the guarantees and grants. The data disclosed by the data subject via the form are strictly limited to what is necessary for offering the respective service. For example, when awarding the home grant to families with many children, REDLATERAL processes the personal data of the applicants as well as of their children: name, personal identification code, e-mail address, residence and data concerning the income, custody and ownership.

The personal data is processed in a situation where it is necessary to assess whether the data subject is eligible for a guarantee or whether the additional collateral provided by the data subject to the enterprise loan is acceptable. REDLATERAL has signed cooperation agreements with many banks and issued authorisations for concluding the guarantee contracts. Based on this, it is the bank and not REDLATERAL who assesses the creditworthiness of the data subject pursuant to the submitted data, and also specifies the availability and amount of self-financing of the data subject, and calculates the guarantee amount. In the case of a positive loan decision and eligibility for the guarantee, the bank concludes the loan as well as the guarantee contract with the data subject.

REDLATERAL also processes the personal data in a situation where the data subject turns to REDLATERAL with specifying questions, requests or inquiries. if the respective communication is by e-mail, REDLATERAL may also additionally collect statistical data in connection with this communication, such as what service the questions are about and what kind of questions arise, etc. REDLATERAL wants to communicate to its customers and other people who are interested in receiving direct marketing messages, the relevant news about the services of REDLATERAL, invitations to the events organised by REDLATERAL and other information pertaining to REDLATERAL. If you have given your consent to receive newsletters and messages, REDLATERAL will also collect the statistics, e.g. whether you opened the letter, which links you pressed, which devices you used for this and what their technical characteristics are.

REDLATERAL uses cookies in the web environment, on its website http://www.redlateral.com, which enable one to improve the performance of the website and thereby provide a better browsing experience of the site. We also use cookies to monitor the user statistics of the website and the operations made on the site, however we do not follow the navigation of each customer on the website. The information obtained is used to improve user convenience and content of the site. More information about using cookies is available on our website.

We also process personal data, if the data subject applies for a job at REDLATERAL. REDLATERAL does not store the documents related to the application for more than one year as of the competition for the post. Based on the data subject’s consent we may also store the data of the candidate within the agreed period of time after the end of the recruitment process to make a further employment offer.

We only collect and process such personal data, the need for which we have clearly defined for ourselves in advance. For example, we collect, process and use the contact pertaining to a data subject in order to contact the data subject, if necessary.

5. Data subject’s rights

Respect for the rights of the data subject is important for REDLATERAL, and accordingly, particular consideration is given to it. On the request of the data subject, REDLATERAL may provide information about the specific data subject by electronic means, in writing or orally, considering that the identity of the data subject is clear and proven.

This means that if there are suspicions when handling your request, REDLATERAL may ask for further information from you to identify the data subject. We do this to be sure of the identity of the data subject and to ensure that we provide the right information to the right person.

If the purposes for which REDLATERAL processes the personal data do not need or no longer need the identification of the data subject, REDLATERAL shall not be obliged to store, collect or process additional information for the identification of the data subject.

5.1 Right of information about the extent and use of personal data

You have the right to access your personal data and get further information about what REDLATERAL processes concerning you. This enables you to be informed and check, if necessary, what kind of personal data is processed by REDLATERAL in relation to you and how. You may also contact REDLATERAL and ask for the purpose of processing your personal data, if the purpose is unclear for you or you have further questions for us. We try to answer your questions as soon as possible, however no later than within one month. For more complicated inquiries we may be required to extend the term of responding to the inquiries and requests of a data subject by another two months. In this case we will contact you to extend the term of responding and explain the reasons for the extension to you.

5.2 Copies

Upon your request, REDLATERAL will make a free copy of the documents pertaining to you, if this is necessary and justified. For any subsequent copies, REDLATERAL may charge a fee for making and forwarding the copies based on the actual cost – above all, if the requests of the data subject are of a recurring nature. If you submit the request by electronic means and unless you request otherwise, REDLATERAL will provide the information by electronic means. REDLATERAL may refuse to provide a copy or to disclose data in the copy, if this has a disproportionate effect on the rights and freedoms of other persons and less restrictive measures cannot be implemented.

5.3 The right to rectification

All data subjects, who notice that their personal data are not up-to-date, are inaccurate or need rectification, may turn to REDLATERAL for the rectification or correction of the data. You may also ask to supplement your incomplete personal data. REDLATERAL will ensure that in the event of justified and legitimate requests, the personal data will be corrected at the first opportunity.

5.4 The right to data portability

If justified in the relevant case and if it does not adversely affect the rights and freedoms of others, the data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, if the processing in question is based on consent or on a contract and the processing is carried out by automated means.

5.5 The right to erasure (right to be forgotten)

This right enables the data subject to demand the erasure of personal data concerning him or her, if the personal data are no longer necessary or suitable in relation to the purposes of their collection or processing. The right to erasure is not an absolute right and accordingly, your request to delete the personal data may not mean that all your personal data are deleted after the request is received. Sometimes, we have a legal obligation to store the data and, in this case, we might not be able to satisfy your request. The same may apply, if we may store the respective data for the establishment, exercise or defence of legal claims.

5.6 Right to the restriction of processing

In justified cases, REDLATERAL may restrict the processing of personal data upon your request for a period enabling one to verify the accuracy of the personal data or until you object to the accuracy of your personal data. The data subject has a right to demand restriction of processing, for example at the time when REDLATERAL assesses the application of the requirement to delete personal data.

5.7 Right to withdraw consent

Where processing is based on consent, you may turn to REDLATERAL at any time and withdraw your consent given for processing the personal data. The withdrawal of consent is without retro-active effect and shall not affect the lawfulness of the completed processing of personal data when the consent was valid.

5.8 Right to object

If you find that the processing of personal data by REDLATERAL infringes your right to the protection of personal data or other rights and freedoms, you shall have the right to object to processing of the personal data.

5.9 Right to lodge a complaint with a supervisory authority

All data subjects have a right to lodge a complaint with a national data protection supervisory authority, if the data subject finds that the processing of his or her personal data does not correspond to the provisions of data protection laws and general data protection rules. In Estonia, the national supervisory authority is the Estonian Data Protection Inspectorate.

6. Safeguards and notification

REDLATERAL keeps the personal data strictly confidential and protects the personal data from illegally falling into the hands of third persons by implementing efficient information IT security measures and organisational and technical measures.

Whenever a personal data breach occurs in REDLATERAL and this represents a likely threat to the rights and freedoms of the data subject, we shall report such breach to the Data Protection Inspectorate. We will implement additional measures to end the breach as soon as possible.

Where the breach is likely to result in a high risk to the rights and freedoms of the data subject, we shall communicate the breach to the data subject. The purpose of communication is to enable the data subjects themselves to implement preventive measures to mitigate the potential risks arising from the situation.

7. Implementing provision

Taking into account the potential changes in the legislation, data protection law and in the development of technology ensuring a high level of protection of personal data, REDLATERAL shall retain the right to make changes to this privacy policy. Accordingly, this privacy policy shall be regularly reviewed and, if necessary, possible amendments will be made to it.