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    FILTER GROUP Privacy Policy

    FILTER GROUP Privacy Policy

    Last Updated: 14.02.2024

    1. Introduction

    This Privacy Policy explains how FILTER Group companies (“we,” “us,” or “our”) collect, use, and share your personal data. We are committed to protecting your privacy and ensuring the security of your personal information.

    2. Definitions and Principles

    2.1 FILTER Group companies that are covered by this Privacy Policy are the following:

    • Filter AS,
    • Filter Solutions OÜ,
    • Filter SIA,
    • Filter UAB,
    • Filter OOD,
    • Filter Sp.Z o.o.

    2.2 The data controller for your personal data is FILTER AS, who may, if necessary, use authorized processors and share Data Subject information with third parties (e.g. FILTER GROUP companies or professional agencies with whom we have contracts).

    2.3 Data Subject/you is a natural person about whom we have information or information that can identify a natural person. We generally processes the data of the following Data Subjects: Customers (natural persons), representatives of Customers and cooperation partners who are natural persons, our employees, (potential) customers and Website Visitors.

    2.4 Customer is any natural or legal person who has purchased or expressed their desire to purchase our solutions, products and/or services.

    2.5 Contract means a contract of sale for solutions, products or another contract entered into between us and the Customer, incl. standard terms and conditions and other applicable procedures and policies.

    2.6 Website means our website https://filter.eu/ as well as our social media pages.

    2.7 Visitor means a person who visits the Website.

    2.8 The Privacy Policy is an integral part of the Contract entered into between us and the Customer.

    2.9 The Privacy Policy is applicable to Data Subjects, and all our employees and key cooperation partners who have access to the personal data in our possession are guided by the rights and obligations specified in the Privacy Policy.

    2.10 Our aim is responsible personal data processing where we are able to demonstrate the compliance of personal data processing with the purposes set and the applicable regulations.

    2.11 Our processes and activities related to personal data processing are based on the following principles: lawfulness, fairness, transparency, purposefulness, minimisation, accuracy, storage limitation, integrity, confidentiality, and data protection by default and by design.

    3. General purposes of data processing

    3.1 Our aim is to offer our Customers high-quality energy and water solutions, products, maintenance services and pleasant customer service.

    3.2 Based on consent, we process personal data precisely within the limits, to the extent and for the purposes for which the Data Subject has given us their consent. The Data Subject’s consent to us shall be freely given, specific, informed, and unambiguous. Consent may also be expressed by a clear act, for example, the Data Subject can, at their own discretion, send inquiries through the inquiry forms on our Website or book a consultation, in which case we process their data to respond to them and offer them our solutions, products and services. For example, we send also marketing messages based on consent.

    Personal data processed on the basis of consent will be stored until the need for processing ceases, but no longer than until the withdrawal of the consent that was the basis for the processing.

    3.3 Upon entering into and performing a Contract, we may process personal data for the following purposes:

    • identifying the Customer to the extent necessary for entering into and performing a Contract;
    • performing the obligations assumed to the Customer with regard to the provision of our solutions, products and services;
    • communicating with the Customer, incl. sending information and reminders about the performance of the Contract or about solutions, products or services.

    Personal data collected for the purpose described above is stored during the period of service provision and up to ten years after the end of service provision.

    3.4 We may process your personal data based on legitimate interest. Legitimate interest means our interest in managing or directing our company and enabling us to offer the best possible solutions, products and services on the market we operate, and our legitimate interest may be for the following purposes:

    • managing and analyzing a customer database and for marketing activities in order to improve the availability, selection and quality of solutions, products and services, incl. using a CRM solution to enable the foregoing, and making the best and most personal offers to the Data Subject upon their consent;
    • ensuring a better user experience, higher quality services, and operation of various channels; we may analyze identifiers and personal data collected when our Website, our social media pages and other sales channels and solutions or products are used, and we may collect statistics about Visitors and Customers;
    • organizing events and/or campaigns, incl. organizing personalized and targeted events and/or campaigns.
    • sending marketing offers to the Customer or potential customer if the respective person has previously purchased a similar product. In this case, the person is always guaranteed to have a simple opportunity to resign from the communication, and we have considered our and the Customer’s interests;
    • conducting satisfaction, incl. customer satisfaction, surveys;
    • measuring the effectiveness of marketing activities performed;
    • making recordings; we may record messages and orders given both in our premises and using means of communication (e-mail, phone, etc.) as well as information and other activities we have performed, inter alia, calls to landline numbers. If necessary, we use these recordings to prove orders or other activities;
    • network, information and cyber security reasons, for example measures for combating piracy and ensuring the security of the Website as well as for making and storing back-up copies;
    • processing for organizational purposes, foremost for financial management and transfer of personal data within the group for internal management purposes (but also audits and other potential supervision), including for processing the personal data of Customers or employees;
    • establishing, exercising or defending legal claims, incl. assigning claims to, for example, collection service providers, or obtaining information from institutions assessing creditworthiness;
    • protecting our health and property and the health and property of our employees and Customers, for example, we may use cameras that may also record sound to ensure safety and security on our territory.

    Personal data processed on the basis of legitimate interest is generally stored until the purpose of the processing activity is achieved or the legitimate interest ceases. In justified cases, we may retain a legitimate interest in processing personal data even after the original processing purpose has been achieved. If you require information on retention periods related to one or more specific data processing activities based on our legitimate interest, please contact us via the e-mail address filter@filter.eu.

    4. Information We Collect

    4.1 Personal data disclosed to us by the Data Subject. We collect and use data from standard communication between us and the Data Subject; and/or data submitted for the purpose of ordering and/or consumption of our solutions, products and services (data like name, contact details, e-mail address, product information); as well as when subscribing to our newsletter (e-mail).

    4.2 Traffic Analytics (Cookies) resulting from visiting and using the Website. We use cookies and similar tracking technologies to collect general traffic analytics about your use of our website (e.g. IP address, Pages visited, Location of access, Referring URL etc.). These analytics help us improve our website’s performance, user experience, and content. Our Website may contain third party Cookies regarding which our cooperation partners are the controllers.

    Specific information about the characteristics and storage periods of cookies is available on our website.

    5. Transfer and authorised processing of personal data

    5.1 We cooperate with persons to whom we may transmit data, including personal data, concerning the Data Subjects within the context and for the purpose of cooperation and on the basis of legitimate interest. When transferring personal data to third parties (e.g. our cooperation partners), we comply with the applicable data protection requirements.

    5.2 Such third parties may include persons in the same group as us, distributors of our Products, logistics companies, supply partners, factoring providers, advertising and marketing partners, payment service providers, customer satisfaction survey companies, debt collection service providers, advisers, credit registers, i.e. service providers for various technical services, provided that:

    • the respective purpose and processing are lawful;
    • personal data is processed pursuant to the instructions of the controller and on the basis of a valid contract.

    6. Your rights and choices

    6.1 You have the following data subject rights as specified in the General Data Protection Regulation:

    • The right to information and access

    You have the right to request information about whether and which personal data, on which legal basis and manner we process about you. You also have the right to request a copy of the personal data processed about you.

    • The right to request correction and erasure of personal data

    You have the right to request that we correct errors in the personal data we process about you (for example, if your personal data has changed). In certain cases, you also have the right to request that we erase the personal data processed about you. Please note that we may have the right to refuse the erasure of specific personal data, for example, if the continuation of processing is necessary to ensure possible claim rights or to fulfil legal obligations.

    • The right to restrict the processing of personal data

    In certain situations you have the right to request that we restrict the processing of your personal data. In such an event, we retain the right to process your personal data only to a limited extent, for example to ensure possible claim rights or to fulfil legal obligations.

    •  The right to object

    If the legal basis for the processing of your personal data is our legitimate interest, you have the right to object to the corresponding processing of personal data. You also have the right to object to any automated decision-making by us and the processing of personal data related to direct marketing.

    • The right to transfer personal data to another controller

    If we process your personal data on the basis of consent or an obligation arising from a contractual relationship between us, you have the right to demand that we provide you with your personal data in a structured, commonly used format and in machine-readable form. If technically feasible, you also have the right to request that we transfer personal data to another data controller indicated by you.

    • The right to withdraw consent at any time

    If the legal basis for the processing of your personal data is consent, you have the right to withdraw your consent at any time. Please note that withdrawal of consent does not affect the legality of prior data processing, that was based on valid consent.

    To exercise the rights described above, please contact us via the e-mail address filter@filter.eu. Cookies can be disabled in your browser settings, but please be aware that this may affect the functionality and user experience of our website.

    Please note that data subject rights are not absolute, and for each request we must assess whether and to what extent applicable data protection legislation allows us to satisfy your request.

    7. Data Security

    7.1 We take reasonable steps to protect your personal information from unauthorized access and disclosure. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee the absolute security of your data.

    7.2 We do the following to ensure security and confidentiality:

    • we provide our employees with access to personal data only where this is necessary for the performance of their duties and where the respective permission has been requested and rights have been granted;
    • a processor may process the personal data transferred to them only for the purpose and to the extent necessary for providing the services set out in the contract and on the basis of legitimate interest.

    7.3 In the event of any incident involving personal data, we do our best to mitigate the consequences and alleviate the relevant risks in the future.

    8. Changes to this Privacy Policy

    We may update this Privacy Policy from time to time to reflect changes in our practices or for legal and regulatory reasons. Any changes will be posted on this page with a revised “Last Updated” date.

    9. Contact Us

    If you have any questions or concerns about this Privacy Policy or the way we manage your personal information, please contact us at: filter@filter.eu.

    We generally respond to request regarding the processing of personal data within one month of receipt. However, considering the volume and complexity of the request, we may extend the response deadline by a further two months, informing you of the extension of the deadline and the reason for it within one month of receipt.

    If you do not agree with the answer you received, you have the right to file a complaint with the respective data protection authority in your country. Information about data protection authorities in the European Union is available here.