MANIMAMA OÜ processes Personal Data about you as a Client, Opponent, Representative of an Opponent, and so on as part of our client and case management in conjunction with our law firm's business operations, when you visit our Website https://manimama.eu/, subscribe to our Telegram Channel, and so forth.
CONTACT INFORMATION The data controller is MANIMAMA OÜ, a company incorporated under the laws of Estonia under registered number 14803352. If you have any questions about MANIMAMA’s processing of your Personal Data or you wish to exercise your rights, you are always welcome to contact us:
Legal and business address: Harju maakond, Tallinn, Kesklinna linnaosa, Pärnu mnt 158/2-88, 11317, Estonia;
If you are dissatisfied, you have the right to lodge a complaint with the supervisory authority for data protection issues - Estonian Data Protection Inspectorate (AKI), Tatari 39, Tallinn, 10134, Estonia, (e-mail: email@example.com/phone: 627 4135) or a claim to court. We would, however, appreciate the chance to deal with your concerns before you approach the AKI so please contact us in the first instance.
1. CATEGORIES OF PERSONAL DATA, PURPOSE AND LEGAL BASIS OF PROCESSING 1.1. We collect Personal Data from you when you become our Client, respond to a survey or marketing communication, fill out a form on our Website, or in any other circumstance listed in Table #1. 1.2. The types of Personal Data we collect are divided into categories and subcategories. The categories (purposes and legal basis) are following: 1.2.1. Money laundering. In cases where MANIMAMA provides assistance in advising on or performing transactions or opening a Clients’ account on behalf of a Client, there are a number of requirements in the anti-money laundering legislation that MANIMAMA must meet. In order to meet these requirements for the prevention of money laundering and financing of terrorism, we process Personal Data about you:
national identification number;
copy of ID (e.g. passport, driver’s license, or the like);
photo/video with ID;
company registered number;
owner and control structure;
beneficial owners, alternatively the day-to-day management (must be authenticated by identity information).
The legal basis for the processing is Article 6(1)(c) of the GDPR, according to which Personal Data can be processed when necessary for compliance with a legal obligation. 1.2.2. Case management. In connection with case management, MANIMAMA processes various categories of Personal Data. The type of Personal Data processed depends on the nature and context of the case. Case management subcategories of Personal Data are listed in Table #1 below. Please note that in some cases we will not collect all Personal Data types included in the section “Personal Data”, but only those ones which are applicable in every unique case:
1.2.3. Business operations. In connection with MANIMAMA’s business operations as a law firm, we process Personal Data concerning our suppliers and business partners. The Personal Data we process may include: - name; - place of work and contact information; as well as - information about the relationship and correspondence. The legal basis is MANIMAMA’s legitimate interests in managing and practicing law (Article 6(1)(f) of the GDPR). In some cases, the legal basis is Article 6(1)(b) of the GDPR, according to which processing is necessary for the performance of a contract to which the data subject is a party. 1.3. Please note that you must provide complete, accurate and correct details and you hereby confirm the details you provided are correct. We may refuse to enter into an agreement with you if you do not provide us with the requested data that is necessary for each activity. If you provide false, incorrect, or outdated information or only partial information, it may impair our ability to contact you.
3. PERSONAL DATA RETENTION 3.1. MANIMAMA keeps Personal Data for as long as it is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). 3.2. In connection with client management, case management and legal advice, MANIMAMA generally stores your information for five years from the end of the year in which the case was closed unless otherwise required according to legislation or in case of original documents. 3.3. If no case has been created and we have registered information about you only in connection with creating a possible relationship, we will store your information for up to six months after ending the correspondence. 3.4. Information for money laundering control purposes, etc. is stored for five years after the case is closed pursuant to the money laundering legislation. 3.5. Information about you as a supplier or cooperating partner is stored for up to five years after the end of the year during which the delivery took place or the cooperation was terminated. 3.6. We will erase your Personal Data without undue delay where one of the following grounds applies: 3.6.1. the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; 3.6.2. you withdraw consent on which the processing is based and where there is no other legal ground for the processing; 3.6.3. you object to the processing and there are no overriding legitimate grounds for the processing (for example where Personal Data are processed for direct marketing purposes, you shall have the right to object at any time to processing of Personal Data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing); 3.6.4. the Personal Data have been unlawfully processed; 3.6.5. the Personal Data has to be erased for compliance with a legal obligation in Union or Member State law to which the MANIMAMA is subject.
5. DISCLOSURE AND TRANSFER OF PERSONAL DATA 5.1. Your Personal Data is disclosed only in connection with case management and legal advice, and only when MANIMAMA is legally obliged to do so, or when you have given your consent. You can always withdraw your consent by contacting MANIMAMA via the above contact information. Personal Data may be disclosed to the following parties: 5.1.1. the parties to your case; 5.1.2. public authorities, including courts, tax authorities, prosecuting authority, banks, etc; 5.1.3. in connection with auditing; 5.1.4. third party organizations that provide applications/functionality, data processing or IT services to us; 5.2. For verifying the identity of our Clients, we use our internal KYC department and may hire other persons who are relied on is required to comply and actually complies with requirements equal to those established by Directive (EU) 2015/849 of the European Parliament and of the Council, including requirements for the application of due diligence measures, identification of politically exposed persons and data retention. 5.3. For behavior statistics and business intelligence we use the service by Google LLC (“Google Analytics”), a company located in the United States. Personal Data that we may provide to Google Analytics may include your IP address and that data is used by Google Analytics to generate information about your usage of our Website. 5.4. For tracking server errors, we use an internal self-hosted monitoring system accumulating stacktraces, logs and metrics. 5.5. For processing notification information, we use chatbots and e-mail notifications. 5.6. MANIMAMA may transmit Personal Data data to third countries, complying with the requirements set out in the legislation, and by adopting appropriate measures to ensure data security. Where we transfer personal data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement that covers the EU requirements for the transfer of personal data outside the EEA, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here. 5.7. Any disclosure of Personal Data is carried out in strict accordance with the requirements of the law. When we disclose your Personal Data to a Third Party, we take all reasonable steps to ensure that those Third Parties are bound by confidentiality and privacy obligations with respect to the protection of your Personal Data. The disclosure is conducted in compliance with legal requirements, including entering into data processing agreements with the relevant Third Parties, to ensure that Personal Data is only processed in accordance with our instructions, applicable law and regulations and for the purpose specified by us and to ensure adequate security measures.
6. SECURITY OF PERSONAL DATA 6.1. We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure. 6.2. Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visits as safe as possible. Your Personal Data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. 6.3. Our Website uses an HTTPS protocol that ensures the security of data exchanged via Transport Layer Security (TLS) protocol. The TLS provides three layers of protection: encryption, data integrity and authentication.
Contact us in Estonia
MANIMAMA OÜ Company number 14803352 Legal address: Harju maakond, Tallinn, Kesklinna linnaosa, Pärnu mnt 158/2-88, 11317, Estonia