Privacy Policy

Data Use Principles of Wolf Group OÜ

Wolf Group OÜ on its own and together with the Wolf Group of companies (hereinafter Wolf Group or we, us, our) values its clients’ (hereinafter you) privacy. In this privacy notice we explain how we collect and use your personal data as well as what we do to protect your data. This privacy notice helps you to understand why and how we process your data as well as what are your rights in relation to your personal data.

This privacy notice is applicable to you if you use our e-shop for purchasing https://penosil.com/products/ as well as creating product wish lists on our websites, if you communicate with us using the chatbot on our website and if you visit our websites https://penosil.com/ or our social media sites. We also process your personal data if you apply to work with us.

Who is the controller of your personal data?

The data “controller” means the entity that will make the decisions what data about you is collected and how is it used. Wolf Group can be a controller or a processor in various data processing operations. To ensure your privacy is protected we abide by confidentiality principles and strictly limits disclosure of personal data.

Wolf Group OÜ, Wolf Group, Suur-Paala 10, 13619 Tallinn, Estonia is the controller of all personal data referred to in this Privacy Notice unless otherwise explicitly stated. The controller can be contacted by e-mail: wg@wolf-group.com.

What type of personal data we process?

Personal data – first and last name;
Contact data – phone number, e-mail address, address;
Company data – if you are a representative of a legal entity we will process your name, job title and your contact data;
Invoice data – data that is on the invoices when purchase services or products from us;
Internet data – to enable a better service in our e-shop we use cookies on our website and e-shop.

Why do we process your data?

We process your personal data because:

• you have given us your consent, for example to gather customer feedback, send you a newsletter or display cookies;
• in our legitimate business interest; if you are our existing client sending you information about our products;
• we have contract with you, for example you have bought a product in our e-shop;
• to comply with legal obligations; for example, we are obliged to keep invoices for a number of years according to the accounting regulations.

Processing data based on your consent.

When we ask for your consent, we only process what you have consented to. We will be very clear asking consent for specific purposes and you are not obliged to consent but sometimes it means we cannot deliver to you content requested by you. When you give consent, you have a right to withdraw your consent at any time by using unsubscribe in the messages or writing to wg@wolf-group.com. When you withdraw consent, we will delete the data we are processing with your consent.

Data processing required for performance of a contract.

Data processing is necessary for performance of a contract concluded with you or for taking measures required prior to signing of the contract. 

Processing to fulfil Wolf Group’s legal obligations.

Legal obligations of processing include all personal data processing under relevant laws and regulations in all of our locations for example Accounting Act in Estonia.

Data processing based on our legitimate interest.

A legitimate interest means that data processing is necessary for our business purposes. For data processing based on our legitimate interest we have conducted balance test to measure the impact of the processing on your privacy and data protection rights. You have a right to see these balance test as well as object to processing based on legitimate interest, if you consider that processing of your data for the following purposes breaches your privacy and data protection rights.

What do we do with social media?

You can join or like our Facebook, LinkedIn, Instagram or TikTok page in which case we will see your name and clicking on that name we would also see your public profile’s information. With the social media you have to keep in mind that:

• our site is public, that means visible to everybody;
• anyone may publish a post on our social media sites and everybody can refer to our social media pages and its public content;
• where available, we permit automatic translation of posts to readers in other languages;
• we apply automatic filtering of the content in social media, meaning publication of posts that contain generally known offensive expressions are automatically prevented;
• you can contact us privately in social media;
  We receive the statistical usage data of our social media sites – how many likes, site visitations etc. This data is prepared by social media providers themselves and presented to us in a de-personalized format.

Do we make any automated decisions?

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. Wolf Group doesn’t make any automated decisions based on the personal data we collect.

What are your rights with regards to your personal data?

Right of access

You have the right to receive information what data we process about you. To receive a copy of what personal data we hold about you contact us on the e-mail below.

We have a legal obligation to make sure that a person requesting information about themselves is indeed the person who has the right to receive the data. For this reason, you may have to prove your identity or right to request the data.

Right to erasure

You have the right to request deletion of your personal data. Please keep in mind that we cannot delete any data that we process to fulfil contractual or legal obligation.

Right to rectification

You have the right to ask us to rectify personal information you think is inaccurate. This could also include the right to ask us to complete information you think is incomplete.

In some circumstances and subject to certain exceptions, you may have the right to ask us to erase your personal information. We cannot erase any data that we have a legal obligation to process.

Right to restrict processing

In certain circumstances, you have the right to ask us to restrict the processing of your information.

Right to object to the processing of your personal information

You have the right to object to the processing of your information. The right to object to the processing of personal information is most commonly used by individuals when asking a business to cease direct marketing.

Right to data portability

You have the right to data portability which means that if technologically possible we can forward your data in a digital format to other similar service.

To exercise the any of the aforementioned rights via e-mail to: wg@wolf-group.com.

Right to complain to Data Protection Inspectorate

In case you consider your privacy and data protection rights breached you have the right to lodge a complaint to Estonian Data Protection Inspectorate or your local data protection supervisory authority.

Who else processes Your data in addition to us?

Your personal data is accessible only to those Wolf Group employees who need the data to perform their work duties, on so-called need-to-know basis.  Outside Wolf Group, and strictly limited by necessity and pursuant to the purposes of processing, Wolf Group forwards data to following categories of data processors:

• service provides such as (not a complete list and subject to change): IT maintenance service provider, server housing, e-mail server provider, website administrator, feedback program KOOS.io, auditor, lawyers;
• if legally obliged, your data to public authorities and institutions (e.g. police, courts, alarm center, Data Protection Inspectorate).

We have concluded a data protection agreement with our partners to ensure secure and lawful processing of personal data. These contracts oblige the other parties to:

• take appropriate measures to ensure confidentiality and security of the personal and
• process personal data in compliance with legal requirements and the agreement.

We do not store or transfer your data outside the European Economic Area or to countries without European Commission’s adequacy decision.

How long do we retain Your personal data?

Your personal data is retained for as long as required by legal requirements or until the purpose of processing is fulfilled. Below are some examples of data retention periods:

Security of your personal data

Wolf Group employs necessary legal, organizational, physical and technical security measures to protect your personal data. Some examples of the measures we use:

Physical measures – the offices are locked and paper-based documents containing personal data are stored in locked cabinets.

Technical measures – computers are password protected and encrypted as necessary; firewalls and antivirus programs are in use; backups are done regularly; all IT system users are assigned roles and profiles.

Organizational means – data protection, information security and access management policy; regular employee training, confidentiality requirements for employees.

Cookies

The Wolf Group uses cookies on the website https://www.penosil.com to improve website users’ experience on and to enable the functioning of the e-shop.

A cookie is a small text file that is automatically saved by the web browser on the device used by you. We use following cookies:

• Necessary cookies are used for essential functions during your visit to the website. These include identifying the country and language used, processing the transaction, identifying the version of the website being used (whether mobile or desktop), fraud detection and prevention and ensuring compliance and website stability. These cookies are classified according to the needs of keeping the website up and running.
• Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. It stores information about the choices you make. With this, we can show you more relevant and personal information.
• Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
• Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
• Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

You can set your browser to refuse any cookie or to alert you to when a cookie is being received. Web browsers allow you to control cookies stored on your hard drive through the web browser settings If you choose not to accept our cookies, some of the features of our site may not work as well as we intend.

Cookie declaration

Changes to privacy notice

We update this privacy notice regularly. The version published on our website is always the latest version.

Contact information:

Wolf Group OÜ
Suur-Paala 10
13619 Tallinn, Estonia

Telephone: +372 6059 300
Email: wg@wolf-group.com