Data Protection Conditions

The page describes the Data Protection Conditions (Privacy Policy) of Numeri.

The aim of the General Data Protection Conditions of Numeri is to protect the Personal Data of Data Subjects in conformity with the legislation of the European Union and the laws of the Republic of Estonia, the Republic of Latvia, and the Republic of Lithuania. The General Data Protection Conditions proceed in particular from Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR), from the Personal Data Protection Act, Personal Data Processing Law, and the Law on Legal Protection of Personal Data.

DEFINITIONS
1. Data Subject: a natural person, whose Personal Data is processed by Numeri. Data subjects are, for example, clients who are natural persons, visitors, cooperation partners, employees and job applicants.
2. Personal Data: any information relating to a Data Subject; a directly or indirectly identified or identifiable natural person, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
3. Special Categories of Personal Data: Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning a natural person’s sex life or sexual orientation.
4. Personal Data Processing: any operation/-s performed on Personal Data, whether automated or not, including collection, recording, organization, structuring, storage, modification, retrieval, consultation, use, transfer, alignment or combination, restriction, erasure or destruction.
5. Data Controller: the entity which, alone or jointly with others, determines the purposes and means of processing Personal Data.
6. Data Processor: the entity which processes Personal Data on behalf of the Data Controller.
7. Personal Data Breach: a security breach leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to Personal Data.
8. Consent: a freely given, specific, informed and unambiguous indication of the Data Subject’s wishes through a statement or by clear affirmative action, agreeing to the Data Subject’s Personal Data Processing.
GENERAL PROVISIONS
1. Numeri OÜ is a legal entity (Reg. No. 10203098, located at Sõpruse pst 145, 13417 Tallinn, Estonia), SIA Numeri is a legal entity (Reg. No. 40003563943, located in Elizabetes iela 33-6, Riga, LV-1010, Latvia), and Numeri UAB is a legal entity (Reg. No. 300602458, J. Jasinskio g. 16B, LT-03163, Vilnius, Lithuania) (all together – Numeri, we, us, our).
2. In regards to Personal Data Numeri may act as:
  1. As a Data Controller, when we determine the purposes and means of processing;
  2. As a Data Processor, when we process data on behalf of a Data Controller according to its instructions.
3. Types of Personal Data processed by us may include:
  1. Personal identifiers: name, surname, personal identification number, passport data (for non-residents);
  2. Contact details: address , telephone number, e-mail address;
  3. Financial data: salary information, bank account information, taxation data;
  4. Employment data: job title, work schedule, leave records, qualifications, education, language skills;
  5. Special category data, where applicable and with explicit consent: health or biometric data.
4. Numeri may process Personal Data created during communication between the Data Subject and Numeri and as a result of our service provision and use of Numeri website (cookies, log files).
5. Only Numeri authorized personnel may process or modify Personal Data. Numeri ensures confidentiality of Personal Data and limits disclosure of Personal Data only to what is necessary for specific purposes.
PRINCIPLES OF PERSONAL DATA PROCESSING
1. Numeri processed Personal Data based on the following principles:
  1. Lawfulness, fairness and transparency: Personal Data are processed lawfully, fairly and in a transparent manner in relation to the Data Subject;
  2. Purpose limitation: Personal Data are collected and processed for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  3. Data minimisation: Personal Data collection and processing is adequate, relevant and limited to what is necessary for the processing purposes;
  4. Accuracy: Personal Data are accurate and, where necessary, kept up to date; every reasonable step is taken to ensure that Personal Data that is inaccurate, is erased or rectified without delay;
  5. Storage limitation: Personal Data are kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data are processed;
  6. Integrity and confidentiality: Personal Data are processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
LEGAL GROUNDS FOR PERSONAL DATA PROCESSING
1. Numeri may process the Personal Data based on the consent of the Data Subject, for the performance of contractual obligations or preparatory measures prior to contractual obligations, for compliance with a legal obligation or in case of legitimate interest.
  1. Consent of the Data Subject: Numeri may process Personal Data within the extent and for explicit purposes as determined by the Data Subject. The Data Subject gives Consent for Personal Data processing voluntary, specifically, knowingly and unambiguously.
  2. Contractual obligations: Numeri may process Personal Data necessary for the performance of a contract to which the Data subject is Party or to take steps at the request of the Data Subject prior to entering into a contract. For example, processing of personal data may be necessary upon the establishment of customer relationship and entering into service agreements for providing accounting services, payroll services, tax consulting services, legal services, administration of customer’s documents.
  3. Legal obligation: Numeri may process Personal Data required by law. For example, such obligation may arise from the employment related laws, anti-money laundering laws and accounting laws etc. Numeri processes the Personal Data on the grounds arising from law only after careful assessment in order to establish that Numeri has a legitimate interest, based on which processing of Personal Data are necessary and in conformity with the interests and rights of the Data Subject.
  4. Legitimate interest: Numeri may process Personal Data for the purpose of improving services and business processed, and promoting business activity, balanced against the Data Subject’s fundamental rights and freedoms.
DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES AND CROSS-BORDER DATA TRANSFERS
1. Numeri may transfer personal data within the provided service or pursuant to law within strictly limited extent to third parties (for example, notary, state-specific tax authority, employment authority, health insurance authority, Data Protection authority, auditors, anti-money laundering authority).
2. If data is transferred outside the EU/EEA, Numeri ensures adequate safeguards, such as Standard Contractual Clauses (SCCs) or adequacy decisions under GDPR.
DATA SUBJECT RIGHTS
1. The right to withdraw Consent at any time: the Data Subject shall have the right to withdraw the Consent at any time, where processing of Personal Data are based on Consent. This does not affect the legality of Data Processing conducted before withdrawal of the Consent.
2. The right to receive and access information: the Data Subject has a right to receive and access information on the Personal Data gathered and receive a copy of the Personal Data undergoing processing. It is possible to receive information from Numeri on the Processing of Personal Data by sending a written request by e-mail to numeri@numeri.ee (Estonia), numeri@numeri.lv (Latvia), office@numeri.lt (Lithuania).
3. The right to rectification: the Data Subject shall have the right to have the inaccurate Personal Data corrected and incomplete Personal Data completed.
4. The right to be forgotten: in certain cases, the Data Subject has a right to demand erasure of Personal Data and Numeri shall be committed to erase the Personal Data without undue delay where one of the following grounds applies:
  1. The Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. The Data Subject withdraws consent given for the processing and where there is no other legal ground for the processing of Personal Data;
  3. The Data Subject objects to the processing of Personal Data and there are no overriding legitimate grounds for the processing, or the Data Subject objects to the processing;
  4. The Personal Data have been unlawfully processed;
  5. The Personal Data have to be erased for compliance with a legal obligation in EU or Member State law to which Numeri is subject.
5. The right to restriction of processing: the Data Subject shall have the right to demand restriction of processing of Personal Data in the following cases:
  1. The accuracy of the Personal Data is contested by the Data Subject, for a period enabling Numeri to verify the accuracy of the Personal Data;
  2. The processing is unlawful and the Data Subject opposes the erasure of the Personal Data and requests the restriction of their use instead;
  3. Numeri no longer needs the Personal Data for the purposes of the processing, but they are required by the Data Subject for the establishment, exercise or defence of legal claims;
  4. The Data Subject has objected to processing the Personal Data pending the verification whether the legitimate grounds of Numeri override those of the Data Subject.
6. The right to data portability: in certain cases the Data Subject shall have the right to receive the Personal Data concerning, which has been provided to Numeri, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
7. The right to object: the Data Subject shall have the right to object, on grounds relating to particular situation, at any time to processing of Personal Data conducted for the performance of a task carried out for reasons of public interest or in the event of a legitimate interest of Numeri or a third person. Numeri shall no longer process the Personal Data unless Numeri demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
PERSONAL DATA RETENTION
1. Numeri keeps the Personal Data in a form, which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data are processed, unless Numeri has a legal requirement stipulating different time limits for the storage of Personal Data:
  1. Accounting documents must be retained in conformity with the country-specific accounting laws and archiving laws;
  2. Employment documentation must be retained in conformity with the country-specific employment laws and archiving laws;
  3. data gathered under the anti-money laundering laws shall be retained pursuant to the country-specific laws.
2. If the job applicant was not elected during recruitment, the Curriculum Vitae of the Data Subject shall be retained in accordance with the country specific GDPR policy. The Personal Data of a job applicant who was not elected shall be deleted in accordance with the country specific GDPR policy.
3. Numeri shall destroy and/or delete securely all Personal Data, the purpose of retention of which does not exist or the retention period of which has expired.
COOKIES
1. Numeri uses cookies and similar technologies on its website to enhance functionality and analyze usage. Essential cookies are necessary; non-essential cookies are used only with user consent.
2. Visitors may control cookie preferences via browser settings or cookie banners.
AUTOMATED DECISION-MAKING
1. Numeri does not carry out automated decision-making or profiling that significantly affects Data Subjects, unless explicitly informed and based on lawful grounds.
EXERCISING OF RIGHTS AND FILING OF COMPLAINTS
1. The Data Subject has a right to exercise the rights: contact Numeri in case of questions, requests or complaints relating to the processing of Personal Data.
2. All questions and proposals concerning the processing of Personal Data may be referred to the following contacts:
  1. Numeri OÜ, Sõpruse pst 145, 13417, Tallinn, Estonia, numeri@numeri.ee;
  2. SIA Numeri, Elizabetes iela 33-6, Riga, LV-1010, Latvia, numeri@numeri.lv;
  3. Numeri UAB, J. Jasinskio g. 16B, LT-03163, Vilnius, Lithuania, office@numeri.lt.
3. The Data Subject has a right to file complaints: if the Data Subject is of the opinion that the processing of their Personal Data has violated their rights, the Data Subject has the right to file this claim to Numeri, the country-specific Data State authority or a court.
4. All complaints concerning the processing of Personal Data may be referred to the following contacts:
  1. Estonian Data Protection Inspectorate;
  2. Latvian Data State Inspectorate;
  3. Lithuanian State Data Protection Inspectorate.
UPDATES TO THIS DOCUMENT
1. This document may be updated to reflect changes in legislation or processing practices. Updated versions will be made available on Numeri website. Latest update: 14 May 2025.

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