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This is an English translation of the Estonian privacy policy, provided for convenience. If the two versions differ, the Estonian version applies.
1. General information
This privacy policy explains how Heamüük OÜ (trademark Upsell) collects and processes your personal data when you apply to join our sales team through the application form on the upsell.ee website.
Data controller: Heamüük OÜ
Registry code: 14071088
Address: Pärnu mnt. 12, 10148 Tallinn, Estonia
Email: talent@upsell.ee
For any questions about data protection, contact us at the email address above.
2. What data we collect
When you fill in the application form, we collect the following data:
- name
- phone number
- email address
- age
- motivation letter (optional, if you fill it in)
In addition, while you use the website we collect technical data (such as device type, browser and actions taken on the page) using cookies and similar technologies, see section 7.
3. Purpose and legal basis of processing
a) Processing your application. We use your data to contact you, assess your suitability and carry out the recruitment process. Legal basis: our legitimate interest in recruiting suitable candidates, and steps taken at your request before entering into a possible contract (GDPR Art. 6(1)(b) and (f)).
b) Marketing and creating lookalike audiences. If you give separate consent, we may contact you in the future about new opportunities and use your contact details (including in hashed form) on advertising platforms to create audiences and lookalike audiences. Legal basis: your consent (GDPR Art. 6(1)(a)). You can withdraw your consent at any time, see section 8.
4. Who we share data with
We do not sell your data. We share data only with the following parties, who process data on our behalf or are necessary for the service to work:
- providers of the website’s and the form’s technical services (such as web hosting, form and automation tools);
- the advertising platform Meta (Facebook, Instagram) and other advertising platforms we may use, but only if you have given marketing consent (section 3b);
- analytics providers, to understand how the website is used.
All service providers are obliged to protect your data and use it only for the agreed purpose.
5. Transfers outside the European Union
Some service providers (such as Meta) may process data outside the European Union, including in the United States. In that case we ensure that the transfer complies with the GDPR, using appropriate safeguards (such as the European Commission’s standard contractual clauses or a valid data protection framework).
6. How long we keep data
We keep data for as long as necessary to fulfil the purpose for which it was collected:
- We keep application data for up to 12 months after the recruitment decision.
- If you have given marketing consent (talent pool and later contact), we keep your contact details for up to 2 years from the date of consent or until you withdraw consent, whichever comes first.
7. Cookies and tracking technologies
The website uses cookies and similar technologies to make the site work and (with your consent) to measure advertising performance. We use the following: Meta Pixel (to measure the performance of Facebook/Instagram advertising).
Meta Pixel is activated only if you give consent in the cookie banner. You can change your choices at any time.
8. Your rights
You have the right to:
- access your data;
- request the correction of inaccurate data;
- request the deletion of data;
- restrict processing or object to processing;
- receive your data in a portable format;
- withdraw your consent at any time (this does not affect the lawfulness of processing carried out before the withdrawal).
To exercise your rights, contact: talent@upsell.ee.
9. Filing a complaint
If you believe your data has been processed unlawfully, you have the right to contact the Estonian Data Protection Inspectorate (www.aki.ee).
10. Changes
We may update this privacy policy from time to time. The current version is always available on this page.