Last updated 07.12.2022
EDENLAB OÜ (“we,” “us,” or “our”) is a custom software development company that provides you with access to and use of these websites https://kodjin.com/, https://edenlab.io/, their Services, Products, and Solutions.
- Engage with us in other related ways, including any sales, marketing, or events.
Summary of Key Points
What personal information do we process? When you visit, use, or navigate our websites, we may process personal information depending on how you interact with us and our Services, Products, and Solutions.
Do we process any sensitive personal information?
We do not process sensitive personal information.
Do we receive any information from third parties?
Some information, such as your browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and other technical information we receive from third parties, such as analytics tools. We don’t disclose or sell this information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our websites, and other technical information.
How do we process your information?
We process your information to provide, improve, and administer our Products, Services, and Solutions, communicate with you for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
1. What information do we collect?
The personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Products, Services, and Solutions (such as your name, email address, and company name) when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information we collect depends on the context of your interactions with us, your choices, and the products and features you use. The personal information we collect may include the following:
- Email address
- Company name
Sensitive Information. We do not process sensitive information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our websites.
We automatically collect certain information when you visit, use, or navigate our websites, using our Products, Services, and Solutions. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our websites, and other technical information. This information is primarily needed to maintain the security and operation of our websites and for our internal analytics and reporting purposes.
The information we collect includes the following:
- Log and Usage Data. Log and usage data is website-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our websites and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, settings, and information about your website activity.
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the websites. Depending on the device used, this data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data. We collect location data, such as information about your device’s location, which can be precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the websites. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the websites.
Other than as required by law, Edenlab websites (https://kodjin.com/ and https://edenlab.io/) do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). EDENLAB OÜ will not collect any information about criminal convictions and offenses.
2. How do we process your information?
In Short: We process your information to provide, improve, and administer our websites, communicate with you for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our websites, including:
- We may process your information to provide you with the requested service.
- To respond to user inquiries. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
3. What legal bases do we rely on to process your personal information?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
- Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection, and prevention
- For business transactions, provided certain conditions are met
- If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession, and the collection is consistent with the purposes for which the information was produced
- If the information is publicly available and is specified by the regulations.
5. How long do we keep your information?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. Do we collect information from minors?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the websites, you represent that you are at least 18. If you become aware of any data we may have collected from children under the age of 18, please contact us at [email protected]
7. What are your privacy rights?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv), if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK, and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent, depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
8. Controls for do-not-track features
9. Do California residents have specific privacy rights?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
The California Code of Regulations defines a “resident” as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
|A. Identifiers||Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name||YES|
|B. Personal information categories listed in the California Customer Records statute||Name, contact information||YES|
|C. Protected classification characteristics under California or federal law||Gender and date of birth||NO|
|D. Commercial information||Transaction information, purchase history, financial details, and payment information||NO|
|E. Biometric information||Fingerprints and voiceprints||NO|
|F. Internet or other similar network activity||Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements||YES|
|G. Geolocation data||Device location||YES|
|H. Audio, electronic, visual, thermal, olfactory, or similar information||Images and audio, video, or call recordings created in connection with our business activities||NO|
|I. Professional or employment-related information||Business contact details in order to provide you our Services at a business level||YES|
|K. Inferences drawn from other personal information||Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics||NO|
How do we use and share your personal information?
You may contact us by email at [email protected] or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” your personal information.
EDENLAB OÜ has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. EDENLAB OÜ will not sell personal information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell your personal information to third parties;
- the categories of personal information that we sold or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your Privacy Rights.
Upon receiving your request, we will need to verify your identity to determine whether you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
To exercise these rights, you can contact us by email at [email protected] or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
10. Do we make updates to this policy?
In Short: Yes, we will update this Policy as necessary to stay compliant with relevant laws.
11. How can you contact us about this policy?
If you have questions or comments about this policy, you may email us at [email protected] or by post to:
Vesivärava str. 50-201
12. How can you review, update, or delete the data we collect from you?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it.
Get your experienced FHIR developers for hire, schedule Kodjin FHIR server demo, or request a consultation
Your form has been submitted successfully
We will contact you shortly
Vesivärava str. 50-201, 10152, Tallinn, Estonia