Privacy Notice and General Rules
This Privacy Notice (hereinafter: Notice) describes how non-profit association BE (registry code 80213483; hereinafter: MBE or us), address Nurme 45, 11621 Tallinn, Republic of Estonia) processes the user’s personal data gathered while using the services on the portal https://industry.poff.ee/ (hereinafter: Portal). MBE gathers the user’s personal information in Portal when signing up for the events (hereinafter: events) organised by MBE, that can differ yearly, including changing the co-operation partners.
In the Portal, we may process your personal data within the framework of various processes and relationships, depending on how you are associated to us. This Privacy Notice is divided into different parts on the basis of the different situations in which we may need to process your personal data. In order to obtain an accurate overview of the personal data processing principles that concern you, kindly find the part(s) below which apply to your connection with to MBE or Black Nights Film Festival (hereinafter: PÖFF)
The terms and definitions used in the Privacy Notice should be construed as in the General Data Protection Regulation of the European Union (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation; hereinafter GDPR).
‘Eventival’ means the film festival management portal at https://www.eventival.com/.
1. Categories of personal data, purposes and legal bases of processing, and storage of personal data
The conditions below are applicable to all cases of processing personal data gathered by MBE, considering the obligations arising from General Terms and Conditions, applicable legal acts and terms arising from the Privacy Notice. By participating in the Event, you agree to comply with the rules and regulations of Industry@Tallinn, MBE and PÖFF, and treat the respective employees, volunteers and other responsible persons with respect and cooperate with them comprehensively if necessary.
The participant of the Event can inform the Organizer of the Event by means of the e-mail below of their wish not to be recorded at the Event, except in the cases prescribed by law, when the Organizer of the Event has the right to record the Event and use this recording in accordance with the law. If the person has not notified of the wish to not be recorded, mentioned in the previous sentence, it is considered that by attending the relevant Event you agree that the organizer has the right to record the Event and direct this recording to the public, including follow-up by registered users of our website and the use of this recording for marketing purposes
I am an invited or registered guest or a journalist at the Event
We may process the following personal data related to you (the categories of personal data may vary depending on which data you have decided to forward to us) in connection with Events or ohter services provided by MBE or it’s partners.
personal details (given name and surname, date of birth, sex, languages);
contact details (e-mail address, phone number);
employment related data (country, position, area, profession);
If we make transport and accommodation bookings for you under an agreement with you, we may additionally process the following personal data:
personal identification document data;
details of transport and accommodation services (e.g. route, duration);
other data which you have forwarded to us for that purpose (e.g. information concerning food intolerances, information concerning physical special needs).
As a rule, we collect your personal data from you and store these under your profile in Eventival. You may also create an Eventival account and add and change data there yourself. Your Eventival account will be linked to your Eventival profile. In order to simplify the creation of an account for you, we may, with your consent, create an account for you, adding the necessary personal data from your profile. If you have given us your consent for the creation of an Eventival account, we shall, after pre-completing the account, give you access to the Eventival user account, which allows you to manage the personal data on your account (allows you to choose your password). Upon pre-completing the profile and the account or for the purpose of establishing first contact with you, we may also collect your name, contact details and employment data from public sources (Google, LinkedIn, Cinando, the websiteof your organisation).
We process your personal data for the following purposes and on the following legal bases:
we process your personal data (name, contact details, employment information) in order to contact you and invite you to the Events, in which case the legal basis for processing is our legitimate interest to invite you to attend the event and thereby increase the quality and attractiveness of the Events
we process your personal data (personal details, contact details, employment information, photo, payment data) in order to allow you to visit Events, including for the purpose of issuing you the badge with a photo necessary for that purpose and to contact you in connection with the event, in which case the legal basis for processing your personal data is the performance or entry into our mutual contract under which you have received an accreditation to attend the Events (Article 6 (1)(b) of the GDPR);
we process your personal data in order to organise transport and accommodation services for you (if we have made a relevant agreement), in which case the legal basis for processing your personal data is the performance of our mutual agreement (Article 6 (1)(b) of the GDPR);
we process your personal data (personal details, contact details, employment information) in order to offer you a personal reception upon your visit to the Film Festival and/or Industry (unless you are accompanying a film guest), in which case the legal basis for processing is our legitimate interest to do so in order to thereby increase the quality and attractiveness of the Events.
we process your personal data (name, contact details, employment information, photo) for printing Industry Guide distributed to the participants of Industry and for preparing the online Eventival catalogue Who Is Here (unless you are accompanying a film guest), in which case the legal basis for processing is our legitimate interest to thereby increase the quality and attractiveness of the Events.
we process your personal data for the fulfilment of our obligations arising from legal acts
if necessary, we process your personal data for filing claims and for defending ourselves against claims, in which case the legal basis for processing is our interest to do so, to the extent that in our assessment overrides your interests and fundamental rights and freedoms.
The data of film guests and jury members (name and employment information) are also disclosed in connection with the Film Festival on PÖFF’s webpage and in other sources. The legal basis for the disclosure is our legitimate interest to provide sufficient information about the Film Festival. We store your personal data until it is necessary depending on the objective for which we collected the data. We may store your personal data longer, if it is necessary for the protection of our interests or the fulfilment of our obligations deriving from the law. For instance, we store personal data necessary for the fulfilment of accounting obligations for at least 7 years from the end of the relevant financial year, and we store personal data necessary for filing claims or defending ourselves against claims for 10 years.
I am a guest who has bought a ticket to the Film Festival
If you are a guest who has bought a ticket to the Film Festival, we generally do not process your personal data, as tickets are not personalised. We may process your personal data (name, contact details) if, for instance, you take part in audience voting. In such case the legal basis for processing is your consent. Please note that you have the right to withdraw your consent at any time by giving notice of your wish to firstname.lastname@example.org. The withdrawal of the consent does not affect the lawfulness of the processing performed on the basis of the consent before the withdrawal thereof. We store your personal data until necessary for the objective for which we collected the data.
1.4. I am a member of the loyalty programme Wolf Pack (PÖFF Club)
In the meaning of this Privacy Notice, ‘memers of the loyalty programme’ include all the persons who have joined the loyalty programme Wolf Pack by creating a user on PÖFF’s webpage or by registering as a loyalty programme member at a PÖFF information point.
1.5. I am a candidate for the position of an employee or a volunteer.
In the meaning of this Privacy Notice, ‘candidates’ include all persons who have expressed their wish to be employed (on the basis of an employment contract or a contract for services) or work as a volunteer at Industry @Tallinn & Baltic Event.
As a rule, we store your personal data for 1 year from making the recruitment decision. If you have given us your consent for making work offers in the future, we store your personal data for 5 years or until you withdraw your consent. We may store your personal data longer, if it is necessary for the protection of our interests or the fulfilment of our legal obligations.
1.6. I am a recepient of the newsletter
In the meaning of this Privacy Notice, ‘recipient of the newsletter’ includes all persons who have subscribed to the PÖFF, PÖFF Shorts or Just Film newsletter lists. We forward the PÖFF, PÖFF Shorts and Just Film newsletter to you only with your consent, for the purpose of informing you of various offers, events and our other activities which may be of interest to you. We also conduct surveys at times in order to receive feedback on our services and to develop our services accordingly. In order to send you the newsletter, we process your given name and surname, e-mail address and the newsletter topic preferences. You have the right to withdraw the consent granted for sending the newsletter at any time by clicking on the link at the end of the newsletter or by sending an e-mail to email@example.com /firstname.lastname@example.org. Please note that the withdrawal of the consent does not affect the lawfulness of the processing performed on the basis of the consent before the withdrawal thereof.
We store your personal data until you ask to be removed from amongst the recipients of the newsletter.
2. Transmission of personal data
We share your personal data with third parties only in the case of justified need to the justified extent and only if we have a legal basis to do so. For instance, in our activities we use the following service providers who may get access to your personal data (data processors): Eventival, Google, e-mail service provider, accounting software provider, payment platform provider, film screening platform provider, IT service providers; and, in the case of the invited guests of the Film Festival and Industry, our contractors and volunteers. We only use processors who provide sufficient guarantees that they apply appropriate technical and organisational measures in order to ensure the protection of your personal data.
We may also transmit your personal data to the following third parties who act as independent controllers with regard to your personal data:
to the recipients of PÖFF’s and ITBE reports, such as film producers, the media, the Ministry of Culture, the Tallinn City Office. The reports contain the name and professional information of the invited guests of the Film Festival and Industry (excluding the persons accompanying the film guests).
to Enterprise Estonia for the fulfilment of our obligations arising from legal acts to submit the data of foreign guests in connection with the certification obligation arising from the receipt of marketing support for large-scale events.
if appropriate, to third parties via whom transport and accommodations services are organised for the invited guests of the Film Festival and Industry, in which case the legal basis for transmission is the fulfilment of our mutual agreement.
to third parties who organise events within the PÖFF Film Festival and Industry for the Film Festival and the Industry guests, participation in which is based on personal invitations or a guest list, in which case the legal basis for transmission is your consent.
to third parties who are involved in the protection of our rights (e.g. legal consultants);
to third parties to whom we are obligated to transmit personal data in accordance with the law or other legal acts (e.g. auditors, supervisory authorities)
3. Transmission of personal data outside the European Union
We transmit your personal data outside the European Union only if we have a legal basis to do so, including to data recipients: (i) who are located in a country where a sufficient level of personal data protection is ensured in the assessment of the European Commission (this includes organisations certified under the Privacy Shield); or (ii) on the basis of an agreement which meets the EU requirements for the transmission of personal data to personal data processors located outside the EU. If you wish to obtain more detailed information about the transmission of your personal data outside the European Union (e.g. the names of the data recipients and the legal basis for transmission), please contact us by using the contact details provided below.
In our assessment, we implement sufficient technical and organisational security measures to protect your personal data, taking into account: (i) the level of technology, (ii) the costs of implementation, (iii) the nature, scope, context and purposes, and (iv) the risks arising for you from processing.
5. Your rights
With regard to your personal data, you have all the rights prescribed by legal acts, including the General Data Protection Regulation, on the terms and conditions and to the extent established therein:
the right to request access to your personal data (including to receive a copy of your personal data);
the right to request the rectification of personal data;
the right to request the deletion of personal data;
the right to request the restriction of the processing of personal data;
the right to the portability of personal data;
the right to submit objections if personal data is being processed on the basis of our legitimate interest and the processing is being done for the purpose of direct marketing.
If you wish to exercise the rights specified above or if you have any questions concerning the processing of your personal data, please contact us by using the contact details provided below.
If you find that your personal data have been processed in contradictions with this Privacy Notice or your personal data rights have been violated, please inform us thereof using the contact details provided at the end of this Privacy Notice. In case of a violation, you also have the right to appeal to the Data Protection Inspectorate or a court. If your permanent place of residence or employment is in a European Union Member State, you can also appeal to the data protection authority of that Member State.
6. Amendment of Privacy Notice
If our personal data processing practices change or we need to change the Privacy Notice due to the changes in the applicable data protection related legal acts, other legal acts, case-law or guidelines or practices of competent authorities, we have the right to unilaterally amend the Privacy Notice. If the amendments have a significant effect for you, we shall give you reasonable prior notification before the entry into force of the amendments by e-mail.
7. Applicable law
Non-profit association MTÜ BE is an association registered in the Republic of Estonia and the processing of your personal data is therefore subject to the laws of the Republic of Estonia. According to the current law of the Republic of Estonia, there may be situations where it is not possible to organize some events due to restrictions imposed on legal grounds, therefore we may cancel or postpone the events, and in such cases, a refund or a pass to the postponed event is possible according to the organizer's decision.
8. Contact details
If you have any questions concerning the processing of your personal data or if you wish to exercise your rights with regard to your personal data, please contact us using the following contact details:
Mittetulundusühing(non-profit association) BE (registration code: 80213483)
Address: Nurme 45, 11621 Tallinn, Eesti Vabariik
Phone: +372 677 6363