Last updated on March 18, 2023
Orien Trade OÜ
Registration code: 12733937
Saalungi 18, 50411 Tartu
Website: orientrade.com, orientrade.net
(” Orien Trade “, ” we “, ” us ” or ” our “)
This Privacy Policy describes how Orien Trade processes the personal data of different consumer groups. This Privacy Policy applies to you when:
- you visit our website;
- you subscribe to our newsletter;
- you place orders in our B2B online store or use our B2B online store in another way;
- you interact with our customer service or with us in other ways, such as through our social media channels;
- you register or have registered as a regular customer of our B2B online store;
- you are a consumer participating in a consumer survey or consumer competition or you provide feedback, for example by filing a complaint or claiming that our products have caused skin irritation or;
- you are a consumer who wants to understand how Orien Trade processes your personal data.
If you are a representative of our corporate customer, supplier or other business partner, please read our Business partners’ privacy statements, where you will find information about the processing of your personal data by Orien Trade.
Orien Trade acts as the data controller for the personal data that our customers, including website visitors, newsletter subscribers, B2B online store users or regular customers of B2B stores, as well as consumers who have participated in a consumer survey or consumer competition or make a complaint or other feedback, share with us or that we collect automatically when using the website or B2B online store in connection with or that are delivered to us through other channels, such as our social media sites, our consumer service or our partners who provide services to us.
As the controller, we are ultimately responsible for the processing of your personal data that we process. Trust is part of privacy protection, and protecting your privacy and personal data is extremely important to us. That’s why we collect your personal data only to the extent we need it to provide you with a first-class customer experience.
Please note that our website, including our B2B nline store, may contain links to content from third-party service providers, and some of the media through which you may interact with us, such as social media channels, are services provided by third parties. Such links to third-party content, as well as our presence on the services of third-party service providers, do not imply that we are affiliated with or have control over such third parties, and therefore, to the extent permitted by applicable law, we are not responsible for such content or services, their level of data protection, or the performance of such third parties. of the actions of the parties.
Why we process your personal data
We process your personal data only for the purposes described in this Privacy Statement or for the purposes otherwise indicated to you when collecting your personal data and only to the extent that it is necessary for each processing purpose described in more detail here.
We process your personal data primarily to provide you with the opportunity to use our website and its functions, including the B2B online store, to process and deliver your order, including the processing of payments, possible returns or complaints and the implementation of possible subsequent warranty measures, or to interact with you in matters related to your product orders or customer relationship, or at your request.
Depending on the context in which you interact with us, we also process your personal data for several different purposes, as described below.
The processing of your personal data as described in this Privacy Statement may be part of the contract we have entered into. For example, when you place an order in our B2B online store, you must provide us with certain personal information for the processing and delivery of your order, as defined below in this Privacy Policy. Likewise, for example, creating a user account in our B2B online store is not possible without certain personal information that we request from you when creating a user account. If you do not provide us with the personal information requested in connection with these functions, you may prevent us from fulfilling our contractual obligations, which may result in you not being able to place an order in our B2B online store or create a user account in our B2B online store.
Website and B2B online store visitors
When you visit our website or use our B2B online store, we process your personal data to provide you with the opportunity to use our website and its functions, including the B2B online store. We may also personalize the content of our website and process your personal data to show you content on our website that is relevant to you. In addition, we process personal data to develop our service and product offering and to ensure the general safety, functionality and stability of the website, including preventing and detecting possible abuses and attacks on the security of the website.
The legal basis for the processing described above is Article 6, paragraph 1, letter a of the General Data Protection Regulation, i.e. your consent, or Article 6, paragraph 1, letter f, i.e. our legitimate interest. Our legitimate interests are the aforementioned purposes.
The collection and processing of your personal data on our website is mostly done using automatic technical means, such as cookies and other similar technologies. For more information on the use of cookies on our website, see our Cookie Policy.
Registering and placing orders in our B2B online store
Our B2B online store is part of our website, so what has been said above about the processing of personal data of visitors to our website and B2B online store applies to you when you register and place orders in our B2B online store. When you decide to register as our B2B online store customer or place an order through the B2B online store, we process your personal data primarily to enable the registration of a user account or to process and deliver your order to us, including processing payments, possible returns or complaints, and implementing possible subsequent warranty measures. We also process your personal data to send you updates about your orders, such as information about the delivery of your orders.
In addition to the above, we process your personal data for the purpose of managing, analyzing and developing the customer relationship between you and us, for example to provide customer service, implement customer communications and send questionnaires. This way we can measure your satisfaction with, for example, our website and B2B online store as well as our products and delivery process. We may also process your personal data to notify you of new and interesting products, special offers and updates on our website or B2B online store within the limits of applicable law and to the extent that you have not opted out of receiving such communications.
In connection with these processing activities, the legal basis for the processing of your personal data is either compliance with the agreement between us, compliance with legal obligations concerning us, or our legitimate interest.
Contractual and statutory obligations : The processing of certain personal data is necessary in order for us to fulfill the contract we have concluded with you. In this case, the legal basis for the processing is Article 6, paragraph 1, subparagraph b of the General Data Protection Regulation. For example, when you register as a customer or place an order in our B2B online store, we must process your personal data in order to fulfill our contractual obligations and register your user profile or deliver your order in accordance with your request and the agreement between us. When you place an order, it also creates certain legal obligations for us, which are related to, for example, product safety, the quality of our products and product returns, in which case the legal basis for processing is Article 6, paragraph 1, subparagraph c of the General Data Protection Regulation.
Our legitimate interest : We process your personal data on the basis of our legitimate interest (Article 6, Paragraph 1 Subsection f of the General Data Protection Regulation), in particular to offer you a first-class customer experience in our B2B online store and in other media, to offer the most relevant online and newsletter content, and to manage, develop and analyze the customer relationship between us.
Consumer subsidies
We make use of consumer surveys, among other things, to adapt the development of new products and our marketing products to better meet the perceived needs of our customers. When conducting consumer surveys, we generally use third-party service providers to recruit respondents based on certain characteristics we define for the survey and to collect responses from respondents. After collecting the information, our service providers compile the results of the survey and deliver them to us in an unidentifiable form. Although we usually do not process data in an identifiable form, we do act as the data controller of respondents’ personal data collected by our service providers.
However, sometimes we conduct research and analyze the results ourselves.
The legal basis for processing is your consent (Article 6(1)(a) of the General Data Protection Regulation) or our legitimate interest (Article 6(1)(f) of the General Data Protection Regulation). Our legitimate interest is to improve and develop our products and services and promote our business. In this context, the legal basis for the processing of the sensitive information you provide is your express consent (Article 9, Paragraph 2, Subsection a of the General Data Protection Regulation).
Complaints and other feedback
When you make a complaint or give us other feedback about our products, we usually also process your personal data. As a manufacturer of cosmetic products, we are obliged to collect information about skin irritations caused by our products and, if the unwanted effect caused by the product is serious, to report it to the competent authorities. When we have responded to the consumer and otherwise handled the matter in such a way that we have been able to ensure that the consumer is satisfied with the end result, we close the case and anonymize the personal data related to the case. If serious unwanted effects are reported to the competent authorities, the data subject is not identified. In addition to handling the consumer’s complaint and reporting serious adverse effects to the competent authorities, we may further process the information reported by the consumer for research and development purposes, but only in de-identified form.
If you provide us with sensitive information, such as information about allergic reactions you have suffered or other health-related information, the legal basis for processing is your explicit consent (Article 9(2)(a) of the General Data Protection Regulation). In other cases, the legal basis for the processing is either a statutory obligation towards us (Article 6, paragraph 1, subparagraph c of the General Data Protection Regulation), or our legitimate interest (Article 6, paragraph 1, subparagraph f of the General Data Protection Regulation) to improve and develop our products
Other processing of the consumer’s personal data
| The context or purpose of the processing | Description | Legal basis |
| Newsletter subscriptions | You can subscribe to our newsletter and receive information about our latest products and offers. | Consent (Article 6(1)(a) of the General Data Protection Regulation) or our legitimate interest (Article 6(1)(f) of the General Data Protection Regulation). |
| Loyalty program | You can register as a loyal customer of our B2B online store and thus receive updates about our B2B store and the campaigns and offers we offer to our loyal customers. | Consent (Article 6(1)(a) of the General Data Protection Regulation). |
| Consumer service | You can contact our customer service through several different channels, such as the online form on our website. We process your personal data to respond to you. We do not process your personal data when we process the content of your message internally, unless it is necessary for us. | Our legitimate interest (Article 6(1)(f) of the General Data Protection Regulation) to carry out actions that are part of the normal course of our business, so that we can respond to requests or inquiries from potential or current customers and further process the matter internally. |
| Consumer competitions | You can participate in the consumer competition we organize through various channels and win, for example, our products. We process your personal data in order to organize the competition, to contact the winners and to reward the people who participated in the competition. | Consent (Article 6(1)(a) of the General Data Protection Regulation). |
Other processing of personal data
In addition to the aforementioned processing purposes, we may process personal data collected for each individualized purpose for other legitimate interests, such as protecting our assets, preventing and investigating suspected abuses, defending or pursuing legal claims, analyzing and compiling statistics for business purposes, developing our products and business, reorganizing our business, and for scientific research purposes, but only to the extent that the processing is proportionate to the interest of the data subjects and the processing can be considered to be in accordance with their reasonable expectations. To the extent that the identification of the data subject is not necessary for these processing purposes, we use the information for these purposes in an unidentifiable form.
The groups of personal data we process
When you give us feedback about our products, return a product to us, or in another similar situation share your personal information with us, this personal information may contain sensitive personal information, such as information about allergic reactions caused by the use of our product or other health-related information.
You may also give us your personal data in other contexts, for example when you are in contact with us in our customer service channels or on social media, in which case we process the content of the communication between us and other personal data that you give us in these contexts.
Website and B2B online store visitors
When you visit our website or the website’s B2B online store, we automatically collect certain information about your terminal device and information about your visit, such as your IP address, information about your operating system and user interface, the type, version and language of your browser, the time of the visit, the referring page and the amount of data transferred. The collection and further processing of your personal data on our website mainly takes place with the help of automatic technical means, such as cookies and other similar technologies. For more information on the use of cookies on our website, see our Cookie Policy.
Registering and placing orders in our B2B online store
When you create a user account in our B2B online store, you will be asked to provide certain personal information, such as: name, contact information, date of birth, phone number, password, and billing and delivery information. You can also voluntarily provide us with information about your interests and your consent to receive direct marketing. Your user account information is constantly updated (for example based on your purchase history).
When you place orders in our B2B online store, we process certain personal data and information related to you and the order you placed, such as: user account information (or your name, shipping and billing address and phone number), the type and quantity of products you ordered, purchase price, order date, order status, payment method and payment related details, product returns and related customer service requests.
Consumer subsidies
The data collected varies per study, but usually they contain at least personal data, based on which we can filter the respondents who meet the characteristics we defined for the study in question (for example, when testing the anti-aging concept, we look for respondents from a certain age group). This filtering information may include, for example, information about gender, age group, skin type or skin problem. Depending on the research, other personal data may also be collected.
Transfer or disclosure of your personal data
Why do we transfer or disclose your personal data?
We may transfer or disclose your personal data to other companies of the Orien Trade group or to external service providers as mentioned below.
We use external service providers, for example for technical maintenance or hosting of our B2B online store, in connection with which these service providers process personal data on our behalf as processors. We require that all these parties process personal data in accordance with our instructions and this Privacy Statement. We can also hand over personal data to our partners within the limits permitted by law, for example for making deliveries, invoicing or marketing. For example, we use the services of our partners to fulfill orders (such as payment services offered by banks or credit card companies or delivery and distribution services offered by shipping companies). We only provide these partners with the information necessary to provide the agreed services, such as payment processing and order delivery. If we advertise via social media channels (e.g. Facebook, Instagram), we may provide information about registered users (e.g. device and usage data, advertising and cookie IDs, e-mail addresses) in encrypted form to the relevant social media channel service provider.
In addition, we may disclose your personal data if required by law (e.g. reporting serious side effects or skin irritation to the competent authorities) or if we believe in good faith that the disclosure of personal data is necessary to comply with the provisions of the law or to comply with a legal process directed at Orien Trade or to protect and defend Orien Trade’s rights or property.
We may share a limited amount of personal data within the Orien Trade Group for legitimate business purposes, such as to develop and improve our business or products and to analyze and improve the customer experience. If we sell all or part of our business or otherwise reorganize our business, we may disclose and transfer personal information to purchasers and their advisors within the limits set by applicable law.
International transfers of personal data
We use partners in business that requires the processing of personal data, and in this context we or our partners may, in accordance with the applicable legislation, process personal data anywhere in the world and thus transfer personal data also outside the EU or the EEA. When personal data is transferred to countries where local data protection legislation does not provide an adequate level of data protection, the transfers are based on appropriate safeguards, such as standard contractual clauses approved by the European Commission or a competent supervisory authority. You can find the commission’s standard contract clauses here .
If you would like more information about the appropriate security measures we use, you can email us at info@orientrade.com.
How do we protect your personal data?
We have implemented appropriate technical and organizational measures to protect the security of your personal data and to ensure that your choices regarding the purpose of use are followed. We protect your data from loss, misuse, unauthorized access or publication, modification or destruction by appropriate technical measures, such as firewalls.
We do not share your personal data outside of Orien Trade, its subsidiaries, branches or other partners, except for the circumstances and purposes mentioned in this Privacy Statement or if otherwise is required within the framework of mandatory and applicable legislation. Orien Trade, its subsidiaries, branches and other partners store personal data on password-protected servers. Only those persons whose job tasks require the processing of personal data have limited access to them.
How long do we keep your personal data?
The storage period of collected personal data depends on the legal basis and processing purpose for which the data was collected. We retain your personal data as long as necessary to fulfill the processing purposes for which it was collected as defined in this Privacy Statement, in particular to fulfill our contractual and statutory obligations (e.g. returns and limited warranty periods). If the processing is based on a legitimate interest, we will keep your personal data as long as our legitimate interest can be considered valid or until you request the deletion of your personal data.
For more information on retention periods, see the table below.
Storage periods
The general retention periods for consumers’ personal data in different contexts are as follows. Data is not necessarily stored for the same length of time for all processing purposes, and the maximum data storage period has been brought up in this secti
| Group of registrants | Retention period |
| Website and B2B online store visitors | According to our cookie policy. |
| Registered B2B online store users | If you choose to delete your user account, we will delete all personal information associated with it, unless the information falls into another category subject to longer statutory or other mandatory retention periods (such as information about your purchase orders). We reserve the right to delete your user account and most of the personal data associated with it after it has been inactive for two years. |
| Consumers who place orders in our B2B online store | We store information about product orders and related payment information in accordance with the requirements of Finnish accounting legislation, i.e. for the current year and six years. |
| Consumers who post product reviews or related questions in our B2B online store. | Until the product is removed from our selections or until the data subject requests removal or withdraws their consent. |
| Consumer survey respondents | We will keep the collected information as long as it is necessary for the purposes of that study, but usually the information is kept without personal identifiers. |
| Consumers who make complaints, give other feedback or claim skin irritation. | We keep the collected information in an identifiable form only as long as we have responded to the consumer and handled the matter in another way so that we have been able to ensure that the consumer is satisfied with the end result. Once the case is closed, we remove direct identifying information from the data. Anonymized feedback data is stored for at least 10 years. |
| Newsletter subscribers | Until the recipient cancels the order. |
| Registered users contact our consumer service | We keep the collected information in an identifiable form only as long as we have responded to the consumer and handled the matter in another way so that we have been able to ensure that the consumer is satisfied with the end result. After the processing of the matter is over, we either delete the direct identifying information from the data or we delete the communication in its entirety, depending on whether it is necessary for us to further process the matter internally. We do not process your personal data when we process the content of your message internally, unless it is necessary for us. |
| Participants in the consumer competition | We will keep the information collected for as long as it is necessary for the purposes of the competition in question, but usually for a maximum of three months. |
| Customers who contact us via social media | In accordance with the terms of use of the social media platform in question. |
When we no longer need the collected personal data, the data is securely destroyed or irreversibly anonymized. If you delete your user account, we will delete all data stored about you, unless contractual or legal retention periods apply. If the complete deletion of your data immediately after you have deleted your user account is not possible or necessary for legal reasons, access to the data for further processing will be blocked.
We may also retain certain personal data as necessary after the end of the original processing purpose, if such retention of personal data is required to comply with other applicable legislation, or if we need personal data to prepare, present or oppose a legal claim.
What rights do you have?
The following is a summary of the rights you have as a registrant under EU data protection law. “Registered” means natural persons whose personal data we process, i.e. our customers and other consumer groups whose personal data we process in the manner defined in this Privacy Statement. Some of these rights are complex and subject to certain exceptions, and in order to keep this Privacy Statement concise, not all details have been included in this section.
Those registered have the right to get access to the data processed by us as the data controller and the right to have incorrect personal data corrected. If you want to use your right of access to information or rectification, proceed as described below.
Your request for access to information or rectification of information must be submitted in writing or in electronic form, and must be signed and sent using the contact information specified in this Privacy Policy. The request must contain the basic information necessary to find the requested information. Once we have received and processed the request, we will send you a copy of the personal data by post or electronically. We reserve the right not to fulfill your request if the request is clearly unfounded. If you request multiple copies, or if you wish to make more than one request per year, we may charge a reasonable fee based on the administrative costs of fulfilling your request.
As a registered user, you also have the right at any time to ask us to delete your personal data that we process, and we are obliged to delete the data if there is no longer a legal basis for processing it. Please note that certain data we process is subject to statutory retention requirements and, despite a deletion request, we cannot delete that data before the end of the statutory retention period. As a registered user, you also have the right to prohibit the processing of your personal data if the data has been processed based on our legitimate interest, and we are obliged to stop processing the personal data in question, unless we can present compelling legal grounds for continuing the processing of the personal data in question. You may also have the right to ask us to restrict the processing of your personal data.
If you have given your consent to certain types of processing operations, you can withdraw this consent at any time with future effects. Such withdrawal does not affect the legality of the processing prior to the withdrawal of consent.
If you want to use the above-mentioned rights, please contact us using the contact information mentioned at the beginning of this privacy statement.
If you consider that the processing of your personal data violates data protection legislation, you have the right to file a complaint with the authority supervising data protection. You can do so in the EU Member State where you have your permanent residence, place of work or the place where the alleged infringement takes place.
Summary
We reserve the right to update and change this Privacy Policy. Unless otherwise required by mandatory applicable law, we cannot personally send changes to this Privacy Statement to data subjects personally, so we encourage you to check this Privacy Statement from time to time for any changes.
If for any reason you believe that we have not complied with the above rules, please notify us by email at info@orientrade.com and we will do our best to investigate and correct the problem as soon as possible.