Preamble
Your privacy is important to Aurora Trading OÜ (“Aurora Trading”, “we”, “us” or “our”). This Privacy Policy (the “Privacy Policy”) explains what Personal Data (as defined below) we collect, how we may use and manage it and the rights you have in relation to your Personal Data.
Aurora Trading controls and intends to keep the website (which includes any of its webpages) up to date. Aurora Trading does not guarantee the accuracy, comprehensiveness or quality of the information on the website. No content on the website may be interpreted as an offer or promise to contract. Aurora Trading reserves the right to modify, add to and cancel individual pages or the whole content of the website without any notice, as well as to suspend any access to the website temporarily or definitively.
Aurora Trading shall not be responsible for any third-party content on the website (e.g. in the guestbook, forum, discussion or any similar platform), as applicable.
Any user or visitor of the website (the “User”) will be solely responsible in case of implementation of any process resulting in downloading any information or content from the website. By visiting the webpage, the User accepts the provisions set out in this policy.
Before you provide us with any Personal Data or browse our websites, you should read through this Policy in full and make sure that you are comfortable with our privacy practices.
For the purposes of applicable data protection and privacy laws, the data controller is Aurora Trading (register code: 16237000) of Männimäe/1, Pudisoo küla, Kuusalu vald, Harju maakond, Estonia 74626.
We reserve the right to make amendments to this Policy at any time without notice. It is your responsibility to check the Aurora Trading website for any changes and before submitting any information to us.
The content and structure of the website are protected by copyright. Any reproduction or use of the content, which includes in particular graphics, sound recording, photography, films, video and/or text, irrespective or its form or support, is not allowed without prior written permission of Aurora Trading.
Personal data
Personal Data refers to any information that can be used to personally identify you. This may include, for example, your name, postal address, e-mail address, phone number, date of birth, job title, photographic identification, age or gender, communications with you (including notes from meetings) and financial and payment information.
Personal information is only collected with your consent, and where it is reasonably necessary to comply with the law or if it is required to administer aspects of the relationship between you and us.
We collect Personal Data from a range of individuals in the context of our business activities, including:
representatives of our suppliers, customers and other business contacts;
contractors;
users of our websites;
individuals who contact us by any means;
recording and retaining certain telephone conversations where we are required to do so to comply with our regulatory obligations; and job applicants.
We obtain Personal Data:
which you knowingly and voluntarily disclose to us, both online and offline, notably when you:
visit our websites and / or complete one of our web forms;
visit our premises;
communicate with us via any means, including but not limited to telephone, email and through the use of social networking websites, third party apps or similar technologies.
from third party sources, e.g. employers, authorized representatives, agents or third parties who are authorized to share Personal Data, as well as publicly available sources of information e.g. address validation software, telephone directories, as well as our agents or other third parties who have identified you as a potential purchaser of our products or services.
When you use our sites at https://www.auroratrading.ee we collect certain standard information that is sent by your browser to the websites, e.g. your IP address, browser type, operating system, language, time zone setting, access times and any referring website addresses.
We may collect your Personal Data for a range of different purposes as a prospective or existing customer or counterparty, including:
to support our procurement and onboarding processes, including complying with our internal policies (particularly policies designed to prevent money laundering and sanctions violations);
to provide our products and services to you, or to provide you with a quote or offer for our products and services;
to communicate with you about a potential or existing engagement with Aurora Trading;
to answer your enquiries and provide any information or documents you ask for;
to ensure that content from the websites is presented in the most effective manner for you and for your computer, including carrying out analytics in relation to the use of the websites;
for administrative, planning, product or service development and delivery purposes;
to comply with our legal and regulatory obligations, which may include the disclosure of certain information and/or recordings of telephone conversations to regulatory authorities;
for other business-related purposes, including negotiating contracts, managing accounts and records, supporting corporate social responsibility activities, legal, regulatory and internal investigations and debt administration; and
to update our records and keep your contact details up to date.
If you choose not to provide your Personal Data to us, we may not be able to engage in a business relationship with you, either partly or at all.
In accordance with the purposes for which we collect and use your Personal Data, as set out above, the legal basis for us processing your Personal Data will typically be one of the following:
your consent;
the processing is necessary in connection with the performance of a contract that we have in place with you or other individuals;
our, or our third parties’, legitimate business interests; or
compliance with our legal obligations.
The data that we collect from you may be transferred to, and stored in, a country other than your own and that such country may provide a lower level of data protection requirements than your own country. By submitting your Personal Data, you agree to this potential transfer to a country other than your own.
Whenever we transfer Personal Data across borders, we will take legally required steps to ensure that adequate safeguards are in place to protect your Personal Data and to make sure that it is treated in accordance with this Privacy Policy.
You acknowledge and understand that the transmission of information via the internet is not completely secure. Although we will take reasonable and appropriate steps to protect your Personal Data once we have received it, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorized access.
Aurora Trading does not guarantee complete data security under any circumstances.
We may disclose your Personal Data to third parties during the course of business, including:
your authorized representatives (agents, consultants, intermediaries);
financial institutions (for payment processing);
government and regulatory authorities (where required or authorized by law);
our service providers, such as information technology suppliers, contractors, debt collection agencies and our professional advisors, such as accountants, auditors and lawyers;
to protect any intellectual property rights in any materials displayed on or otherwise available from our websites;
to respond to a legal request or comply with a legal obligation; and
to enforce the terms of use of our websites.
We may also disclose your Personal Data to third parties:
In the event that we sell, merge or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.
If Aurora Trading or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be transferred.
We may decide to allow our website users to share comments, postings, testimonials, or other information. If you choose to submit such information to us, the information that you submit may be available generally to the public. Information that you provide in these areas may be read, collected, and used by others who access them.
We may also share non-Personal Data with other third parties that are not described above. When we do so we may aggregate or de-identify the information so that a third party would not be likely to link data to you, your computer, or your device. Aggregation means that we combine the non-Personal Data of numerous people together so that the data does not relate to any one person. De-identify means that we attempt to remove or change certain pieces of information that might be used to link data to a particular person.
International transfers of your Personal Data
The disclosures discussed above include transfers of Personal Data which is subject to Swiss, UK or European Economic Area data protection laws to countries outside Switzerland, the UK and the EEA. Aurora Trading is a global company and we have relationships with service providers, counterparties and governmental authorities in many countries. This includes transfers to countries which are not regarded by the European Commission (or the equivalent authorities in other jurisdictions) as ensuring an adequate level of data protection, but we ask that these third parties hold, use and disclose your Personal Data in accordance with any applicable data protection laws.
Data retention
We will keep your Personal Data for as long as we need to keep it for legal compliance or business purposes. Please contact Aurora Trading for more information about our record retention practices.
We take reasonable steps to ensure the Personal Data we collect, use and disclose about you is correct, complete and relevant for the purposes for which we collect it.
Applicable data privacy laws give rights to individuals in respect of Personal Data that organizations hold about them.
Third Party Websites
The websites may, from time to time, contain links to and from the websites of our partner networks and affiliates, or of other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.
Cookies
The website operated by Aurora Trading may use cookies, as commonly used on any webpages. The website may include persistent and/or session cookies, as specified hereafter.
When visiting the webpage, the User is requested to confirm the approval of the use of cookies.
Aurora Trading reserves the right to make any changes to its policy concerning the use of cookies. The continued access to the website and the corresponding approval of the cookies by the User shall also apply to any such changes.
For general information purposes, cookies are files containing small amounts of information which are downloaded to the device that the User uses when visit a website, such as Aurora Trading website, as applicable from time to time.
Aurora Trading intends to use the information contained in the cookies to recognize the User’s device when visiting the website, to improve the website usability, to allow the User to share webpages such as LinkedIn, Facebook or Twitter and to further analyze the use of the website (including for statistical analysis). Aurora Trading may use persistent cookies or session cookies. They work in a similar way, but have minor differences.
Persistent cookies remain on the User’s device after the User has closed the browser and allow a website to remember the User’s actions and preferences. They are stored by the browser and remain valid until their set expiry date (unless the User deletes them before such expiry date).
Aurora Trading may use persistent cookies in a few ways, for example, to make it easier for the User to log into any platform available on the website, as applicable, and for Aurora Trading to recognize and warn the User if a new login occurs from a new machine (that has no Aurora Trading cookie on it). Aurora Trading may also use persistent cookies to allow Aurora Trading to analyze visits to the website, for the ultimate purpose of understanding of how Users arrive at and use the website and improve Internet search results.
Session cookies last only for the duration of the User’s visit and are deleted when the User closes the browser. They facilitate tasks such as allowing a website to identify that a user of a particular device is navigating from page to page, supporting website security or basic functionality.
In principle, most of the cookies used by Aurora Trading on the website are session cookies. For example, they help us to improve the security of any session and keep the User signed in to the relevant User account, as applicable, while moving between functions and pages.
Unless otherwise specified, Aurora Trading may use any third-party cookies.
Any data collected through the use of cookies is anonymized and no individual tracking occurs.
The User may block or restrict cookies set by the website through the browser settings on each device used by the User to access the Internet. However, blocking or restriction of cookies is expected to cause significant disruption in the use of the website, which would not operate in a suitable manner or not operate at all.
Any relations deriving from the use of the website by the User shall be exclusively submitted to Estonian law.
Any disputes between a User and Aurora Trading shall be submitted to the exclusive competence of the ordinary Courts of the Republic of Estonia.
Last updated 28 May 2021
