Application Privacy Policy

1. What is covered by the Privacy Policy?

1.1 This Privacy Policy (the “Privacy Policy“) for Fontakt (“Fontakt“, “we“, “us“, or “our“) describesthe relationship, rights, and obligations between Fontakt and the user of Fontakt`s mobile App (the “App User”) when providing, offering, downloading, and using Fontakt`s mobile App (the “App“).

1.2. By agreeing to the Privacy Policy, the App User confirms that he or she has read the Privacy Policy and the Data Protection Conditions of Fontakt (the “Data Protection Conditions”) and agrees to comply with them. Data Protection Conditions are available at https://fontakt.com/en/data-protection/. If the Privacy Policy is not accepted by the App User, it is not possible to use the App.

1.3. From the moment the App User indicates that he/she accepts the terms of the Privacy Policy, a contract is concluded between Fontakt and the App User in accordance with the Privacy Policy.

1.4 The Privacy Policy does not apply to any third-party program, service, website, or mobile App, even if used and/or accessed by the App User through the Fontakt website www.fontakt.com  (“Fontakt website“) and/or the App. The Privacy Policy and the Data Protection Conditions do not apply to personal data provided and/or submitted by the data subject himself or herself to third parties. Where the Privacy Policy or the Data Protection Conditions do not apply, the data subject must, before disclosing his or her personal data to third parties, consult the applicable third-party terms and conditions or privacy policies published on the relevant website, mobile application and/or that are applicable in relation to any other service used by the data subject.

1.5 Fontakt has the right to unilaterally change the Privacy Policy at any time, if it is necessary for the operation of the App, including its updates, or due to changes in legislation. If the Privacy Policy changes, Fontakt will display the changed Privacy Policy to the App User in the App and the App User must re-accept the Privacy Policy to continue using the App. If the App User does not agree with the amended Privacy Policy, he or she will not be able to use the App.

2. What is the App?

2.1. Fontakt App is a mobile application that allows a person who has registered an account as an App User and has ordered a free or paid package of the App in accordance with the Privacy Policy to:
1) contact by phone the contact persons of the specific responsibilities of the companies represented in the App database; and
2) ask Fontakt to arrange a meeting with the contact persons of the specific areas of responsibility of the companies represented in the App Database (referred to throughout the Privacy Policy as the “App“).

2.2. The App, including its content, belongs to Fontakt OÜ, which is also the provider of the App (registry code 11091789; address Pärnu mnt 139c, 11317 Tallinn, Estonia; e-mail abc@fontakt.com, phone +3726865555) (“Fontakt“).

2.3 The App can be accessed on the following platforms
1) Google Android, by accessing the Google Play store listing: https://play.google.com/store/apps/details?id=app.fontakt
2) Apple iOs, by accessing the Apple Store listing: https://apps.apple.com/ee/app/fontakt/id1586636997

3. Who can use the App?

3.1. Any natural person at least 18 (eighteen) years of age may use the App and become an App User. Any natural person at least 16 (sixteen) years of age may also use the App and become an App User if he or she has the prior consent of his or her legal representative. By agreeing to the Privacy Policy, the App User confirms that he or she is at least 18 (eighteen) years old or at least 16 (sixteen) years old and has the consent of his/her legal representative to use the App and to become an App User.

4. For what purposes and in what ways can the App be used?

4.1. With the help of the App, the App User is allowed to contact the contact persons of the companies only for work- and business-related questions and issues and only in business areas directly related to the company contacted and/or only in areas of responsibility of the contact person contacted, whereby the App User is responsible for the legality of such contact. Among other things, the App User is obliged to check and make sure that he or she has a legal basis for processing such personal data and that other data protection requirements have been met. The App allows to make phone calls only on weekdays and during normal business hours (Mon-Fri, 9 am – 6 pm GMT +3 in summer and GMT +2 in winter).

4.2. The App User is prohibited from calling to the contact persons of the companies or requesting a meeting with the contact persons for the purposes of advertising, direct marketing, personal communication, etc., which have no direct work and business connection with the respective company and specific responsibilities.

4.3. The App User is prohibited from copying or attempting to copy or otherwise obtain possession of the App or transfer any data to a third party in any way.

4.4. The App User may make calls and request appointments only in person and manually using the App. The App User is prohibited from using automated tools and programmes, such as Bots, etc., or forwarding calls or appointments to other persons while using the App.

4.5. The App User is prohibited from using the App for any purpose other than as expressly permitted in the Privacy Policy.

5. What do I need to use the App and how do I subscribe to the App package?

5.1. To use the App, the App User must download the App to his/her own smart device and register his/her App User account in the App. If the App User wishes to use the features of the paid packages of the App, the App User must order the corresponding paid package. The App User can use the App to a limited extent without ordering a paid package, but in this case the App User will not be able to use the features of the App that are intended only for subscribers to paid packages.

5.2. In order to use the App, it is necessary to have an Internet connection, mobile data connection or Wi-Fi provided by the App User.

5.3. The App User may download the App from the App Store or Google Play, depending on the App User’s smart device. Fontakt does not guarantee that the App can be downloaded from these environments at any time.

5.4. To use the App, the App User must register his/her App User account by following the instructions provided when opening the App. When registering an App User account, the App User must provide only correct and true information about himself or herself.

5.5. If the App User wishes to use the features of the paid packages of the App, the App User must select the appropriate package available to him or her in the App and pay a package fee to Fontakt for the respective package, using the payment options available in the App. The contents of the packages are described in the App. It is not possible for the App User to order packages for a shorter or different period than the package period indicated in the App. The App User can start using the package of the App immediately after the package fee paid by the App User has reached Fontakt. At this time, Fontakt will also send the App User an automatic notification to the App User’s e-mail address, which the App User submitted to Fontakt upon registration of the App User account. In the first month of subscription, the App User can use the package for which he/she paid package fee until the end of the current calendar month for which the package fee was paid. The fee for the first order month is calculated in proportion to the number of days remaining in the first order month. Thereafter, the periodic package fee will be deducted from the App User’s account on the first day of each month, and the App User will be able to use the package during the calendar month for the package fee. The App User, including the App User who is a Consumer, has no right to withdraw from the contract after the payment has been made and the paid package fee will not be refunded to the App User, except in the case provided for in clause 9.2 of the Privacy Policy.

5.6. If the App User wishes to use additional paid features of the App outside the package, the App User must select the appropriate paid feature available in the App and pay a fee to Fontakt for using it, using the payment options available in the App. The content of additional paid features is described in the App. The App User can start using the additional function of the App immediately after the fee for the additional function paid by the App User has reached Fontakt. At this time, Fontakt will also send the App User`s e-mail address an automatic notification, which the App User submitted to Fontakt upon registration of the App User account. In the first month of subscription, the App User can use the selected function for which he/she paid the additional fee until the end of the current calendar month for which the additional fee was paid for. The fee for the first order month is calculated in proportion to the number of days remaining in the first order month. Thereafter, the periodic fee for the additional function will be deducted from the App User’s account on the first day of each month, and the App User may use the additional function for that additional function fee during the calendar month. The App User, including the App User who is a Consumer, has no right to withdraw from the contract after the payment has been made and the fee paid will not be refunded to the App User, except in the case provided for in clause 9.2 of the Privacy Policy.

5.7. Fontakt will send the App User a payment confirmation confirming the payment of the App package fee and the additional function fee to the e-mail address indicated by the App User upon registration. The corresponding document with the payment confirmation is available to the App User in the App and can also be downloaded in the App.

6. What functions does the App perform?

6.1. By using the App, and in accordance with the more detailed description of the package provided in the App, the App User can:
1) contact by phone the contact persons of the specific responsibilities of the companies represented and available in the App database; and
2) ask Fontakt to arrange a meeting with the App User`s selected contact persons of the specific areas of responsibility of the companies represented and available in the App database.

6.2. In order to comply with the principle of minimization arising from data protection regulations, the App User does not see the companies contact persons telephone numbers or names when using the App.

6.3. Fontakt updates the data of the companies represented in its databases and their areas of responsibility over time.

6.4. Fontakt does not guarantee that every company of interest to the App User is present in the App.

6.5. Fontakt does not guarantee that for each company represented in the App there is a responsibility area of interest for each App User.

6.6. Fontakt will use its best endeavours to update, at least on an annual basis, the contact details of the companies represented in the App and their respective areas of responsibility, but Fontakt does not guarantee that these details are correct at all times.

6.7. Fontakt does not guarantee the around-the-clock and error-free operation of the App.

6.8. Fontakt provides the App User with support via Fontakt website to solve questions and problems, but Fontakt does not guarantee the around-the-clock operation of the support or the solution of all questions and problems. The App support provided by Fontakt is available in English and Estonian.

6.9. Fontakt may change the App, including its functions and content, at any time in its sole discretion, if necessary for the operation of the App or its updates, or due to changes in legislation.

6.10. Fontakt has the right to restrict the App User`s use of the App, including the number of calls and appointment requests numbers to be made or target groups of calls and appointment requests, if this is necessary for the operation of the App or to protect the rights of third parties, including pursuant to the Data Protection Conditions.

7. How is the secure use of the App ensured?

7.1. Fontakt will make efforts to ensure the secure use of the App but cannot fully guarantee it. Fontakt implements the following security measures to increase the security of the App: all passwords in the App are encrypted using Bcrypt and Blowfish for other sensitive data; Renewable tokens are in use when accessing the App, so the App User has a different token for each session; no credit card data is stored on Fontakt servers, all credit card payments are covered by Stripe service.

7.2. It is the App User’s responsibility to ensure protection against virus and malware protection when using the App.

7.3. The App User is obliged to take all necessary measures to prevent third parties from accessing the App. The App User, through whose smart device the actions were performed, is responsible for the actions performed by third parties through the App.

7.4. The App User is prohibited from damaging the App or third parties through any means, including but not limited to removing or attempting to remove security measures or restrictions used in the App.

7.5. The App will from time to time require software updates to improve or enhance its functionality and security. If the App User does not agree to such software updates, not all features of the App may work.

8. How to stop using the App and what are Fontakt’s rights to stop offering the App?

8.1. In order to stop subscribing to a paid package or feature of the App prospectively, the App User must cancel the subscription in the App by following the instructions provided in the App. If the App User submits a cancellation request in the App to terminate the subscription of a paid package or function, his/her subscription will be cancelled from the first day of the following calendar month and the App User will no longer be charged for the respective package or function.

8.2. The App User has the right to delete the App from his/her device at any time but deleting the App from the device will not delete the App User’s account or cancel the subscription to the service. The App User has the right to delete his/her App User account through the App at any time but deleting the App User account also requires the App User to cancel the subscription to the paid package, the appropriate instructions for which shall be provided to the App User through the App prior to deleting the App User account.

8.3. Fontakt has the right to unilaterally terminate the provision of the App by giving the App User 1 calendar months’ prior notice.

8.4. Fontakt has the right to immediately, without prior notice restrict, suspend, or terminate the App User’s use of the App if Fontakt suspects or has reason to believe that the App User does not comply with the Privacy Policy or violates the Data Protection Conditions, legislation or third-party rights or receives complaints about the App User.

8.5. In the event of termination of the use of the App or termination of provision of the App, the obligations of the App User already incurred from the Privacy Policy shall continue to apply.

9. If and in which cases will the App User be refunded the App Package Fee?

9.1. Fontakt does not return to the App User the package fee paid by the App User, including not for the period of time the App User has not yet used the App. Among other things, Fontakt will not refund the paid package fee if the App User no longer wishes to use the App or if the App User can no longer use the App due to the App User’s disagreement with the amended Privacy Policy, software updates or in case Fontakt has restricted, suspended, or terminated the App User’s use of the App in accordance with clause 8.4 of the Privacy Policy.

9.2. Exceptionally, Fontakt will return the package fee paid by the App User to the App User if Fontakt terminates to offer the App solely due to circumstances attributable to Fontakt and for this reason the App User is unable to use the App during the period for which the App User has already paid the package fee. In the event of such a situation, Fontakt will contact the App User with the contact information provided by the App User upon registration of the App User account and will return the package fee paid for the period of time during which the App User cannot use the App.

10. What are the responsibilities associated with the App?

10.1. Fontakt shall not be liable for any costs or other damages arising from the use of the App, except to the extent that the applicable legislation does not allow the exclusion or limitation of Fontakt’s liability.

10.2. Fontakt is not responsible for the information provided by third parties or actions performed through the App.

10.3. Fontakt is not responsible for any possible damage resulting from the infection of the App with a virus or malware or their spread through the App.

10.4. In no case shall the amount of damages paid by Fontakt exceed the amount of package fees paid by the App User to Fontakt for the use of the App during the last 3 months until the moment when the App User notifies Fontakt of his/her claim for damages.

10.5. Fontakt is not responsible for the processing of personal data by the App User in the App.

10.6. Fontakt reminds that in case of non-compliance with the terms of the Application, the consumer can rely on the legal remedies provided by law. Pursuant to the Law of Obligations Act in force in Estonia, if the debtor has breached the obligation, the creditor may: 1) demand performance of the obligation; 2) refuse to perform his or her due obligation; 3) demand compensation for damage; 4) withdraw from the contract or cancel the contract; 5) lower the price; 6) in the event of delay in the performance of a financial obligation, demand interest on arrears. In the case of consumer sales, the seller is liable for non-compliance with the terms of the contract which becomes apparent within two years of delivery of the thing to the buyer. In the case of consumer sales, the lack of conformity which arose within six months from the date of delivery to the purchaser shall be presumed to have existed at the time of delivery, unless such presumption is incompatible with the nature of the thing or defect. In the case of a sale to the consumer, the consumer must notify the seller of the lack of conformity within two months of becoming aware of the lack of conformity.

11. What are the App User’s responsibilities when using the App?

11.1. The App User is liable for any damage suffered by Fontakt and caused by the App User’s breach of the Privacy Policy, legislation, or the rights of third parties.

11.2. The App User is an independent controller of personal data when using the App. This means that the App User is responsible for making sure that he/she has a legal basis for contacting the contact persons of the companies through the App and that all other conditions for such processing of personal data are met. In the event of a claim or fine being imposed on Fontakt in relation to the App User’s processing of personal data in the App, the App User shall indemnify Fontakt in full against all such claims, fines, and other possible amounts.

12. How and which kind of personal data of the App User is processed by Fontakt?

12.1. Fontakt processes the App User’s personal data in the manner described in the Data Protection Conditions. The Data Protection Conditions are available at https://fontakt.com/en/data-protection/

12.2 Fontakt collects and processes the App User’s personal data only if they are adequate and necessary for the legitimate purposes for which they are processed. The purposes for which the App User’s personal data is processed, the legal basis for the data processing and the retention periods are described in the Data Protection Conditions. App User’s personal data may be kept longer than the period set out in the Data Protection Conditions only if:
12.2.1 there are reasonable grounds to suspect that the App User has committed a breach and Fontakt needs the App User’s data to investigate the possible breach.
12.2.2 they are necessary for the proper resolution of a dispute or complaint.
12.2.3 they are necessary to ensure the security of the App, e.g., to detect suspicious activities by the App User.
12.2.4 for other specific reasons, conditions or cases provided for by law.

12.3 Taking into account the services, functions of the App and other communication channels offered to the App User, Fontakt may process the following personal data of the App User, including both in the App and on the Fontakt website:
12.3.1 Data Category (Data Types): User identification, contact details, work details and questionnaire data.

Personal data collected and processed:

• Identification data and contact details: first name and surname, e-mail address, telephone number.
• Work details: company the App User works for and App User’s area of responsibility within the company.
• Other data provided by the App User at his/her request when filling in the questionnaire forms: reason for requesting a meeting, monthly sales target, average transaction value, customer profile (companies most similar to the App User’s customers), companies recommended to the App User, search history of recent companies, history of re-qualifications, history of meetings, statistics on calendar month results.

Data source: Obtained from the App User when the App User creates App User account in the App, submits his or her data through the App User account in the App, submits a package order and the data necessary for its fulfilment, contacts Fontakt regarding an App order, query, or complaint.

12.3.2 Data Category (Data Types): Registration, login, and account technical, administrative data.

Personal data collected and processed:

• Registration and login details: phone number, email address and password, which Fontakt keeps securely encrypted and cannot be disclosed.
• Technical/administrative data necessary for the operation and security of the account: phone number, username, account status (active, deleted, etc.), IP address, account logins and account operations
• Other information: an indication that the App User has read the Privacy Policy and/or other terms and conditions, the date and time of such reading.

Data source:

• Obtained from the App user when he/she registers App User account in the App.
• Automatically created or stored (including through the use of cookies and similar technologies) when App User registers, logs into or uses App User account (e.g., technical data).

12.3.3 Data Category (Data Types): Package subscription details

Personal data collected and processed:

• Payment confirmation for the package: user’s e-mail address;
• Package or service order details: package ordered, price, date and time of order;
• Billing information: payment method, date and time, payment details (including but not limited to bank account number);
• Subscription status information: whether the package has been activated;
• Communication data: information on communication with the App User on matters relating to the order and its fulfilment, feedback from the App User, other communication content.
• Other information: indication that the App User has read the Privacy Policy and/or other terms and conditions, date, and time of reading.

Data source:

• Obtained from the App User when the App User places an order for a paid package in the App, makes a payment for the order or when the App User contacts or is being contacted with in relation to the order and its fulfilment.
• Data may also be generated during the fulfilment of the order (e.g., information that the order has been paid for).;
• Data may also be collected by means of cookies or similar technologies where such information is necessary for the conclusion of the contract, the acceptance of the order and its processing (for example, cookies may be used to indicate that the App User has read the Privacy Policy or other terms).

12.3.4 Data Category (Data Types): Application User consents, communication and/or service (package) management options.

Personal data collected and processed:

• Consents and communication: App User consent to marketing and/or other communications, to subscribe to information and/or to opt-out of communications.
• Service choices: information about the services (packages) to which the App User has subscribed, including cancellation.
• App User’s choices about cookies.

Data source:

• Obtained from the App User (and stored in an automated way, including through cookies and similar technologies).
• By indicating his/her respective consents and/or choices, the App User subscribes to or unsubscribes from the relevant communications and/or services.

12.3.5 Data Category (Data Types): Data regarding App User’s browsing on Fontakt website and/or App.

Personal data collected and processed:

• Browsing data: web pages or packages viewed, date and time viewed, browsing time, banner clicks, other clicks and interest in content, information from which Application User access the page;
• Technical data: IP address, session ID, browser used, device type, resolution.

Data source:

• Collected through cookies and similar technologies when browsing the Fontakt website and/or App.
• Generated from App User browsing data (e.g., browsing statistics).

12.3.6 Data Category (Data Types): Other data generated when using the App’s functions.

Personal data collected and processed:

• Data that is generated when using certain features of the App: for example, when App User allows (consents) in the App the App to send notifications to his/her  phone screen i.e. push notifications, the App collects App User device IDs for sending push notifications (such IDs are not kept in the database and the App User can disable notifications in the App at any time, in which case Fontakt will delete such data immediately); if the App User allows (consents) the App to receive information about the physical geographic location of the App User’s device in real time in accordance with clause 3.4 of the Data Protection Conditions, in which case the App collects such data only when and at the moment of the App User’s own activation of the corresponding function in the App (such data is not kept in the database and is collected only when the function is used and activated by the App User who can deactivate such function in the App at any time, in which case Fontakt deletes the corresponding data immediately and does not keep such data even after the function is deactivated); including App User’s choice of language in Fontakt website or App; calls made by the App User in the App (including call-backs and call history); companies searched by the App User in the App (including history of companies searched and recommended companies); the App User’s calendar of appointments and appointments added by the App User to the App;
• Data that is generated when using the App and its certain features for the purpose of displaying analytics to the App User about his/her use of the App features or services subscribed to through the App by the App User: business goals for the current and previous calendar month of use (including companies viewed by the App User).
• Statistics about the App User’s calls made through App (including call time included in the package subscribed to by the App User), statistics about the App User’s appointments made through the App.

Data source: Obtained from the App User himself/herself (including through automated means, including cookies and similar technologies) when the App User uses the App, its relevant features or the Fontakt website.

12.3.7 Data Category (Data Types): Newsletter and other message review data.

Personal data collected and processed:

• Information that the message has been successfully delivered, information about when the message was opened, clicking on links in the message, information about the email. Forwarding of the message (without fixing the addressee), information on rejection of messages (corresponding type of messages).

Data source: Collected through cookies and similar technologies when the App User receives newsletters and other messages.

12.3.8 Data Category (Data Types):  Application User interaction details

Personal data collected and processed:

• When Fontakt is contacted for help, assistance, questions, queries, complaints, etc., then Fontakt processes the documents and data provided by the App User, depending on when and to what extent they are necessary to process the App User’s request and provide a response.

Data source: Obtained from the App User when the App User contacts Fontakt with a request, query, complaint, or other inquiry. Fontakt also has the right to collect the data itself in order to resolve the App User’s request, provided that such data is lawfully available to Fontakt and that it is necessary to resolve the App User’s request.

13. Data safety and sharing of data

13.1. The security measures relating to the safety of the App User personal data are described in Section 7. of the Privacy Policy, such as: App passwords are encrypted, use of renewable tokens when accessing the App, no credit card data stored in Fontakt servers, etc. The App User may also request the deletion of its personal data in the manner and on the basis described in the Data Protection Conditions and section 14. of the Privacy Policy.

13.2. n order to offer the App Fontakt owns and updates CRM database that is owned by Fontakt and contains the contact details of the contact persons in the specific areas of responsibility of the company (company, name of the contact person in the specific area of responsibility, his/her role in the company, work e-mail). This database is not public and Fontakt uses this database only to provide the App and other Fontakt services described in the Data Protection Conditions. Fontakt collects data in its database from the public data of the commercial register, from the websites of companies and contacts companies themselves to obtain the data. Fontakt also collects database data from the App User from the App at the moment he/she registers App User account in the App, and such data is: the contact information of the App User (i.e. first and last name of the App User, phone number and e-mail address), App User`s work details (i.e. the name of the company the App User works for and the area for which the App User is responsible for in the company).

13.3 Personal data of the App User may only be transferred if there is a legal basis for the transfer of such personal data. Where Fontakt uses a third party to transfer personal data, the third party is the data processor and must comply with Fontakt’s data processing regulations and agreement or otherwise with the instructions and requirements provided.

13.4 In legal proceedings and in other cases provided for by law, the App User personal data may be disclosed to public authorities in accordance with the procedure established by the legislation of the Republic of Estonia.

14. How can App User delete his/her personal data?

14.1. The App User has the right to request the deletion of his/her personal data in the manner and on the basis provided in the Data Protection Conditions in accordance with the General Data Protection Regulation (the “GDPR“). For example, App User has the right to request that his/her personal data not be processed by Fontakt and that Fontakt deletes such data when at least one of the following circumstances are met:
14.1.1 such personal data is no longer necessary for the legitimate purposes for which it was collected or otherwise processed; 
14.1.2 the processing of the personal data is based on consent and the App User withdraws his/her consent and there is no other legal basis for the processing.
14.1.3 the processing of the App User personal data is unlawful;
14.1.4 the processing of the personal data is based on a legitimate interest of Fontakt and the App User has objected to the processing of his/her personal data on the basis of the legitimate and legal interest of Fontakt and, in a particular case, the interests of the App User prevail.

14.2. Fontakt will not delete the App User’s personal data if:
14.2.1 the personal data of the App User is necessary for the legitimate and legal purposes for which they it was collected or processed and there are legal grounds for such processing.
14.2.2 the App User has not withdrawn his/her consent to the processing of his/her personal data where the data is processed on the basis of the App User’s consent.
14.2.3 the processing of the App User personal data is necessary for the legitimate and legal interests of Fontakt, and the interests of the App User do not prevail.
14.2.4 the processing of the App User personal data is necessary for the establishment, exercise, or defence of legal claims.
14.2.5 the App User personal data is needed to be processed for the performance of a contract concluded with the App User (including for the provision of the App to the App User or for the performance of App or its package subscription submitted by the App User, e.g. for the provision of paid package to the App User) and the App User has not terminated or withdrawn from the contract (e.g. has not cancelled a subscription to a package or has not deleted his/her account in the App).
14.2.6 Fontakt is obliged to process the App User’s personal data in accordance with the applicable European Union and national legislation.

14.3. The App User can delete his/her App User account and personal data in the App in the manner described in section 14.4 of the Privacy Policy. The App User also has the right to delete (uninstall) the App from his/her device at any time but deleting the App from the device does not delete the App User account or cancel the App User’s subscription to paid services (paid packages or other paid features).

14.4. The App User can delete his/her App User account through the App as follows: the App User must go to the “Privacy” sub-category from the “Menu” and from there to the “Delete User” option, then the App User must enter his/her App User account password and click on the “Delete Account” button, in which case the App User account and account personal data will be permanently deleted from the App, along with the history of such personal data. If the App User has subscribed to a paid package or other App paid functions, deleting the App User account will require the App User to cancel the subscription to the paid package or other paid function before deleting the App User account, for which the appropriate instructions will be provided to the App User via the App prior to deleting the App User account.

14.5. The App User and the App User account in the App will not be deleted in the manner described in clause 14.4. of the Privacy Policy when: (1) the App User enters an incorrect password when deleting his/her App User account and/or does not enter the password when deleting his/her App User account; and/or (2) the App User does not click on the “Delete account” button when deleting his/her App User account; and/or (3) the App User only deletes (uninstalls) the App from his/her smart device, but does not delete the App User account in the App; and/or (4) the App User has an active paid package or has subscribed to other paid functions in the App and he/she has not cancelled such subscription.

14.6. In addition to the provisions of clauses 14.3. and 14.4. of the Privacy Policy, the App User may also request the deletion of his/her personal data in the manner and on the grounds set out in clauses 7. and 8. of the Data Protection Conditions.

15. How can App User change/update his/her personal data?

15.1 The App User can change or correct his/her personal data if his/her personal data is incorrect or incomplete in the App in following ways:
15.1.1 in the App, in his/her personal App User account, under the “My Profile” subcategory of the “Menu” menu; or
15.1.2 by contacting Fontakt as described in section 8. of the Data Protection Conditions.

16. Complaints and redress procedures, applicable law, and jurisdiction

16.1 Disputes between Fontakt and the App User or between Fontakt and a third party shall be settled through negotiations. The App User can address a complaint, claim, or concern to Fontakt using the contact details provided in clause 18. of the Privacy Policy. Fontakt will then contact the App User as soon as possible, but no later than within 15 working days from the receipt of the complaint, claim, etc., to find a solution to the problem. Upon filing a GDPR application as set forth in clause 16.2. of the Privacy Policy, Fontakt will contact the App User as soon as possible, but no lates than within 30 calendar days from the receipt of the GDPR application.  If it is not possible to resolve the complaint within the specified term, Fontakt shall justify the delay and notify the App User thereof in writing or in a form that can be reproduced in writing, setting a new reasonable term. A reply will be sent to the App User at the postal address or e-mail address indicated by the App User upon registering the App User account, unless otherwise agreed with the App User.

16.2 In the event of a question, request or complaint related to the processing of personal data, the App User has the right to contact Fontakt through the e-mail address referred to in clause 18. of the Privacy Policy by sending a digitally signed request, question or complaint to the indicated e-mail address or filling in the corresponding GDPR application form here https://fontakt.com/en/gdpr-App/ The procedure for requests, questions and complaints regarding data protection is set out in Section 8. of the Data Protection Conditions.

16.3 In the manner and on the basis described in the Data Protection Conditions, the App User has the right to withdraw his/her consent to the processing of personal data at any time, if the processing of the App User’s personal data is based on his/her consent. Withdrawal of consent does not affect the lawfulness of the processing of personal data that took place prior to the withdrawal of consent.

16.4 In the manner and on the basis described in the Data Protection Conditions, the App User has the right to object to the processing of his/her personal data on the basis of his/her individual situation, if the processing is based on the legitimate interest of Fontakt. In such a case, Fontakt will not further process the App User personal data, unless there is a compelling legitimate and legal ground for doing so which prevails the interests, rights and freedoms of the App User, or there is another legal basis for the processing. For example, there is a legal ground for processing personal data if the personal data is processed for the purposes of providing the App services subscribed by the App User or fulfilling the App User’s order and/or providing other App services requested by the App User, i.e. if the App User would not have provided or allowed the processing of the relevant personal data, the App User would not have been able to use the App, place an order or use the relevant service available in the App.

16.5 Complaints or disputes will be resolved between Fontakt and the App User or between Fontakt and a third party through negotiations. If no solution is reached through negotiations, disputes will be settled in Harju County Court in Estonia.

16.6 The App User who is a Consumer can also turn to an out-of-court complaint and dispute resolution body, which is the Consumer Disputes Commission in Estonia (e-mail avaldus@komisjon.ee, more information on the conditions for contacting them can be found here). The consumer may also use the relevant online platform http://ec.europa.eu/consumers/odr/

16.7 The law of the Republic of Estonia applies to the Privacy Policy. In matters not regulated by the Privacy Policy or the Data Protection Conditions, Fontakt and the App User shall be guided by the legislation in force in the Republic of Estonia or the relevant EU regulations regarding personal data protection, especially the GDPR.

16.8 If the applicable law does not allow the agreement to limit the applicable law to Estonian law or authority to the jurisdiction of Harju County Court, Fontakt and the App User or a third party shall follow the provisions of applicable law and jurisdiction prescribed in

17. Intellectual property

17.1 The App, including its content, (also its logo, brand, visual design, etc.), is protected by intellectual property rights owned by Fontakt.

17.2 The App User is prohibited from infringing the intellectual property rights of Fontakt and other persons, which includes the prohibition to distribute the App or any part thereof for a fee or free of charge, and prohibition to use the App’s trademark, logo, contact information or any other markings.

18. Contacts

18.1. If you have any questions, notices, or complaints, please contact Fontakt at Pärnu mnt 139c, 11317 Tallinn, Estonia; e-mail address abc@fontakt.com or phone number +3726865555. Fontakt communicates with the contact person in Estonian or English.