1. Data Controller
The controller of your personal and company data is:
Hirvu OÜ
Tartu mnt 67/1-13b
10115 Tallinn, Harju maakond
Estonia
Registration number: 17264235
Email: contact@hirvu.com
For matters relating to data protection and processing of personal data, please contact us at: contact@hirvu.com
2. Purposes and legal bases of data processing
We process your personal and company data for the following purposes:
Handling offer forms
- Analysis of recruitment needs, automatic offer generation through AI
- Legal basis: Art. 6(1)(f) GDPR - legitimate interest
- Retention period: 5 years from last contact
Business contact
- Sending price lists, service information, telephone contact
- Legal basis: Art. 6(1)(f) GDPR - legitimate interest
- Retention period: 5 years from last contact
Website analytics
- Google Analytics 4, visit statistics
- Legal basis: Art. 6(1)(a) GDPR - consent to cookies
- Retention period: 26 months
Contact with AI consultants
- Communication regarding recruitment processes and offer
- Legal basis: Art. 6(1)(b) GDPR - contract performance/pre-contractual steps
- Retention period: 5 years from end of cooperation
3. Categories of processed data
We collect the following categories of personal and company data:
From offer forms
- Identification data (first name, surname, email, phone, position in company)
- Company data (company name, business description, industry, registration number, VAT ID)
- Description of recruitment needs
Technical data (automatic)
- IP address, browser type, operating system
- Analytics data (navigation paths, time on page)
- Cookies (according to Cookie Policy)
Data sources: Data comes directly from you and may be made available to us through contact forms, email or phone as well as from publicly available sources for B2B business contacts.
4. Data recipients
Personal/company data may be transferred to the following categories of recipients:
- Google (Analytics) - website analytics (according to cookie consent)
- IT service providers - hosting (OneProvider), email (Namecheap)
- Legal and accounting service providers - for business activities
- Public authorities - in case of legal obligation
Data transfers outside the EU - Google Analytics (USA)
Based on the European Commission's adequacy decision we transfer to Google:
- Statistical data - anonymised IP address, browser type, navigation paths
- Form analytics data - pseudonymous session identifier (e.g. "client_12345678"), selected industry, information about successful form completion
- Technical data - browser language, screen resolution, traffic source
We do NOT transfer:
- Contact data (email, phone)
- Company names and company data
- Query content and needs descriptions
- Lead ID numbers from our system
- First and last names of contact persons
Data protection: Complete data from contact forms is processed exclusively on EU servers and does not leave the territory of the European Union.
5. User rights
You have the following rights:
- Right of access to your personal and company data
- Right to rectification of incorrect data
- Right to erasure ("right to be forgotten")
- Right to restriction of processing
- Right to data portability
- Right to object to processing (especially for direct marketing)
- Right to withdraw cookie consent (at any time - independently through the website)
To exercise these rights, please contact us: contact@hirvu.com
Right to lodge a complaint: You have the right to lodge a complaint with the Estonian Data Protection Inspectorate as the supervisory authority responsible for the data controller.
6. Cookie Policy
Our website uses cookies for:
- Website functionality (necessary cookies)
- Analytics - Google Analytics 4 (analytical cookies)
- User preferences - remembering cookie settings
Types of cookies:
- Necessary - required for website operation (cannot be disabled)
- Analytical - Google Analytics 4 (consent required)
- Functional - language settings and preferences
Cookie management:
During the first visit to the website, a cookie banner is displayed with options:
- Accept all - consent to all cookies
- Necessary only - reject analytical cookies
- Reject all - minimal functional cookies
Consent can be changed at any time by clicking "Change cookie settings" in the page footer.
Disabling cookies in browser:
Cookies can be managed directly in browser settings:
- Chrome: Settings → Privacy and security → Cookies
- Firefox: Settings → Privacy and security
- Safari: Preferences → Privacy
Google Analytics:
We use Google Analytics 4 for website traffic analysis. Tracking can be disabled by installing an add-on: https://tools.google.com/dlpage/gaoptout
Pseudonymous identifier: To track form effectiveness we generate a local session identifier (e.g. "client_12345678"), which contains no personal/company data and allows only statistical analysis without user identification.
7. Automated decision-making and profiling
We use automated processing in the following areas:
Generating business offers:
- Purpose: Automatic preparation of preliminary offer based on form data
- Logic: AI algorithm analyses industry, needs description and company scale, selecting appropriate services and preliminary pricing from our parameter database. In case of insufficient data or non-compliance with market standards, AI may not generate an offer
- Consequences: You receive a personalised business offer tailored to your stated needs or information about the need for additional data
- Safeguards: Every automatically generated offer is verified by our consultants. Prices may be subject to individual negotiations
AI consultant support:
- Purpose: Assistance in analysing recruitment needs and candidate matching
- Logic: AI analyses employer requirements and candidate profiles, suggesting best matches
- Consequences: Faster and more precise matching of candidates to job offers
- Oversight: Final decisions on contacts and recommendations are made by our consultants
Your rights regarding automated processing:
- Right to human intervention - you can request verification of the decision by a consultant
- Right to express your point of view - you can present your comments on the automated decision
- Right to contest - you can disagree with the automated assessment and request re-analysis
- Contact: For automated decisions, please contact us by email: contact@hirvu.com
8. Data security
We apply appropriate technical and organisational measures to ensure data security:
- SSL/TLS encryption of all communication
- Access control - data access only for authorised persons
- Regular backups and security updates
- Incident response procedures for security incidents
- Data separation - sensitive data processed exclusively in the EU
9. Policy changes
We reserve the right to update this Privacy Policy. We will inform about significant changes via a notice on the website or email (if provided).
The current version of the Privacy Policy is always available on our website.
10. Contact
For matters relating to data protection and processing of personal data:
Email: contact@hirvu.com
Address: Hirvu OÜ, Tartu mnt 67/1-13b, 10115 Tallinn, Estonia
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This Privacy Policy complies with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and Estonian data protection legislation.
