1. General Terms

1.1. This privacy policy regulates the principles of collecting, processing, and storing personal data. The personal data is collected, processed, and stored by the data controller Vabanemine OÜ (hereinafter referred to as the data processor).

1.2. A data subject in the context of this privacy policy is a customer or any other natural person whose personal data is processed by the data processor.

1.3. A customer in the context of this privacy policy is anyone who purchases goods or services from the data processor’s website.

1.4. The data processor follows the principles of data processing set forth in legal acts, including processing personal data lawfully, fairly, and securely. The data processor is able to confirm that personal data has been processed in accordance with the requirements set forth in legal acts.

2. Collection, Processing, and Storage of Personal Data

2.1. The personal data collected, processed, and stored by the data processor is gathered electronically, primarily through the website and email.

2.2. By sharing their personal data, the data subject grants the data processor the right to collect, organize, use, and manage personal data for the purposes defined in this privacy policy, which the data subject shares directly or indirectly when purchasing goods or services on the website.

2.3. The data subject is responsible for ensuring that the data provided is accurate, correct, and complete. Deliberately providing false information is considered a violation of this privacy policy. The data subject is obligated to inform the data processor immediately of any changes to the provided data.

2.4. The data processor is not liable for any damages caused to the data subject or third parties due to the submission of incorrect data by the data subject.

3. Processing of Customers’ Personal Data

3.1. The data processor may process the following personal data of the data subject:

3.1.1. First and last name;

3.1.2. Phone number;

3.1.3. Email address;

3.1.4. Delivery address;

3.1.5. Bank account number;

3.1.6. Payment card details;

3.2. In addition to the above, the data processor has the right to collect data about the client that is available in public registers.

3.3. The legal basis for the processing of personal data is Article 6(1) points (a), (b), (c), and (f) of the General Data Protection Regulation:

a) the data subject has given consent to process their personal data for one or more specific purposes;

b) the processing of personal data is necessary for the performance of a contract to which the data subject is a party or for taking steps at the request of the data subject prior to entering into a contract;

c) the processing of personal data is necessary for compliance with a legal obligation to which the data controller is subject;

f) the processing of personal data is necessary for the purposes of legitimate interests pursued by the data controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data, especially when the data subject is a child.

3.4. Processing of personal data according to the purpose of processing:

3.4.1. Purpose of processing – security and safety
Maximum retention period of personal data – according to the deadlines specified by law

3.4.2. Purpose of processing – order processing
Maximum retention period of personal data – 7 years

3.4.3. Purpose of processing – ensuring the operation of e-commerce services
Maximum retention period of personal data – 7 years

3.4.4. Purpose of processing – customer management
Maximum retention period of personal data – 7 years

3.4.5. Purpose of processing – financial activities, accounting
Maximum retention period of personal data – according to the deadlines specified by law

3.4.6. Purpose of processing – marketing
Maximum retention period of personal data – 7 years

3.5. The data processor has the right to share customers’ personal data with third parties, including authorized data processors, accountants, transport and courier companies, and companies providing transfer services. The data processor is the responsible data controller. The data processor will transmit the necessary personal data for payment processing to the authorized processor Montonio Finance UAB.

3.6. In the processing and storage of the data subject’s personal data, the data processor implements organizational and technical measures that ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.

3.7. The data processor retains the data of data subjects depending on the purpose of processing, but not longer than 7 years.

4. Rights of the Data Subject

4.1. The data subject has the right to access their personal data and to be informed about it.

4.2. The data subject has the right to obtain information about the processing of their personal data.

4.3. The data subject has the right to complete or correct inaccurate data.

4.4. If the data processor processes the data subject’s personal data based on the data subject’s consent, the data subject has the right to withdraw their consent at any time.

4.5. The data subject can contact customer support at the e-commerce site at  info@oja9.ee to exercise their rights.

4.6. The data subject also has the right to file a complaint with the Data Protection Inspectorate to protect their rights.

5.Final Provisions

5.1. These data protection terms have been drawn up in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals 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), the Personal Data Protection Act of the Republic of Estonia, and the legislation of the Republic of Estonia and the European Union.

5.2. The data processor has the right to partially or fully amend these data protection terms, notifying the data subjects of the changes on the website https://oja9.ee/.