1. General Provisions
1.1. This Privacy Policy governs the principles related to the collection, processing, and storage of personal data. Personal data is collected, processed, and stored by the data controller ARRE INVESTMENTS OÜ (hereinafter referred to as the “data controller”).
1.2. A data subject, within the meaning of this Privacy Policy, is a customer or any other natural person whose personal data is processed by the data controller.
1.3. A customer, within the meaning of this Privacy Policy, is any person who purchases goods or services from the data controller’s website.
1.4. The data controller complies with the principles of data processing set out in legislation and processes personal data lawfully, fairly, and securely. The data controller is able to confirm that personal data has been processed in accordance with applicable laws.
2. Collection, Processing and Storage of Personal Data
2.1. Personal data collected, processed, and stored by the data controller is collected electronically, primarily via the website and email.
2.2. By sharing their personal data, the data subject grants the data controller the right to collect, organize, use, and manage personal data for the purposes defined in this Privacy Policy, which the data subject directly or indirectly provides when purchasing goods or services via the website.
2.3. The data subject is responsible for ensuring that the data provided is accurate, correct, and complete. Knowingly submitting false information is considered a violation of this Privacy Policy. The data subject is obliged to promptly notify the data controller of any changes to the submitted data.
2.4. The data controller shall not be liable for any damage 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 controller may process the following personal data of the data subject:
- 3.1.1. First and last name
- 3.1.2. Date of birth
- 3.1.3. Phone number
- 3.1.4. Email address
- 3.1.5. Delivery address
- 3.1.6. Bank account number
- 3.1.7. Payment card details
3.2. In addition to the above, the data controller has the right to collect data about the customer that is available in public registers.
3.3. The legal basis for processing personal data is Article 6(1)(a), (b), (c), and (f) of the General Data Protection Regulation:
a) the data subject has given consent to the processing of their personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which the data controller is subject;
f) processing is necessary for the purposes of the 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, especially if the data subject is a child.
3.4. Processing of Personal Data by Purpose
3.4.1. Purpose – Security and safety
Maximum retention period – in accordance with legal requirements
3.4.2. Purpose – Order processing
Maximum retention period – up to 3 years from completion of the order
3.4.3. Purpose – Ensuring the functioning of e-shop services
Maximum retention period – up to 1 year
3.4.4. Purpose – Customer management
Maximum retention period – up to 3 years from the last activity
3.4.5. Purpose – Financial activities, accounting
Maximum retention period – in accordance with legal requirements
3.4.6. Purpose – Marketing
Maximum retention period – until consent is withdrawn, but no longer than 3 years from the last activity
3.5. Disclosure of Personal Data
The data controller has the right to share customers’ personal data with third parties, such as authorized processors, accountants, transport and courier companies, and payment service providers. The data controller is the controller of personal data. The data controller transfers personal data necessary for making payments to the authorized processor Maksekeskus AS.
3.6. Data Security
When processing and storing personal data, the data controller implements organizational and technical measures to protect personal data against accidental or unlawful destruction, alteration, disclosure, or any other unlawful processing.
3.7. Data Retention
The data controller retains personal data 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 and review their personal data.
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 supplement or correct inaccurate data.
4.4. If personal data is processed based on consent, the data subject has the right to withdraw consent at any time.
4.5. To exercise their rights, the data subject may contact customer support at info@naturaldates.eu.
4.6. The data subject has the right to lodge a complaint with the Estonian Data Protection Inspectorate.
5. Final Provisions
5.1. This Privacy Policy has been prepared in accordance with Regulation (EU) No 2016/679 of the European Parliament and of the Council (General Data Protection Regulation), the Estonian Personal Data Protection Act, and applicable legislation of the Republic of Estonia and the European Union.
5.2. The data controller has the right to amend these data protection conditions in whole or in part by notifying data subjects via the website www.naturaldates.eu.