1. General provisions
1.1. This privacy policy governs the principles for the collection, processing and storage of personal data. Personal data is collected, processed and stored by the personal data controller Küttepuude Kuller OÜ, registry code 17093744, VAT no. EE102962172 (hereinafter the data processor).
1.2. A data subject within the meaning of the privacy policy is a customer or other natural person whose personal data the data processor processes.
1.3. A customer within the meaning of the 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 laid down in legislation, among other things the data processor processes personal data lawfully, fairly and securely. The data processor is able to confirm that personal data has been processed in accordance with what is laid down in legislation.
2. Collection, processing and storage of personal data
2.1. The personal data that the data processor collects, processes and stores is collected electronically, mainly via the website, online shop orders and e-mail.
2.2. By sharing their personal data, the data subject grants the data processor the right to collect, organise, use and manage, for the purpose defined in the privacy policy, the personal data that the data subject shares with the data processor directly or indirectly when purchasing goods or services on the website.
2.3. The data subject is responsible for ensuring that the data they provide is accurate, correct and complete. Knowingly providing false data is considered a breach of the privacy policy. The data subject is obliged to notify the data processor immediately of any change in the data provided.
2.4. The data processor is not liable for damage caused to the data subject or to third parties by the data subject providing false data.
3. Processing of customers’ personal data
3.1. The data processor may process the following personal data of the data subject:
- First and last name
- Telephone number
- E-mail address
- Delivery address
- Order content and order history
- Payment-related information. Card payments and recurring subscription payments are processed by Maksekeskus AS. The data processor itself does not see or store the full card number. When paying by bank transfer, the payer’s account number may be visible to the data processor.
3.2. In addition to the above, the data processor has the right to collect data about the customer that is available in public registers.
3.3. The legal basis for the processing of 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 of the personal data is necessary for the performance of a contract concluded with the participation of the data subject or in order to take steps prior to entering into a contract at the request of the data subject; c) processing of the personal data is necessary for compliance with a legal obligation of the controller; f) processing of the personal data is necessary for the legitimate interests of the 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, in particular where the data subject is a child.
3.4. Processing of personal data according to the purpose of processing:
3.4.1. The purpose of processing is security and safety. The maximum retention period for personal data is in accordance with the deadlines specified in law.
3.4.2. The purpose of processing is order processing and delivery. The maximum retention period for personal data is until the order is fulfilled, and as source accounting documents 7 years.
3.4.3. The purpose of processing is to ensure the functioning of the online shop and subscription (full-service) services. The maximum retention period for personal data is for as long as the customer account or subscription exists.
3.4.4. The purpose of processing is customer management. The maximum retention period for personal data is until the end of the customer relationship.
3.4.5. The purpose of processing is financial activity and accounting. The maximum retention period for personal data is in accordance with the deadlines specified in law (under the Accounting Act, 7 years).
3.4.6. The purpose of processing is marketing. The maximum retention period for personal data is until consent is withdrawn.
3.5. The data processor has the right to share customers’ personal data with third parties, who are authorised processors and cooperation partners that process the data only according to the data processor’s instructions and to the extent necessary for providing the service:
- Maksekeskus AS (MakeCommerce) for processing payments and recurring subscription payments. In the case of a subscription, Maksekeskus stores the payment mandate on the basis of which the agreed recurring payments are initiated.
- Merit Tarkvara (accounting and issuing invoices).
- Twilio (SMS notifications about delivery).
- Klaviyo (e-mail notifications and marketing based on consent).
- Google (map and route application and web statistics).
- Transport and courier partners. If the data processor uses an external transport or courier service to deliver an order, only the data necessary for delivery is transmitted to them (name, delivery address, telephone number and order content).
The data processor is the personal data controller. The data processor does not sell personal data to third parties. Data may be disclosed to competent authorities if required by law.
3.6. When processing and storing the data subject’s personal data, the data processor applies organisational 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 stores the data of data subjects depending on the purpose of processing, but no 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 examine it.
4.2. The data subject has the right to receive 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 the data processor processes the data subject’s personal data on the basis of the data subject’s consent, the data subject has the right to withdraw consent at any time.
4.5. To exercise their rights, the data subject can contact the online shop’s customer support at info@kyttepuudekuller.ee.
4.6. To protect their rights, the data subject may lodge a complaint with the Data Protection Inspectorate (aki.ee).
5. Final provisions
5.1. These data protection terms have been prepared in accordance with Regulation (EU) No 2016/679 of the European Parliament and of the Council on the protection of natural persons 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 change the data protection terms partially or fully, notifying data subjects of the changes via the website kyttepuudekuller.ee.