1. General Provisions

1.1. This privacy policy regulates the principles of collecting, processing, and retaining personal data. Personal data is collected, processed, and retained by the data controller, Lavatera OÜ (hereinafter referred to as the data controller).

1.2. A data subject under this privacy policy is a client or any other natural person whose personal data is processed by the data controller.

1.3. A client under this privacy policy is anyone who purchases goods or services from the data controller’s website.

1.4. The data controller adheres to the principles of data processing established by law, including processing personal data lawfully, fairly, and securely. The data controller is able to confirm that personal data has been processed in accordance with legal requirements.

2. Collection, Processing, and Retention of Personal Data

2.1. Personal data collected, processed, and retained by the data controller is collected electronically, primarily through 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 shares 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 violation of the privacy policy. The data subject is obligated to inform the data controller immediately of any changes to the provided data.

2.4. The data controller is not responsible for any damage caused to the data subject or third parties due to the provision of false data by the data subject.

3. Processing of Clients’ 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 client 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 (GDPR):

a) The data subject has given consent to process 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 according to the purpose of processing:

3.4.1. Purpose of processing – security and safety
Maximum retention period – as specified by law.

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

3.4.3. Purpose of processing – ensuring the functioning of the e-store services
Maximum retention period – 7 years.

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

3.4.5. Purpose of processing – financial activities, accounting
Maximum retention period – as specified by law.

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

3.5. The data controller has the right to share clients’ personal data with third parties, such as authorized processors, accountants, transport and courier companies, and payment service providers. The data controller is the responsible processor of personal data. The data controller transmits personal data necessary for payment processing to the authorized processor Maksekeskus AS.

3.6. When processing and retaining the data subject’s personal data, the data controller applies organizational and technical measures to ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.

3.7. The data controller retains data subjects’ data 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 and review their personal data.

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

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

4.6. The data subject 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 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 other legal acts of the Republic of Estonia and the European Union.

5.2. The data controller has the right to partially or fully amend the data protection terms, notifying data subjects of the changes through the website www.lavatera.ee.