1. General Provisions

1.1. This privacy policy regulates the principles of collection, processing, and storage of personal data. Personal data is collected, processed, and stored by the responsible data processor Clivecode UÜ (hereinafter the data processor).

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

1.3. A client, 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 adheres to the principles of data processing established in legal acts and processes personal data lawfully, fairly, and securely. The data processor is able to confirm that personal data has been processed in accordance with the provisions of legal acts.

2. Collection, Processing, and Storage of Personal Data

2.1. 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 with the data processor 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 information is considered a violation of this privacy policy. The data subject is obligated to immediately inform the data processor of any changes to the provided data.

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

3. Processing of Clients’ 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. 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 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)(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 party or in order 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 processor is subject;

f) Processing is necessary for the purposes of the legitimate interests pursued by the data processor or by 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. 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 – 2 years

3.4.3. Purpose of processing – ensuring the functioning of e-shop services

Maximum retention period of personal data – 2 years

3.4.4. Purpose of processing – customer management

Maximum retention period of personal data – 2 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 – 2 years

3.5. The data processor has the right to share clients’ personal data with third parties, such as authorized data processors, accountants, transport and courier companies, and companies providing transfer services. The data processor is the responsible data processor. The data processor transfers the personal data necessary for making payments to the authorized processor Maksekeskus AS.

3.6. In processing and storing the personal data of the data subject, the data processor applies 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 for no longer than 2 years.

4. Rights of the Data Subject

4.1. The data subject has the right to access their personal data and to review 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 personal data of the data subject based on the consent of the data subject, the data subject has the right to withdraw their consent at any time.

4.5. The data subject can contact the e-shop’s customer service at info@clivecode.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) 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 legal acts of the Republic of Estonia and the European Union.

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