Privacy Policy


1.1 The privacy policy (hereinafter the privacy policy) lays down the principles according to which Kullakuu OÜ (hereinafter the company) protects personal data with relation to the rendering of services and the purposes for which the company processes personal data.

1.2 The privacy policy applies to all persons who use the services and website ( of the company and make queries regarding the company’s services.

1.3 The privacy policy is based on the General Regulation on the Protection of Personal Data of the European Union (Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data repeals Directive 95/46/EC, the “GDPR”) and specifies its implementation principles by the company.

1.4 The privacy policy forms an integral part of all contracts of the company. By visiting the website, submitting queries to the company regarding services and using the services of the company, you agree to the principles of data processing described in the privacy policy.


Person – customer, a person related to the customer, or a visitor.

Customer – person who uses a service provided by the company or a representative of such person. Person closely related to a customer – person whose personal data the company processes to perform a contract.

Visitor – person who visits the website of the company.

Data – personal data of the person that become known to the company through the customer using the services of the company or making queries about the services.

Website – website of the company.

Services – services provided by the company.

Contract – contract entered into with a customer for the provision of services.

Newsletter subscriber – person who has subscribed to the company’s newsletter. Subscribing to the newsletter by a person who has not entered into a contract constitutes an entry into a contract between the company and the newsletter subscriber to subscribe to and receive the newsletter.

All terms mentioned in the singular are also applicable to the plural.


3.1 The company processes personal data to offer the best services to its customers, perform a contract entered into to provide a service, and answer to queries submitted with regard to the services. We only collect the minimum customer data that we need to attain the purposes of processing.

3.2 The company collects personal data:

3.2.1 When the services of the company are ordered and used and upon entering into a contract;

3.2.2 when a request for information is sent to or through the company;

3.2.3 When the company’s newsletter is subscribed to.

3.3 The data processing is necessary to enable the company to provide services to the customer, reply to service requests, and ensure that the newsletter is sent to its subscribers.

3.4 Data processing is based on a person’s consent, contract, or law.


4.1 The company may use the personal data of a customer, person related to a customer, and newsletter subscriber to perform a contract under legislation without the person’s consent in the following cases:

4.1.1 To identify a customer or his/her representative for the purpose of entering into a contract;

4.1.2. To perform the actions required to provide the customer with the services and give advice with relation to the services;

4.1.3 To create and store logs of the company’s website and electronic solution, to eliminate errors, to perform maintenance and development, and to store data related to the contract (including using cloud services);

4.1.4 To improve the services and the user experience of the customer and visitor, to provide information related to the use of the services, and for other activities necessary for the provision of the services;

4.1.5 To prepare and deliver invoices;

4.1.6 To exchange information related to the provision of services and business, to document business activities (e.g., to provide information to comply with the obligations imposed on the company by legislation, etc.), as well as to assess and prevent business risks and losses;

4.1.7 To send information to customers regarding the services via email;

4.1.8 To improve and develop the quality of customer service and measure user activity and customer satisfaction;

4.1.9 To protect violated or contested rights of the company and to collect debts, including the transfer of data to a legal or lawyer’s office and to a debt collection company;

4.1.10 To enable and control the customer's and user’s access to digital channels in order to improve the user experience of digital services and to customize views for devices, as well as to prevent unauthorized access to digital channels and their misuse, ensuring information security, to improve technical systems and information technology structure, and to develop services through testing and improvement;

4.1.11 In other ways, to assist in the execution of the contract, the conclusion and execution of the contract, to perform the activities required for the provision of services or the protection of their own rights.

4.2 The customer cannot refuse the processing of data for reasons provided in clauses 4.1.1–4.1.11, insofar as it would make it impossible to render services to the customer.

4.3 The company may use the data of a newsletter subscriber (name and email address) to perform the newsletter contract on the basis of legislation without the consent of the person to deliver the company;s newsletter to the email address of the person who requested it. The person can cancel his/her newsletter subscription, terminating the newsletter contract.


5.1 The company processes the following data for purposes provided in clauses 4.1.1 – 4.1.11:

5.1.1 Customer’s name, email address, address, phone number, bank account number, invoice and payment information, credit card information;

5.1.2 Name, email address and/or address of a person related to a customer;

5.1.3 Data regarding the use of services provided by the company: Data on the start and period of use of the services, data on the customer’s orders, data on statements, invoices, and payment information related to the contract, data on the choices, actions, and logs made in electronic channels, data collected by means of cookies, and other data concerning the use of the company’s services.

5.1.4 Other data that the company may process to perform the contract to a reasonable extent and in necessary composition.


span>6.1 We consider the personal privacy and the protection of personal data of utmost importance and make the best efforts to ensure the security and protection of the data.

6.2 We protect the security of personal data and ensure the prevention of data leaks and loss by way of risk mitigation and threat prevention.

6.3 We ensure the security of data processing according to legal acts (e.g., the GDPR) and good business practices.


7.1 The company has the right to use a customer’s data under the contract to conduct marketing and statistical analysis of the company’s services and service environment (e.g., typical behaviour and method of use) by combining data received from external sources with internal data with the purpose of ascertaining the needs and preferences of a person.

7.2 Sending offers to the customer is allowed on the basis of the contract, the newsletter contract, consent, and legitimate interest of the company, unless the person has renounced marketing offers. Upon entry into contract, the customer and newsletter subscriber give the company consent to receive direct marketing, campaign and special offers, and that which was provided in clause 7.3. The consent is in force until it is withdrawn or the contract is terminated.

7.3 The person may contact the company at any time via the contact information provided on the website to announce his/her wish to no longer receive personal offers and to withdraw consent. For this, a request in free format shall be sent to


The company shares the data in the following cases:

8.1 in cases provided by legal acts upon request of authorities (e.g., law enforcement agencies);

8.2 to companies related to the provision of services, if it is necessary to perform the contract;

8.3 to legal and financial consultants, debt collection agencies, and other processors, if it is necessary for the provision of services, complying with the company’s obligations, and protection of rights.


9.1 The company does not store data longer than what is necessary. The company stores the data until the purpose of its use is fulfilled.


10.1 Pursuant to legislation, a customer, a person related to a customer, and a newsletter subscriber has the following right:

10.1.1 receive information from the company related to the processing of his/her personal data;

10.1.2 request that the company terminates the use of his/her data or changes and deletes his/her data;

10.1.3 give of withdraw consent to the use of his/her data for marketing purposes.


Our contact information for the submission of notices, queries, and requests:

12.1 Company email:


13.1 The company uses cookies on its website (text files that are downloaded to the user’s device (phone, computer) via the website or the company’s electronic solution. Cookies will be stored into browser file catalogs (e.g., Chrome, Internet Explorer) and on the hard drive of end device of the website visitor. Cookies enable to recognize the user the next time the user opens the website, identify his/her interests and preferences, analyze his/her choices and offer better terms of use, and make offers and send advertisements via the website on the basis thereof. Cookies do not endanger the device the website is used on.

13.2 The company uses cookies so that the person would not have to enter information he/she previously already entered when visiting the website or using the company’s electronic solution again.