Privacy Policy

1. General Provisions

1.1. This privacy policy governs the principles of collecting, processing, and storing personal data. Personal data is collected, processed, and stored by the data controller Nutikas Valik OÜ (hereinafter referred to as 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 follows the principles of data processing outlined in legal acts, including processing personal data legally, fairly, and securely. The data processor can confirm that personal data has been processed according to the provisions set out in legal acts.

2. Collection, Processing, and Storage of Personal Data

2.1. The personal data collected, processed, and stored by the data processor is gathered electronically, mainly via 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 the privacy policy, which the data subject directly or indirectly shares 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. Providing knowingly incorrect data is considered a breach of the privacy policy. The data subject is obligated to notify the data processor immediately 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 resulting from the provision of incorrect data by the data subject.

3. Processing of Client Personal Data

3.1. The data processor may process the following personal data of the data subject:

  1. First and last name;
  2. Date of birth;
  3. Phone number;
  4. Email address;
  5. Delivery address;
  6. Bank account number;
  7. Payment card details.

3.2. In addition to the aforementioned data, the data processor 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) of the General Data Protection Regulation, points (a), (b), (c), and (f):

  • a) The data subject has given consent for the processing of their personal data for one or more specific purposes;
  • b) The processing of personal data 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) The processing of personal data is necessary for compliance with a legal obligation to which the data controller is subject;
  • f) The processing of personal data is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, particularly if the data subject is a child.

3.4. Processing of personal data according to the processing purpose:

3.4.1. Processing purpose – Security and safety

  • Maximum retention period of personal data – as per legal deadlines

3.4.2. Processing purpose – Order processing

  • Maximum retention period of personal data – 7 years

3.4.3. Processing purpose – Ensuring the functionality of e-store services

  • Maximum retention period of personal data – 7 years

3.4.4. Processing purpose – Customer management

  • Maximum retention period of personal data – 7 years

3.4.5. Processing purpose – Financial activities, accounting

  • Maximum retention period of personal data – as per legal deadlines

3.4.6. Processing purpose – Marketing

  • Maximum retention period of personal data – 7 years

3.5. The data processor has the right to share client personal data with third parties, such as authorized processors, accountants, transport and courier companies, and companies providing payment services. The data processor is the data controller. The data processor transmits the personal data necessary for payment processing to the authorized processor Montonio Finance OÜ.

3.6. In processing and storing personal data, the data processor implements organizational and technical measures to ensure the protection of personal data from accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.

3.7. The data processor stores the data of data subjects according to the processing purpose 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 review it.

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 the data processor processes the personal data of the data subject based on the data subject's consent, the data subject has the right to withdraw their consent at any time.

4.5. The data subject can exercise their rights by contacting the e-store's customer support at info@iupgrade.eu.

4.6. The data subject can also file a complaint with the Data Protection Inspectorate to protect their rights.

5. Final Provisions

5.1. These data protection conditions have been prepared in accordance with the European Parliament and Council Regulation (EU) 2016/679 on the protection of natural persons regarding the processing of personal data and the free movement of such data, 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 partially or fully amend the data protection conditions by notifying the data subjects via the website iupgrade.eu.