Privacy Policy

1. General provisions

1.1. This Privacy Policy regulates the principles of collection, processing and storage of personal data. Personal data are collected, processed and stored by the data controller Wagenküll Hotell OÜ (hereinafter the data controller).

1.2. A data subject within the meaning of this Privacy Policy is a client or any other natural person whose personal data are processed by the data controller.

1.3. A client within the meaning of this Privacy Policy is anyone who purchases goods or services from the data controller’s website.

1.4. The data controller follows the principles of data processing laid down in legislation and, among other things, processes personal data lawfully, fairly and securely. The data controller is able to confirm that personal data have been processed in accordance with the requirements set out in legislation.

2. Collection, processing and storage of personal data

2.1. Personal data that the data controller collects, processes and stores are collected electronically, mainly via the website and e-mail.

2.2. By sharing their personal data, the data subject gives the data controller the right to collect, organise, use and manage personal data for the purposes defined in this Privacy Policy, which the data subject directly or indirectly shares with the data controller when purchasing goods or services on the website.

2.3. The data subject is responsible for ensuring that the data submitted by them are accurate, correct and complete. Knowingly providing false data is considered a violation of this Privacy Policy. The data subject is obliged to notify the data controller immediately of any changes in the submitted data.

2.4. The data controller is not liable for any damage caused to the data subject or third parties as a result of the data subject providing incorrect data.

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 name and surname;
3.1.2. Date of birth;
3.1.3. Telephone number;
3.1.4. E-mail 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 are 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:

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 controller is subject;

f) processing is necessary for the purposes of the legitimate interests pursued by the controller 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 period of storage of personal data – according to the deadlines specified in law

3.4.2. Purpose of processing – processing of orders

3.4.3. Purpose of processing – client management

3.4.4. Purpose of processing – financial activities, accounting

3.4.5. Purpose of processing – marketing

3.5. The data controller has the right to share clients’ personal data with third parties, such as authorised processors, accountants, transport and courier companies, and payment service providers. The data controller is the controller of personal data. For the performance of payments, the data controller transfers the personal data necessary for making payments to the authorised processor Maksekeskus AS.

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

3.7. The data controller stores data subjects’ personal data depending on the purpose of processing, but not longer than 1 year.

4. Rights of the data subject

4.1. The data subject has the right to gain access to their personal data and to view them.

4.2. The data subject has the right to obtain information regarding the processing of their personal data.

4.3. The data subject has the right to supplement or rectify inaccurate data.

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

4.5. To exercise their rights, the data subject may contact customer support at info@wagenkull.ee.

4.6. To protect their rights, the data subject may also lodge a complaint with the Data Protection Inspectorate.

5. Final provisions

5.1. These data protection terms have been drawn up 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 legislation of the Republic of Estonia and the European Union.

5.2. The data controller has the right to amend the data protection terms in part or in full by notifying data subjects of the changes via the website www.wagenkull.ee.