PRIVACY POLICY

1. General Provisions

1. General Provisions 1.1. This Privacy Policy sets out the principles governing the collection, processing, and storage of personal data. Personal data is collected, processed, and stored by the data controller. (Kadriart OÜ) (hereinafter referred to as the “Data Controller”).

1.2. For the purposes of this Privacy Policy, the data subject is the Customer or any other natural person whose personal data is processed by the Data Controller.

1.3. For the purposes of this Privacy Policy, the Customer is any person who purchases goods or services from the Data Controller’s website.

1.4. The Data Controller follows the principles of data processing established by applicable legislation and, among other things, processes personal data lawfully, fairly, and securely. The Data Controller is able to demonstrate that personal data has been processed in accordance with the requirements set out in applicable legislation.

2. Collection, Processing, and Storage of Personal Data

2.1. The personal data collected, processed, and stored by the Data Controller is collected electronically, primarily through the website and by email. 

2.2. By providing their personal data, the Data Subject grants the Data Controller the right to collect, organize, use, and manage the personal data shared by the Data Subject directly or indirectly when purchasing goods or services through the website, for the purposes defined in this Privacy Policy.

2.3. The Data Subject is responsible for ensuring that the information provided by them is accurate, correct, and complete. Knowingly providing false information is considered a violation of this Privacy Policy. The Data Subject is required to notify the Data Controller immediately of any changes to the information provided.

2.4. The Data Controller is not liable for any damage caused to the Data Subject or third parties as a result of false information provided by the Data Subject.

## 3. Processing of Customers’ 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;

Expand the list to include any other types of personal data that are processed. Remove any items from the list that are not collected.**

3.2. In addition to the above, the Data Controller has the right to collect information about the Customer 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 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 for taking 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 a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject that require the protection of personal data, particularly 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 for personal data – in accordance with the periods prescribed by law.

3.4.2. **Purpose of processing – order processing**
Maximum retention period for personal data – 7 years.

3.4.3. **Purpose of processing – ensuring the operation of the online store services**
Maximum retention period for personal data – until the Customer’s account is deleted.

3.4.4. **Purpose of processing – customer management**
Maximum retention period for personal data – until the Customer’s account is deleted.

3.4.5. **Purpose of processing – financial activities and accounting**
Maximum retention period for personal data – in accordance with the periods prescribed by law.

3.4.6. **Purpose of processing – marketing**
Maximum retention period for personal data – until the Customer’s account is deleted or until the Customer is removed from the email list.

3.5. The Data Controller has the right to share customers’ personal data with third parties, including, for example, authorized data processors, accountants, transportation and courier companies, and companies providing payment and money transfer services. The Data Controller acts as the controller of the personal data. The Data Controller transfers the personal data necessary for processing payments to the authorized data processor Maksekeskus AS.

3.6. When processing and storing the Data Subject’s personal data, the Data Controller implements appropriate organizational and technical measures to ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, or any other unlawful processing.

3.7. The Data Controller retains the personal data of Data Subjects depending on the purpose of processing, but for 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 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 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 the online store’s customer support at: (info@minnijewels.com).

4.6. The Data Subject has the right to lodge a complaint with the Estonian Data Protection Inspectorate to protect their rights.

5. Final Provisions

5.1. These Privacy Policy provisions 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, 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 Controller has the right to amend these Privacy Policy provisions in whole or in part by notifying Data Subjects of any changes through the website (https://minnijewels.com).

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