Last update: 2025-03-26

1. General provisions

1.1. This privacy policy regulates the principles of collection, processing, and storage of personal data. Personal data is processed and stored by Guldra & Partners OÜ, who is the controller of the personal data (hereinafter the controller).

1.2. For the purposes of this privacy policy, a data subject means the customer or another natural person whose personal data is processed by the controller.

1.3. For the purposes of this privacy policy, a customer means anyone who purchases goods or services on the controller’s website.

1.4. The controller observes the principles relating to personal data processing provided by legislation and, among other things, processes personal data in a lawful, fair, and secure manner. The controller is able to declare that personal data has been processed in accordance with the provisions of the legislation.

2. Collection, processing, and storage of personal data

2.1. The personal data collected, processed, and stored by the controller has been collected electronically, mainly via the website and e-mail.

2.2. By sharing their personal data, the data subject grants the controller the right to collect, arrange, use and administer, for the purpose defined in the privacy policy, the personal data that the data subject shares with the controller either directly or indirectly when purchasing goods or services on the website.

2.3. The controller may collect certain technical data when the data subject interacts with the website. This includes, but is not limited to, IP address, browser type, operating system, device type, and browsing behavior. This data is collected automatically and used to ensure the security and proper functioning of the website, improve user experience, and analyze website traffic. The data is stored for a period of 1 year and is processed in accordance with applicable data protection laws.

2.4. The data subject is liable for the accuracy, correctness, and integrity of the data submitted by them. The submission of knowingly false data is regarded as a breach of the privacy policy. The data subject is required to immediately notify the controller of any changes in the data submitted.

2.5. The controller is not liable for any damage or loss caused to the data subject or a third party as a result of the submission of false data by the data subject.

3. Processing of personal data of customers

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

3.1.1. Given 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 foregoing, the controller has the right to collect data about the customer that are available in public registers.

3.3. The legal basis for the processing of personal data points (a), (b), (c) and (f) of Article 6(1) of the General Data Protection Regulation:

(a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;

 (b) processing is necessary for the performance of a contract to which the data subject is a 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. The controller may process collected personal data to enhance the quality of services, optimize website functionality, and improve customer experience. This includes analyzing purchasing patterns, identifying technical issues, and refining customer support processes. The data used for these purposes is anonymized whenever possible. Any personally identifiable information will be processed in compliance with applicable data protection regulations.

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

3.5.1. Purpose of processing – security and safety

 The maximum period of storage of personal data – according to the terms specified by law

3.5.2. Purpose of processing – the processing of orders

 Maximum period of storage of personal data – 1 year

3.5.3. Purpose of processing – ensuring the functioning of online store services

 Maximum period of storage of personal data – 2 years

3.5.4. Purpose of processing – customer management

 Maximum period of storage of personal data – 3 years

3.5.5. Purpose of processing – financial activities, accounting

 Maximum period of storage of personal data – according to the terms specified by law

3.5.6. Purpose of processing – marketing

 Maximum period of storage of personal data – 2 years

3.6. The controller may use third-party service providers such as Maksekeskus, Klaviyo, Google Analytics, Google Ads, Google Tag Manager, Meta, or other services to provide personalized advertising and promotional offers. This may involve processing customer data, including browsing history, purchasing behavior, and interaction with marketing campaigns. The data subject has the right to opt out of targeted marketing at any time by adjusting their privacy settings or contacting customer support at info@swishtime.eu.

3.7. The controller has the right to share personal data of customers with third parties such as processors, accountants, transport and courier companies, companies providing transfer services. The controller is in charge of the processing of personal data. The controller transmits the personal data necessary for making payments to the processor, Maksekeskus AS.

3.8. The controller processes and stores personal data of the data subject implementing the organizational and technical measures to ensure that the personal data is protected against any accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.

3.9. The controller stores the data of the data subjects depending on the purpose of processing, but no longer than for 3 years.

4. Rights of the data subject

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

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

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

4.4. If the controller processes personal data of the data subject based on the consent granted by the latter, the data subject has the right to withdraw their consent at any time.

4.5. The data subject has the right to request the deletion of their personal data under certain conditions, such as when the data is no longer necessary for the purpose for which it was collected, or when the data subject withdraws consent. Requests for data deletion can be submitted to info@swishtime.eu. The controller will assess each request in accordance with applicable legal requirements and inform the data subject of the outcome. Please note that certain legal obligations may require the controller to retain specific personal data despite a deletion request.

4.6. To exercise their rights, the data subject can contact the customer support of the online store at (info@swishtime.eu).

4.7. To protect their rights, the data subject can file a complaint with the Data Protection Inspectorate.

5. Final provisions

5.1. These data protection terms and conditions have been prepared in compliance 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.

5.2. The controller has the right to amend the data protection terms and conditions in part or in full, notifying the data subjects of the amendments via (swishtime.eu).

Guldra & Partners OÜ is the controller of personal data, Guldra & Partners OÜ transfers the personal data necessary for making payments to the authorized processor Maksekeskus AS.