This Privacy Policy explains how Financial Triangulation OÜ collects, uses and protects personal data in connection with the website triangulation.ee (the “Website”) and our business communications. We process personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”) and the Personal Data Protection Act of the Republic of Estonia.
1. Data controller
The controller of your personal data is Financial Triangulation OÜ, commercial registry code 1737/0511, registered address Luise tn 4-46, Kesklinna linnaosa, 10142 Tallinn, Harju maakond, Estonia (“we”, “us”, “our”). For any questions about this Policy or your personal data, write to us at this address.
2. Personal data we process
We process only the personal data necessary for the purposes described below:
- Contact data you provide when you contact us: name, email address, phone number, company name, position and the content of your message.
- Business contact data of representatives and contact persons of our clients, partners and suppliers, processed in connection with the conclusion and performance of agreements.
- Technical data automatically recorded when you visit the Website: IP address, browser type and version, operating system, date and time of access and pages viewed (server log data).
The Website does not contain a contact form, user accounts or online payments, and we do not intentionally collect special categories of personal data.
3. Purposes and legal bases
- Responding to inquiries and communicating with you — our legitimate interest in answering requests (Art. 6(1)(f) GDPR) or taking steps at your request before entering into an agreement (Art. 6(1)(b) GDPR).
- Concluding and performing agreements with our clients and partners — performance of a contract (Art. 6(1)(b) GDPR) and our legitimate interest in communicating with representatives of legal entities (Art. 6(1)(f) GDPR).
- Complying with legal obligations, including accounting, tax and anti-money-laundering requirements — legal obligation (Art. 6(1)(c) GDPR).
- Ensuring the operation and security of the Website — our legitimate interest in protecting the Website against misuse (Art. 6(1)(f) GDPR).
- Establishing, exercising or defending legal claims — our legitimate interest (Art. 6(1)(f) GDPR).
4. Cookies
The Website uses only cookies and similar technologies that are strictly necessary for its technical operation. We do not use analytics, advertising or tracking cookies. If this changes, we will update this Policy and, where required by law, ask for your consent before such cookies are used.
5. Recipients of personal data
We do not sell personal data. We may share personal data only with:
- service providers acting on our behalf, such as website hosting, email and IT service providers, accountants and legal advisers, who process data under our instructions and on the basis of data processing agreements;
- banks and payment service providers, to the extent necessary for payments and compliance checks;
- public authorities, courts and other bodies, where required by applicable law.
6. Transfers outside the European Economic Area
Where personal data is transferred outside the European Economic Area, we ensure an adequate level of protection, for example on the basis of an adequacy decision of the European Commission or the Standard Contractual Clauses approved by the European Commission.
7. Retention periods
- Correspondence and inquiries that do not lead to an agreement — up to 3 years after the last communication.
- Agreements and related correspondence — for the term of the agreement and for the limitation period of possible claims thereafter.
- Accounting source documents — 7 years, as required by the Accounting Act of the Republic of Estonia.
- Server log data — up to 90 days, unless needed longer to investigate a security incident.
After the retention period ends, personal data is deleted or anonymised.
8. Your rights
Under the GDPR you have the right to request access to your personal data, rectification of inaccurate data, erasure of data, restriction of processing and data portability, and to object to processing based on our legitimate interests. Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing before withdrawal.
To exercise your rights, send a written request to our registered address above. We will respond within one month of receiving your request. You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee) or the supervisory authority of your place of residence or work in the EU.
9. Security
We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration or disclosure, including access restrictions, encrypted connections and confidentiality obligations of persons who have access to the data.
10. Changes to this Policy
We may update this Privacy Policy from time to time. The current version is always published on the Website with the date of the last update.
11. Contact
Financial Triangulation OÜ
Luise tn 4-46, Kesklinna linnaosa, 10142 Tallinn, Harju maakond, Estonia