Privacy Policy

Your privacy is important to us. Brykkar Oü's policy is to respect your privacy and comply with all applicable laws and regulations regarding any personal information we may collect about you, including throughout our website, https://www.brykkar.ee and other sites we own and operate.

Personal information is any information about you that can be used to identify you. This includes information about you as an individual (such as name, address and date of birth), your devices, payment details and even information about how you use a website or online service.

If our site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After linking to any third-party content, you should read their posted privacy policy for information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our Site.

This policy is effective from July 1, 2024.

Last updated: 1. July 2024.

Cumulative information

The information we collect falls into two categories: "voluntarily submitted" information and "automatically collected" information.

Voluntary Information refers to information that you knowingly and actively provide to us when you use or participate in any of our Services and Promotions.

Automatically Collected Information refers to any information that your devices automatically send to access our products and services.

Log data

When you visit our website, our servers may automatically log standard data provided by your web browser. This may include your device's Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other visit details.

In addition, if you experience certain errors while using the Site, we may automatically collect data about the error and the circumstances in which it occurred. This data may include technical details of your device, what you tried to do when the error occurred, and other technical information related to the problem. You may or may not be notified of such errors even at the time they occur, their occurrence, or the nature of the error. 

Please note that while this information may not be personally identifiable by itself, it may be possible to combine it with other information to identify individual individuals.

Device data

When you visit our website or interact with our services, we may automatically collect information about your device such as:

  • Device type
  • Operating System
  • Unique device identifiers
  • Device settings
  • Geolocation data

The data collected may depend on the individual settings of your device and software. We recommend that you consult the policies of your device manufacturer or software provider to find out what information they make available to us.

Personal information

We may ask you for personal information, for example when you subscribe to our newsletter or when you contact us, and this may include one or more of the following:

  • By them
  • E-mail
  • Social media profiles
  • Date of birth
  • Telephone / mobile phone number
  • Postal code / address

Legitimate reasons for processing your personal data

We only collect and use your personal data if we have a legitimate reason to do so. In this case, we will only collect personal information that is reasonably necessary to provide you with the Services.

Tea collection and use

We may collect personal information from you when you do the following on our website:

  • Register to create an account
  • You participate in our competitions, sweepstakes and surveys
  • You sign up to receive updates from us via email or social media channels
  • You use a mobile device or web browser to access our content
  • You contact us by email, social media or other similar technologies
  • You mentioned us on social media

We may collect, hold, use and disclose information for the following purposes, and personal data will not be further processed in a manner incompatible with these purposes:

  • to provide you with the core features and services of our platform
  • to customize or personalize your experience on our website
  • deliver products and/or services to you
  • to contact you and communicate
  • for analytics, market research and business development, including managing and improving our website, related apps and related social media platforms
  • for advertising and marketing, including providing you with promotional information about our products and services and information about third parties that we think may be of interest to you
  • to enable you to access and use our website, related applications and related social media platforms
  • for internal record keeping and administrative purposes
  • to run contests, sweepstakes and/or provide you with additional benefits
  • comply with our legal obligations and resolve any disputes we may have
  • attribute the content you enter (such as posts and comments) that we publish on our website
  • for security and fraud prevention and the safety, security and use of our Sites and Apps
    per our terms of use
  • for technical evaluation, including the use and improvement of our App, related applications and related social media platforms

We may combine voluntarily provided and automatically collected personal data with general information or research data obtained from other reliable sources. For example, during our marketing and market research, we may discover data and insights that we may combine with information about how visitors use our site to improve our site and your experience on it.

The security of your personal data

When we collect and process personal information and store that information, we protect it in a commercially acceptable manner to prevent loss and theft, and to prevent unauthorized access, disclosure, copying, use or alteration.

Although we do our best to protect the personal information you provide to us, we emphasize that no method of electronic transmission or storage is 100% secure and no one can guarantee absolute data security.

You are responsible for choosing any password and its overall security strength, ensuring the security of your information within our Services. For example, ensure that passwords associated with access to your personal information and accounts are secure and confidential.

How long we keep your personal data

We only keep your personal data for as long as necessary. This period of time may depend on what we use your information for in accordance with this Privacy Policy. For example, if you have provided us with personal information during account creation, we may retain that information for as long as your account exists in our system. If your personal information is no longer needed for this purpose, we will delete it or anonymize it by removing all information that identifies you.

However, if necessary, we may retain your personal data to comply with legal, accounting or reporting obligations or for archival purposes in the public interest, scientific or historical research or statistical purposes.

Last privacy

We do not target any of our products or services directly to children under the age of 13, and we do not knowingly collect personal information from children under the age of 13.

Disclosure of personal data to third parties

We may disclose personal information to the following persons:

  • a parent, subsidiary or affiliate of our company
  • third party service providers to enable them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, advertising networks, analytics, error collectors, debt collectors, maintenance or problem resolution providers, marketing or advertising providers, professional advisors and payment system operators
  • our employees, contractors and/or related entities
  • our existing or potential agents or business partners
  • sponsors or promoters of contests, sweepstakes or promotions that we run
  • credit reporting agencies, courts, tribunals and regulatory authorities, in the event that you fail to pay for goods or services provided to you
  • courts, tribunals, regulatory agencies and law enforcement officials, as required by law, in connection with any actual or future legal proceedings or to establish, exercise or defend our legal rights
  • third parties, including agents or subcontractors, who assist us in providing you with information, products, services or direct marketing
  • to third parties for data collection and processing
  • an entity that purchases or to which we transfer all or substantially all of our assets and business

Third parties currently in use include:

  • Google Analytics
  • Claviyo
  • Bitespeed
  • Google Adsense
  • Bing ads
  • META ads

Your rights and control of your personal data

Your choice: By providing us with personal information, you understand that we will collect, store, use and disclose your personal information in accordance with this Privacy Policy. You are not required to provide us with personal information, but failure to provide it may affect your use of our website or the products and/or services offered on or through it.

Third Party Information:If we receive personal information about you from a third party, we will protect it in accordance with this Privacy Policy. If you are a third party that provides personal information about someone else, you represent and warrant that you have the consent of such person to provide us with personal information.

Marketing Consent:If you have previously agreed to us using your personal data for direct marketing purposes, you can change your mind at any time by contacting us using the details below.
Access: You can request details of the personal information we hold about you.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details in this Privacy Policy. We will take reasonable steps to correct inaccurate, incomplete, misleading or out-of-date information.

Non-discrimination:we will not discriminate against you for exercising your rights with respect to personal information. Unless your personal information is required to provide a specific service or offer (such as providing help desk support), we will not deny you goods or services and/or charge you different prices for goods or services, including giving you discounts or other benefits or penalties, or offer you different levels or quality goods or services.

Reporting of data breaches:we comply with all applicable laws regarding breaches of our data.

Complaints: if you believe that we have breached relevant data protection law and would like to make a complaint, please contact us using the details below and provide us with details of the alleged breach. We will investigate your complaint promptly and respond to you in writing with the results of our investigation and the steps we are taking to resolve your complaint. You also have the right to address your complaint to a regulatory authority or a data protection authority.

Unsubscribe:To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details in this privacy policy or opt out of the opt-out options provided in the notice. We may need to ask you for specific information to help us identify you.

Use of cookies

We use cookies to collect information about you and your activities on our site. A cookie is a small piece of data that our website stores on your computer and is accessed each time you visit so that we can understand how you use our site. This helps us deliver content based on the preferences you set.

More information can be found in our cookie policy.

Business transfer

If we or our assets are acquired or (in the unlikely event) we go out of business or enter bankruptcy, we will include data, including your personal data, among the assets of all of our acquired parties. You acknowledge that such transfers may occur, and that any parties that acquire us may, to the extent permitted by applicable law, continue to use your personal information in accordance with this Policy, which they must assume is the basis of any ownership or use rights in such information.

Our policy boundaries

Our website may link to external sites that we do not control. Please note that we have no control over the content and policies of these sites and cannot be responsible or liable for their respective privacy practices.

Changes to this policy

At our discretion, we may change our Privacy Policy to reflect updates to our business processes, current acceptable practice, or legislative or regulatory changes. If we decide to change this Privacy Policy, we will post the changes here at the same link through which you access this Privacy Policy.

If the changes are material or required by applicable law, we will contact you (based on the preferences you have chosen for our communications) and all of our registered users with new details and links to the updated or revised policies.

If required by law, we will obtain your permission or give you the opportunity to opt-in or opt-out of new uses of your personal information.

Additional General Data Protection Regulation (GDPR) Compliance Disclosures (EU)

Data controller / data processor

The GDPR distinguishes between organizations that process personal information for their own purposes (so-called data controllers) and organizations that process personal data on behalf of other organizations (so-called data processors). We, Brykkar Oü located at the address provided in the Contact Information, are the data controller for the personal data you provide to us. 

Legal basis for processing your personal data

We only collect and use your personal data if we have a legal right to do so. In this case, we will collect and use your personal data lawfully, fairly and transparently. If we ask for your consent to process your personal data, and if you are under 16, we will ask for your parent's or legal guardian's consent to process your personal data for that specific purpose.

Our lawful bases depend on the services you use and your use of them. This means that we will only collect and use your information on the following basis:

Your consent

If you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the options we provide; however, this will not affect the use of your information that has already taken place. You may consent to the transmission of your name and contact information to enter a sweepstakes or offer. Although you can withdraw your participation at any time, this will not affect any choices or decisions that have already taken place. If you have any further inquiries about withdrawing your consent, please refer to the Contact Us section at the end of this Privacy Policy.

Execution of the contract or transaction

If you have entered into a contract or transaction with us or to take preparatory steps before entering into a contract with us or you. For example, if you contact us with an inquiry, we may require personal information, such as your name and contact information, in order to respond.

Our legitimate interests

If we deem it necessary for our legitimate interests, such as to provide, manage, improve and report on our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and advertising the Services, measures taken to make the Services work effectively, marketing analysis and measures taken to protect our legitimate rights and interests.

Compliance with laws

In some cases, we may have a legal obligation to use or retain your personal information. Such incidents may include, but are not limited to, court orders, criminal investigations, government requests, and regulatory obligations. If you have any further queries about how we store personal data to comply with the law, you can check the Contact Us section of this Privacy Policy.

International transfers outside the European Economic Area (EEA)

We ensure that any transfer of personal data from European Economic Area (EEA) countries to non-EEA countries is protected by appropriate safeguards, such as using standard data protection clauses approved by the European Commission or the use of binding company rules or other legally recognized means.

Your rights and control of your personal data

Restriction: you have the right to request that we restrict the processing of your personal data if (i) you are concerned about the accuracy of your personal data; (ii) you believe that your personal data has been unlawfully processed; (iii) you need us to retain your personal information only for the purpose of a legal requirement; or (iv) we consider your objection to the processing on the basis of legitimate interests.

Objection to processing:You have the right to object to the processing of your personal data based on our legitimate interests or public interest. Once this is done, we must provide compelling legitimate grounds for the processing that override your interests, rights and freedoms in order to process your personal data.
Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we provide this information in CSV or other easily machine-readable format. You may also have the right to request that this personal data be transferred to a third party.

Deletion: You may have the right to request the deletion of any personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of the website or products and services. There may be exceptions to this right for specific legal reasons, which we will provide in response to you as appropriate. If you terminate or delete your account, we will delete your personal information within 24 days of deleting your account. Please note that search engines and similar third parties may still retain copies of your personal information that has been disclosed at least once, such as certain profile information and public comments, even after you have deleted the information from our Services or deactivated your account.

Contact us

If you have questions or concerns about your privacy, you can contact us using the following information:

Rauno Kutti
info@brykkar.ee