Privacy Policy of Kogemus & Elamus OÜ
(Applies also to Kogemus ja Elamus (OÜ) or K&E OÜ in written formats)

The following data protection principles cover Kogemus & Elamus OÜ’s (hereafter referred to as Kogemus & Elamus) practices related to the collection, storage, retention, and processing of personal data. Specifically, this document outlines the types of information we handle about individuals who visit our website at www.kogemusjaelamus.ee/eng/ (“Website”), use our products and services, or contact us in other ways, and how we use this data.

This Privacy Policy primarily applies to information we collect online, but the parts related to the General Data Protection Regulation (GDPR) may also apply to data shared with us privately or in other ways (e.g., at a seminar or via phone).

We created this Privacy Policy to demonstrate our strong commitment to privacy and security. It describes how we collect data from all users of our online services (“Services”), including those who use the Services without participating in our courses or being members of our Facebook or Instagram groups (“Guests”), as well as those who purchase products or Services, pay for courses, or participate in free courses (“Clients”).

Please read our Privacy Policy carefully. By visiting and using our Website and participating in courses, you agree that your use, as well as any privacy-related disputes, is governed by this Privacy Policy. In keeping with technological changes and evolving laws and regulations, we may need to update our Privacy Policy from time to time. In such cases, we will post the changes on our Website and update the effective date, which indicates when the changes were made. By continuing to use our Website or participate in courses after changes are made, you agree to the most recent version of the Privacy Policy.

INTRODUCTION

We may collect and store personal and other information voluntarily provided by individuals online or otherwise when they visit our Website, order an e-article from the Website, register for courses or events, or contact us to schedule consultations or advisory sessions or purchase a product. We may contact those who have provided us with their email addresses. We collect personally identifiable information when Guests or Clients register for events, courses, or consultations, join Kogemus & Elamus membership, participate in advisory services, or provide us with their email addresses in other ways. This information typically includes a name, email address, reason for attending advisory services or events, billing details, or contact information (phone number, mailing address, nearest parcel locker details), required for delivering physical materials or maintaining contact. All such data is provided to us directly by the individuals themselves.

We use the collected data in several ways, including to tailor our services and advertising, and to send helpful information via email. In certain cases, we may share collected information with third parties, such as service providers, partners, and advertisers, for the purposes described below. Unless a person notifies us otherwise as outlined below, we reserve the right to use and share with third parties any data they provide through our online channels or other means. This helps us and third parties offer more relevant product and service information, thus providing greater value to our Clients and Guests.

Please note that whenever someone voluntarily discloses personal information publicly (e.g., on their social media timeline, in online logs, emails, or comments), that information is visible, collectible, and usable by others besides us. We cannot be held responsible for any use of such unprotected information by third parties.

PERSONAL DATA COLLECTED BY KOGEMUS & ELAMUS AND HOW IT IS USED

Introduction

For paid courses/programs, advisory services, or Kogemus & Elamus membership, we request personal information from the buyer, including their name, the reason for attending, email address, and in the case of businesses, a postal address, phone number, and sometimes a home address. If multiple people are involved in a single purchase, we ask for their details as well. When joining the Value Letter, we ask for the first name, last name, and email address. These and any subsequent processes are primarily used to provide customized experiences and services for our product and service consumers. We do not disclose, trade, or sell this data to third parties, except in the specific cases described below, where data may be shared with known third parties.

What Information We Collect

We collect information during Website visits, when joining the community, registering for membership, courses, or consultations, ordering e-articles and webinar recordings, and signing up for the Value Letter. Additionally, we collect data through survey responses and participation in live events. We collect and store the following data: name, email address, billing address, phone number, home address (in some cases), nearest parcel locker details, survey responses, registration channel, IP address, timestamp, device type, operating system, web browser, email open and click data, user behavior, order details, location, Facebook and Instagram user data, photo, language, country, time zone, birthday (in some cases), feedback (we ask for separate permission for this).

How and Why We Use Personal Data

We collect, store, and manage personal data to operate, improve, and market our services; contact individuals when they express interest; respond to inquiries and emails (we do not use the response address for any other purpose); monitor and analyze trends like purchase history, sales reports, Website behavior, clicks, and email opening statistics; market our products and services through email marketing, advertising, and targeted ads on Google, Instagram, and Facebook; for administrative and legal purposes.

ACCESS TO PERSONAL DATA WITHIN KOGEMUS & ELAMUS

In our company, access to personal data is limited to those whose role is to make services and products available, contact clients, and respond to their inquiries (including processing refunds). Relevant employees or team members of Kogemus & Elamus are given access to data only to the extent necessary for fulfilling their duties.

ACCESS TO PERSONAL DATA OUTSIDE KOGEMUS & ELAMUS

Process Administrators

We use service providers to operate and develop our Website and assist with certain functions (e.g., list and customer data management, email delivery, surveys and campaigns, data hosting, marketing management, and some technical and customer support tasks). We take measures to ensure these service providers have access to personal data only to the extent required and for the purposes specified, confidentially, and in compliance with GDPR.

We use third-party solutions for marketing and its analysis. These processes occur on third-party platforms but through Kogemus & Elamus-associated accounts (e.g., Google Analytics). Data processing is in accordance with data protection rules.

Authorities

We may disclose personal data, including correspondence, to third parties if we deem it necessary and in compliance with the law, if required by authorities or auditors. We may also disclose personal data if we believe the person’s actions conflict with our published regulations and principles, or to protect Kogemus & Elamus’s rights, property, and safety, as well as to prevent fraud and malice.

DATA RETENTION

We retain certain collected information for as long as a member is on our Value Letter list or actively participates in events. In some cases, after the client relationship has ended, we retain data for the following reasons:

• To enable Website usage;
• To ensure we do not contact someone who has requested to no longer be contacted;
• To process refunds;
• To better understand Website traffic and offer all Members the best possible experience;
• To identify and prevent misuse of our Website, illegal activities directed at the Website, and violations of our service terms;
• To comply with applicable laws, tax, and accounting requirements.

When the purpose for retaining personal data is fulfilled or we no longer have a legal or business reason to store the data, we will delete or anonymize it.

DATA DISCLOSED TO THIRD PARTIES

Resellers

Sometimes links to courses, programs, consultations, or memberships are associated with reseller accounts. In such cases, the owner of the link has access to the information entered via that link. This may include email addresses, names, mailing addresses, or other requested information. Kogemus & Elamus is not responsible for the data clients provide to resellers.

Participation in Paid Services

If a client purchases our products or services, such as participating in our courses, workshops, programs, consultations, or community, we use the data entered during the purchase solely for processing that purchase. We do not share this data with other parties, except the organizers of specific courses facilitated by Kogemus & Elamus, to the extent necessary. Before confirming registration, the purchaser must review and agree to the terms and conditions, clearly referred to in the registration form before submitting the registration.

Kogemus & Elamus OÜ is the data controller and shares personal data required for payment processing with authorized processor Maksekeskus AS.

For more details or inquiries regarding this Privacy Policy, please contact us at kogemusjaelamus@gmail.com.