Privacy Policy
Last Updated: [Date, e.g., January 20, 2026]
1. General Provisions
This Privacy Policy describes how CLUBS TRAVEL OÜ, a company registered in Estonia (registry code 10746676), processes the personal data of users of the website clubstravel.ee.
- Data Controller: CLUBS TRAVEL OÜ
- Address: Narva Maante 7D, korpus b, 4 korrus
- Email: info@clubstravel.ee
2. What Personal Data We Collect
We collect data that you provide directly to us and data collected automatically:
- Identity Data: Name, surname, date of birth (if applicable).
- Contact Data: Email address, phone number, shipping/billing address.
- Technical Data: IP address, browser type, cookies, and usage data via Google Analytics or similar tools.
- Transaction Data: Details about payments and services/products purchased.
3. Legal Basis for Processing
In accordance with Article 6 of the GDPR, we process data based on:
- Contractual Necessity: To fulfill your orders or provide services.
- Legal Obligation: To comply with Estonian accounting and tax laws.
- Legitimate Interest: To improve our website, prevent fraud, and for direct marketing (where permitted).
- Consent: Where you have explicitly agreed (e.g., subscribing to a newsletter).
4. Data Retention
We retain personal data only as long as necessary:
- Accounting Data: 7 years (as required by the Estonian Accounting Act).
- Marketing Data: Until you withdraw consent or for [e.g., 2 years] of inactivity.
- Customer Account Data: As long as the account is active.
5. Sharing Your Data
We do not sell your data. We share it only with trusted partners:
- Payment Providers: [e.g., Montonio, Maksekeskus, Stripe]
- Logistics: [e.g., Omniva, Itella Smartpost, DPD]
- IT/Cloud Services: [e.g., Google, AWS]
- Public Authorities: Only when legally required by Estonian law.
6. International Transfers
If we transfer data outside the EU/EEA, we ensure a similar level of protection is afforded to it by using Standard Contractual Clauses (SCCs) approved by the European Commission.
7. Your Rights
Under the GDPR, you have the following rights:
- Right of Access: Request a copy of your data.
- Right to Rectification: Correct inaccurate data.
- Right to Erasure: Request deletion (“Right to be forgotten”).
- Right to Restriction/Objection: Limit how we use your data.
- Data Portability: Receive your data in a machine-readable format.
To exercise these rights, contact us at [Email Address]. We will respond within 30 days.
8. Cookies
We use cookies to enhance your experience. You can manage your preferences through our cookie banner or browser settings.
- Essential: Required for site functionality.
- Analytical/Marketing: Only used if you provide consent.
