Privacy Policy

Date of publication: 01 July 2019

Current version is available at here:

1. What does this Privacy Policy cover

This Privacy Policy (“Policy”) covers any information, about you that may include personal data as defined by applicable laws and regulations (“Personal information”), which the Company RGZ.EE OÜ (“Company”) may obtain when you use any of the Company websites, programs, products or services, (collectively, the “Services”), information about which you can find on rgz.ee and romazolotarev.com (collectively, the “Sites”), and as well as during the performance of any contract or agreement the Company conclude with you in relation to your using the Services. Also, Personal information can be obtained by the Company through its partners (“Partners”), such as advertising partners, who provide you with access to or let you use websites, programs, products or services owned or operated by them. Partners can provide Personal information to the Company only as stipulated by applicable laws and regulations and in accordance with special agreements between the Company and each of the Partners.

Payment transactions are processed by Paddle. Paddle Buyer Privacy Notice available at https://paddle.com/privacy-buyers/.

2. Who processes your personal information

To provide you with access to the Sites and Services, your Personal information is collected and used by Sole trader Roman Zolotarev registration number 317169000003180.

3. What is the purpose of this Policy

When you use the Sites and/or Services, the Company processes your Personal information and ensures its protection in strict compliance with applicable laws and regulations.

4. What type of Personal information is collected

Personal information collected when you use the Sites and/or Services may differ depending on whether you access the Sites or Services while logged in to your user account or without logging in. When you are logged in to your user account as you are using the Sites or Services, Personal information collected by the Company may be collated and combined with other Personal information collected by the Company in your user account.

The Company does not verify Personal information provided by you and cannot posit if it is true and whether you have the legal capacity required. However, the Company assumes that the information you provide is true, sufficiently complete and up-to-date.

Personal information collected by the Company when you access, interact with or operate the Sites and/or Services includes:

(i) Information provided by you when you register (create) a user account, such as your name and email address;

(ii) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser information, information about your hardware and software);

(iii) date and time of accessing the Sites or Services;

(iv) information related to your activity when using the Sites or Services; and

(v) information about you that we may receive from a Partner of the Company in accordance with an agreement you made with this Partner and an agreement between the Company and this Partner.

In addition, the Company uses cookies and web beacons (including pixel tags) to collect your Personal information and associate this Personal information with your device and web browser (see Section 10 below).

The Company does not actively collect any sensitive personal data (such as racial origins, political opinions, health, or biometric data).

The Company does not perform any form of profiling which has the potential to significantly impact your rights and freedoms.

5. What are the legal basis and the purposes for processing your

Personal information

The Company is not allowed to process your Personal information if it does not have a valid legal ground. The Company will therefore only process your Personal information if:

(i) The processing is necessary to perform our contractual obligations towards you including providing you with Sites and/or Services;

(ii) the processing is necessary to comply with our legal or regulatory obligations; or

(iii) in case it is provided by applicable law, the processing is necessary for the legitimate interests of the Company and does not unduly affect your interests or fundamental rights and freedoms. Please note that when the Company processes your Personal information on this basis, the Company will always seek to maintain a balance between legitimate interest of the Company and the protection of your privacy.

Examples of such legitimate interests are:

(iv) for specific purposes we may ask your consent for processing of your Personal information.

The Company always processes your Personal information for a specific purpose and only processes Personal information which is relevant to achieve that purpose. In particular, we process your Personal information for the following purposes:

(i) To provide you with the Sites and/or Services;

(ii) to provide you with access to your user account;

(iii) to contact you to notify and/or inform you or request information from you in relation to the Sites and Services, or to execute our agreements with you or process your request or application;

(iv) to provide advertisements and/or commercial offers based on your preferences and other Personal information available to the Company;

(v) to improve user experience;

(vi) to develop new products, applications, and services;

(vii) to protect your rights and the rights of the Company; and

(viii) to collect, process and present statistical data, or perform other research and/or analysis of Personal information.

6. How your Personal information is protected

In most cases, Personal information is processed automatically. To protect your Personal information and ensure its confidentiality, the Company follows technical and organisational measures to protect Personal information against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of Personal information.

7. Who else has access to your Personal information

The Company may transfer Personal information to third parties to complete the purposes listed in Section 5 above. Such third parties may include:

(i) Partners, such as media publishers, advertising networks and other partners providing Company with services related to the placement and display of advertisement on the websites, programs, products and/or services owned or operated by such Partners;

(ii) advertisers or other Partners serving targeted advertisement on the Company Sites or Services; and third parties who process Personal information, such as IT systems providers and/or consultants.

(iii) any third party to whom we assign or novate any of our rights or obligations under a relevant agreement;

(iv) any national or international regulatory, enforcement, exchange body, central or local government department and other statutory or public bodies or court where we are required to do so by applicable law or regulation at their request;

(vi) third parties if you expressed your consent to such transfer or transfer of your Personal information is required for your use of a certain Service or performance of a particular agreement or contract with you;

(iv) any third party to ensure legal protection for the Company and/or the third parties if you violate the User Agreement of any of the Company Services (https://rgz.ee/terms.html), this Policy, or if there is a threat of such violation.

8. For how long do we store your Personal information

The Company will only keep your Personal information for as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal and regulatory requirements.

If you wish to have any Personal information removed from databases of the Company, you can have it removed via your account or using interface of the Sites or Services (where applicable).

9. Your rights

9.1 What are your rights

If it is provided by applicable law, you have a right of access to your Personal information as processed by the Company under this Policy.

If you believe that any information we hold about you is incorrect or incomplete, you can log in to your user account and correct your Personal information yourself.

If it is provided by applicable law, you also have the right to:

The Company will honour any such requests or objections as required under applicable law.

To the extent provided by applicable law, you may be subject to other rights not specifically mentioned herein.

9.2 How can you exercise your rights

To exercise the above rights, please log in to your user account, which will provide you with the option to do so, or in case of absence of special function in user account interface please contact the Company (see Section 12 hereof).

If you are not satisfied with how the Company processes your Personal information, please let the Company know and the Company will investigate your concern. If you are not satisfied with response from the Company, you have the right to make a complaint to the competent data protection authority.

10. How do we use cookies

10.1 What are cookies

Cookies are small text files placed on the device you use to access our Sites. They contain information that is collected from your device and sent back to the Sites on each subsequent visit so as to remember your actions and preferences over time.

The following types of cookies are used on the Sites:

10.2 How long are those cookies stored on your device

Company only uses the information contained in the cookies for the above purposes, after which the data collected will remain stored on your device for a period that may depend on cookies type, but no longer than necessary to achieve their purpose and will be automatically removed from your system thereafter.

10.3 Who else has access to the information contained in the


Personal information collected through cookies placed on your device may be transmitted to and accessed by the Company or the third parties referred to in Section 7 hereof. The use of Personal information outside of the Sites for advertising purposes, if any, may be subject to separate policies available on the above third parties’ websites. The Company or those third parties might also provide you with a possibility to opt out of receiving targeted advertising, which shall be subject to laws and regulations applicable to such products, utilities and offerings.

You can delete the cookies stored by your browser (usually via the options in your browser’s Privacy menu — please refer to your browser’s manual or developer’s website). If you do not consent to the use of cookies, certain features of the Sites might become unavailable, which may affect your browsing experience. You may also set up your browser preferences to accept or decline by default all cookies or cookies from specific websites, including the Sites.

The Company may also use web beacons (pixel tags) in order to access the cookies previously placed on your computer for the following purposes:

(i) to track your actions on the Sites and when using the Services, by accessing and interacting with the cookies stored on your computer;

(ii) to collect statistical information related to operating the Sites, the Services or products, utilities, advertisements or other Company offerings.

11. Updates to this Policy

This Policy may be subject to amendments. The Company shall be entitled to make such amendments at discretion of the Company, including, without limitation, to reflect changes in applicable legislation or amendments to the Sites and/or Services.

The Company undertakes not to introduce significant changes, imposing additional obligations or reducing your rights under this Policy without proper notice to you. You will be notified about such changes. If applicable, changes will be announced on the Site (e.g. via a pop-up or web banner) prior to such changes taking effect, and you may also be notified via other channels (e.g. by email) if you have provided us with your contact details.

12. Questions and Suggestions

The Company welcomes your questions or suggestions concerning implementation of or amendments to this Policy. To contact the Company please use this feedback form:

You can also use this form to exercise your rights or report any inaccuracies in your Personal information or protest its processing.