Privacy Policy

1. What is the purpose of this Privacy Policy?

This Privacy Policy (“Privacy Policy”) helps understand what data are collected by VINSPY OÜ, legal entity reg. No. 149325177, Karja 2-42 Paide, Estonia (“Service Provider”), on the website (“Website”), by telephone and/or e-mail and what such data are used for. 

2. What personal data do we collect? 

When you visit our Website or office, contact us by e-mail or phone, we collect the following information: 

  • For the purpose of registration: e-mail address. These personal data are processed on the basis of a contract and stored for ten (10) years after your last visit to our Website.
  • For the purpose of providing services: e-mail address, name, surname, phone number, information about payment for the service and other information voluntarily provided by you. These personal data are processed on the basis of a contract and stored for ten (10) years after your last visit to our Website.
  • For the purpose of direct marketing: name, surname, e-mail address, phone number. The Service Provider processes your personal data for direct marketing purposes on the basis of legitimate interest and/or your consent.

Unless you expressly object to receiving direct marketing messages by clicking “I do not agree” when purchasing a product and/or service on the Website, the Service Provider shall process your (as the Service Provider’s client) personal data (name, surname, position, e-mail address) for direct marketing purposes and send you e-mail messages on the basis of lawful interest in order to contact you and provide you with the news and other information about the products and/or offers of the Service Provider. In each direct marketing message, you will be given the opportunity to opt out of receiving direct marketing messages by notification to the given e-mail address or by other means specified in this Privacy Policy.

Based on your consent, the Service Provider shall process the following personal data: name, surname, phone number, e-mail address.

Based on your consent and/or legitimate interest of the Service Provider, your personal data shall be processed for five (5) years after your last actions on our Website (login, registration and/or other active steps).

  • Information about your computer, your visits and use of the Website and/or Mobile App, including your IP address and time and date of login to the Website and/or Mobile App. These data shall be processed on the basis of your consent and stored for the time period set out in the table below. For more information, see “Cookies”.
  • Any other personal data, which may be provided by you at any time in the course of our communication: by e-mail, letter, phone or upon your arrival at our office. These data shall be processed on the basis of your consent and stored for two years. In case you submit a complaint, claim or request by e-mail, in writing or otherwise, the data voluntarily provided by you shall be processed for the purpose of administration of such complaint, claim and/or request and stored for ten (10) years.

3. Cookies

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer with your consent. We use different cookies for different purposes. Cookies help us to distinguish you from other users of the Website and thus ensure a more enjoyable browsing experience and improve our Website.

Most browsers allow you to reject all cookies and some browsers allow rejecting only third-party cookies. You may take advantage of these options. For more information, see the user guide of your browser or device. However, please note that rejecting all cookies will have a negative impact on the use of the Website and you will not be able to use all services provided on the Website without cookies.

We use the following cookies (a detailed list is available HERE):

(a) Strictly necessary cookies. 

These cookies are required for the operation of our Website. These can be the cookies that, for example, give you access to protected Website areas, allow you to register for events or use other services. 

(b) Analytical and/or performance cookies. 

They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are easily finding what they are looking for. The basis for the processing of data collected by these cookies is your consent. 

(c) Functionality and advertising cookies. 

These cookies are used to recognize the clients when they return to the Website. This allows us to show you customized content, remember the information relevant to you and advertise. The basis for the processing of data collected by these cookies is your consent.

However, if you object to the use of cookies and/or want to withdraw your consent, please inform us by e-mail [email protected].

4. Direct marketing

If you wish to receive our news and offers, you may give consent for direct marketing during registration on our Website by clicking “I AGREE” to receive news and offers by e-mail and phone.

You may opt out of receiving direct marketing messages free of charge at any time by informing us by e-mail [email protected] and/or clicking on the respective link in any message about offers sent to you.

5. Social media

All information provided by you using social media (including the use of Like and Follow buttons and other communication) is controlled by the social network controller. 

The Website contains links to our social media accounts. Currently, we have the following social media account:

Facebook: @vinspy; Facebook privacy notice is available at

We recommend that you read the privacy notices of third parties and directly contact service providers if you have any questions as to how they use your personal data. 

6. Personal data of children

The services provided on the Website are intended for people over 14. In case of reasonable suspicion that we are processing the data of persons younger than specified herein, we shall delete such data from the databases.

7. Recipients of the data

We may disclose the information about you to our employees, managers, agents, suppliers or subcontractors, if reasonably necessary (e.g. financial transactions on the Website may be processed by our payment service providers), Website hosting providers, server and server maintenance providers, e-mail service providers, etc.

In addition, we may disclose information about you:

  • if required to do so by law;
  • in order to protect our rights or interests (including the transfer of your data to third parties with the purpose of recovering your debt to us).

Except as provided in this Privacy Policy, we do not provide your personal data to any third parties. We may transfer your personal data to third parties with the purpose of offering you a product and/or service with your prior consent only. However, if you have given consent to transfer your data to third parties, you may withdraw this consent at any time.

In each case of transfer of your personal data to a third country, one of the following conditions shall be met: (i) the data is transferred to a country for which a decision on adequacy has been made; (ii) data transfer is carried out using appropriate safety measures required by legislation; (iii) if data cannot be transferred in accordance with points (i) and (ii), derogations set out in legislation shall be observed.

8. Security of personal data

Your personal data shall be processed in accordance with the requirements of the Law on Legal Protection of Personal Data of the Republic of Estonia and other legislation. When processing your personal data, we implement organisational and technical measures to protect personal data against accidental or unlawful destruction, alteration, disclosure as well as from any other unauthorised form of processing.

However, data transmission over the internet is inherently insecure and we cannot guarantee secure transmission of data over the internet.

9. What are your rights?

You have the right to: 

  • submit a written request to receive information whether we process any data related to you; if we do, you have the right to access your personal data and receive the following information: purposes of data processing; categories of personal data; data recipients or categories of data recipients who have received or will receive your personal data; where possible, the expected period of storage of personal data or, where not possible, the criteria for determining the storage period; 
  • request to rectify inaccurate data or supplement incomplete personal data related to you; 
  • request that we delete your personal data. Nevertheless, this right is not absolute and can only be justified by at least one of the following reasons: personal data are no longer needed to achieve the purposes they were collected or otherwise processed for; you decide to withdraw your consent to process your personal data, where your data is processed solely on the basis of consent and there are no other grounds for the processing of your personal data; your personal data have been processed unlawfully; your personal data must be deleted when we are legally required to do so;
  • request that the processing of your data be restricted in one of the following cases: you dispute the accuracy of the data (in such case, the processing shall be restricted for the time period that allows us to verify the accuracy of your personal data); the processing of your personal data is unlawful and you do not agree that your personal data be deleted and instead request that their processing be restricted; we no longer need your personal data for processing purposes, but you need them for establishing, exercising or defending legal claims. Where the processing of your personal data is restricted, such personal data may be processed (except storage thereof) only with your consent or for the purpose of establishing, exercising or defending legal claims and/or protecting your or other person’s rights or for reasons of public interest; 
  • withdraw consent to process your personal data, where personal data is processed solely on the basis of your consent; 
  • request that your personal data processed by us be transferred to another data controller, where technically feasible;
  • submit a complaint to us or the State Data Protection Inspectorate, if you believe that your rights as a data subject have been and/or may be infringed.

10. Third-party websites

Our Website may contain links to other web sites. We are not liable for the privacy policy and its implementation in third-party websites.

11. Responsibilities

You are responsible for keeping your password and user details confidential and for any actions (data transmission, placed orders, etc.) carried out on our Website using your login information. You may not disclose your password to third parties. If our Website services are used by a third party who has logged in using your login information, we shall assume that it is you. If you lose your login information, you must immediately inform us about it by mail, phone, fax or e-mail.

You are responsible for the accuracy, correctness and completeness of information provided by you. In case of changes to your personal data, you must immediately inform us about it by amending the data in the registration form or, if the data is not provided in the registration form, writing us by e-mail. In no event shall we be liable for the damages incurred by you due to incorrect or incomplete personal data provided by you or your failure to inform us of changes thereto.

12. Changes to the Privacy Policy

We may update or change this Privacy Policy at any time. Such updated or changed Privacy Policy shall enter into force upon its publication on our Website. In case of essential changes to the Privacy Policy, they shall be published on the Website. Nevertheless, you should check this page from time to time and make sure that the current version of the Privacy Policy is acceptable to you.

13. Contact information

If you have any questions related to the terms of this Privacy Policy, please contact us using the following contact details:

Registration number: 14932517
Address: Karja 2 Paide Estonia
E-mail: [email protected]

We will respond to received requests, complaints or claims within the time limits and in accordance with procedure prescribed by legislation. We will make effort to provide you with information as soon as possible, but in any case not later than within 30 days from the receipt of your request.

In case of suspicion concerning the identity of the person submitting a request, complaint or claim, we shall have the right to request an ID document of the applicant.

If we are unable to provide you with requested information and/or you have any claims concerning the processing of your personal data, you have the right to file a complaint with the State Data Protection Inspectorate.