Legal

Touringery Privacy Policy

Last amended 12.08.2025

This is an English translation provided for convenience. In the event of any discrepancy, the Estonian version at touringery.ee/privacy-policy/ prevails.

1. Application of the Privacy Policy

1.1 This privacy policy (hereinafter: Privacy Policy) applies in all cases where Touringery OÜ (hereinafter: Touringery) processes, as controller, the personal data of natural persons (hereinafter: Data Subject) while providing platform services in the course of its economic and professional activities (hereinafter: Platform Services).

1.2. The Platform Services are a booking environment service available on the website touringery.ee (hereinafter: Platform), within which Touringery’s private customers (hereinafter: End User) can make bookings for services offered by Touringery’s business customers (hereinafter: Partner) (hereinafter: Services) and pay for them.

1.3. As a general rule, Touringery is not the controller where Touringery processes the personal data of the Partner’s representatives (or of other natural persons connected with the Partner) who are not End Users, and this Privacy Policy does not apply to such processing. Likewise, this Privacy Policy does not apply where the Data Subject uses the Partner’s Services and/or visits the Partner’s websites (including websites that can be accessed via links on the Platform), in which case the relevant Partner is the controller. You can obtain further information about those processing operations from the relevant Partner.

1.4. Touringery is committed to protecting and respecting the privacy of Data Subjects. Please read this Privacy Policy carefully in order to understand Touringery’s rules and practices in processing personal data.

1.5. The Privacy Policy applies from the date stated above. Touringery may unilaterally amend and supplement the Privacy Policy. Touringery notifies Data Subjects of changes to the Privacy Policy by making them available on its website (or in another manner at Touringery’s discretion).

2. Controller

2.1. The controller of the Data Subjects’ personal data is Touringery OÜ, registry code 16277040, registered address Tiku, Kiidjärve village, Põlva rural municipality, Põlva County 63604, Estonia.

2.2. For all questions relating to the Privacy Policy and the processing of personal data, you may contact Touringery by sending an enquiry by e-mail to support@touringery.ee

3. For what purpose and which personal data are processed

3.1. Touringery collects and processes personal data for the following purposes:

(a) to provide the Platform Services, which includes communicating with the Data Subject;

(b) to communicate with a potential End User regarding the possible provision of Platform Services in the future, where the Data Subject has expressed such a wish;

(c) to send news, special offers and general information about the Platform Services to the End User, unless the End User has opted out of receiving such information;

(d) to improve and enhance the Platform Services and the Platform;

(e) to protect and enforce the rights laid down in legislation and contracts applicable to Touringery;

(f) to comply with obligations arising from legislation applicable to Touringery and with lawful orders.

3.2. Touringery collects and processes the following personal data:

(a) for the purpose of providing the Platform Services (purpose in clause 3.1.(a)):

i. first and last name, e-mail address, telephone number, language of communication, payment method information;

ii. connection with the Partner and its Services (e.g. the fact that the End User is a customer of the Partner, data on the Services booked and used, etc.);

iii. technical data such as the time and manner of use of the Platform;

iv. any other personal data that the End User may voluntarily submit in connection with the Platform Services, such as questions and observations, as well as the End User’s claims and complaints that Touringery may handle.

(b) for the purpose of communicating with a potential End User (purpose in clause 3.1.(b)): data made available voluntarily by the data subject, which is usually the first and last name and e-mail address.

(c) for the purpose of sending news, special offers and general information about the Platform Services (purpose in clause 3.1.(c)): first and last name, e-mail address, history of use of the Platform.

(d) for the purpose of improving and enhancing the Platform Services and the Platform (purpose in clause 3.1.(d)): above all, data made available voluntarily by the End User, such as their feedback on the Platform Services, but also any other personal data listed above, depending on the specific updates made to the Platform Services. As a rule, personal data are pseudonymised in such a case.

(e) for the purpose of enforcing and protecting Touringery’s rights (purpose in clause 3.1. (e)): any of the personal data listed above, determined according to the specific right that Touringery is enforcing.

(f) for the purpose of complying with obligations arising from legislation and with lawful orders (purpose in clause 3.1.(f)): any of the personal data listed above, determined according to the specific obligation that Touringery must fulfil.

3.3. Where the entry of certain personal data has been made mandatory when using functions of the Platform, the submission of that personal data is necessary in order to enter into a contract with Touringery and to perform that contract. If the End User refuses to submit such personal data, the Platform Services may not be available to the End User, and Touringery may prohibit or restrict the End User’s right to use the Platform Services. Where the submission of personal data has not been made mandatory on the Platform and is not otherwise required from the Data Subject, submission is voluntary and failure to submit has no direct adverse consequences for the Data Subject.

3.4. As a general rule, Touringery collects personal data directly from the Data Subject, except where the Data Subject’s personal data are collected from another person who is entitled to do so (e.g. from the Partner, or from a person who is in direct communication with Touringery when concluding a contract for the Platform Services).

4. Legal bases for processing personal data

4.1. Touringery processes the End User’s personal data because it is necessary for the provision of the Platform Services (purpose in clause 3.1.(a)) or for taking steps prior to providing the Platform Services at the request of the Data Subject (purpose in clause 3.1.(b)). In such a case the legal basis for processing personal data is the performance of a contract concluded with the participation of the Data Subject, or the taking of steps prior to entering into a contract at the request of the Data Subject.

4.2. To the extent that Touringery processes personal data in order to send news, special offers and general information about the Platform Services (purpose in clause 3.1.(c)), the legal basis for processing is the Data Subject’s prior consent. If the Data Subject does not give consent to such processing, Touringery does not process personal data for that purpose and no news, special offers or general information are sent. The Data Subject may withdraw consent previously given at any time by sending a notice to Touringery’s e-mail address support@touringery.ee. Withdrawal of consent does not affect the right to use the Platform and to receive the Platform Services.

4.3. To the extent that Touringery processes personal data for the purpose of improving and enhancing the Platform Services and the Platform (purpose in clause 3.1.(d)), the legal basis for processing is Touringery’s legitimate interest in improving and enhancing the offering and the quality of the Platform Services. Touringery cannot provide the best and most up-to-date Platform Services without making the necessary updates.

4.4. In addition, Touringery processes personal data in order to protect and enforce the rights laid down in legislation and contracts applicable to Touringery (purpose in clause 3.1. (e)). In such a case the legal basis for processing is the legitimate interest of Touringery as controller. Touringery’s legitimate interest is to protect its rights in the manner Touringery considers necessary.

4.5. Touringery also processes personal data in order to comply with obligations arising from legislation and with lawful orders (purpose in clause 3.1.(f)). In such a case the legal basis for processing is compliance with the statutory obligations of Touringery as controller.

5. Transfer of personal data to third parties

5.1. Touringery does not transfer the Data Subject’s personal data to third parties, except to:

(a) Partners that have joined the Platform and provide Services to the End User;

(b) service partners providing IT services (e.g. Flowit Estonia OÜ);

(d) service partners providing payment intermediation services (e.g. Maksekeskus AS, established in Estonia).

5.2. All processors named in clause 5.1 ensure the protection of personal data as required by the legislation regulating the protection of personal data. Where personal data are transferred outside the European Economic Area, appropriate safeguards in accordance with European Union data protection requirements are applied.

5.3. Touringery is also entitled to disclose the Data Subject’s personal data to an authority which, under legislation in force in the Republic of Estonia, has the right to require Touringery to disclose the personal data it processes, and where Touringery is obliged to disclose the personal data to that authority.

6. Retention of personal data

6.1. Touringery processes and retains personal data only for as long as is necessary to fulfil the purpose of the processing – once the purpose has ended, the personal data are deleted or anonymised.

6.2. Touringery processes and retains personal data as follows:

(a) up to 1 year after the end of the provision of the Platform Services, where personal data are processed for the purpose of providing the Platform Services (purpose in clause 3.1. (a));

(b) up to 1 year after the last contact with the Data Subject, to the extent that Touringery retains the Data Subject’s personal data in connection with taking steps prior to entering into a contract at the request of the Data Subject (purpose in clause 3.1.(b));

(c) up to 1 year after the end of the provision of the Platform Service, or until consent is withdrawn (whichever occurs earlier), to the extent that Touringery processes personal data in order to send news, special offers and general information (purpose in clause 3.1.(c));

(d) up to 1 year after the end of the provision of the Platform Services, where personal data are processed for the purpose of updating the Platform Services and the Platform (purpose in clause 3.1.(d));

(e) up to 3 years after the end of the provision of the Platform Services, or until the expiry of the limitation period for the relevant claim (the limitation period for claims arising from law is generally 10 years), where Touringery processes personal data in order to enforce and protect Touringery’s rights (purpose in clause 3.1.(e));

(f) up to 3 years after the end of the provision of the Platform Services (or another period laid down by law), where Touringery processes personal data in order to comply with obligations arising from legislation and with lawful orders (purpose in clause 3.1.(f)).

6.3. Personal data contained in accounting source documents are retained by Touringery for 7 years from the end of the financial year to which those documents relate.

7. Rights of the Data Subject

7.1. The Data Subject has the right to contact Touringery at any time with a request in simple written and free form, by e-mail to support@touringery.ee, in order to:

(a) request access to the personal data concerning the Data Subject;

(b) request the rectification of personal data;

(d) restrict the processing of personal data;

(e) object to the processing of personal data;

(f) request the portability of personal data;

(g) request that no decision based on automated processing be taken in respect of the Data Subject, where such processing takes place;

(h) withdraw consent to the processing of personal data, where consent has been given;

(i) lodge a complaint with the supervisory authority (the Estonian Data Protection Inspectorate, for further information see: https://www.aki.ee/en; or contact: info@aki.ee).

7.2. Where Touringery processes personal data on the basis of its legitimate interest, the Data Subject has the right to request further information from Touringery about the legitimate interest, including an explanation of the balancing of the interests of the Data Subject and of Touringery.