GDPR

Policy on the processing of personal data

1. General provisions

This policy explains how Regulated United Europe OÜ processes personal data under Regulation (EU) 2016/679 (GDPR), the Estonian Personal Data Protection Act and other applicable legislation.

1.1. The operator makes it his most important goal and condition for the implementation of his activity to respect the rights and freedoms of a person and a citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator’s Personal Data Processing Policy (hereinafter referred to as Policy) applies to all information that the Operator may obtain about visitors to the website rue.ee.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer tools.

2.2. The blocking of personal data is a temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data).

2.3. Website – a collection of graphic and informational materials, as well as software for computers and databases,  making them available on the Internet at rue.ee.

2.4. Personal Data Information System – a set of personal data contained in databases, and providing their processing information technologies and technical means.

2.5. Anonymisation means transforming data so that individuals are no longer identifiable by means reasonably likely to be used. Data that can be linked back to an individual using additional information are not necessarily anonymous; pseudonymisation must be distinguished from anonymisation.

2.6. Processing of personal data – any action (transaction)  or combination of actions (transactions) performed using or without means of automation with personal data, including collection, recording,  systematization, accumulation, storage, clarification (update,  modification), extraction, use, transfer (dissemination,  provision, access), depersonalization, blocking, deletion,  destruction of personal data.

2.7. Operator – State, municipal body,  Legal or natural person, independently or jointly with other persons, organizing and (or) performing the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (transactions) performed with personal data.

2.8. Personal Data – any information relating directly or indirectly to a certain or defined User of the Website rue.ee.

2.9. Personal data permitted by the subject of personal data for dissemination – personal data, access to an unlimited number of persons to whom the subject has provided

Personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Personal Data Act (hereinafter personal data permitted for dissemination).

2.10. User – any visitor of the website rue.ee.

2.11. Provision of Personal Data – Actions aimed at disclosing personal data to a certain person or a certain group of persons.

2.12. Dissemination of personal data – any action aimed at disclosing personal data to an undetermined circle of persons (transmission of personal data) or at familiarizing oneself with the personal data of an unlimited number of persons, including the publication of personal data in the mass media, posting in information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign natural or foreign legal person.

2.14. The destruction of personal data – any action that results in the permanent destruction of personal data with the impossibility of further recovery of the content of personal data in the information system of personal data and (or) The material holders of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The operator has the right to:

• To receive from the subject of personal data reliable information and/or documents containing personal data.
• If consent is withdrawn, processing based on that consent must stop. Data may still be retained or processed for a separate lawful purpose, such as compliance with a statutory obligation, where the applicable GDPR requirements are met. Withdrawal does not permit retrospective substitution of another legal basis for the same processing.
• Implement and regularly review appropriate technical and organisational measures to comply with the GDPR and applicable Estonian legislation, taking account of the processing and risks to individuals.

3.2. The operator shall:

• To provide the subject of personal data, upon request, with information relating to the processing of his personal data;
• To organize the processing of personal data in accordance with the procedure established by the current legislation of Estonia;
• To respond to requests and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
• Cooperate with the competent supervisory authority and provide requested information within the deadline applicable to its lawful request or order. A general 30-day response period does not override a shorter binding deadline.
• Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
• Undertake legal, organizational and technical measures to protect personal data from improper or accidental access to it, destruction, modification, blocking, copying,  provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
• Cease transmission (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for in the Personal Data Act.
• To perform other duties stipulated by the Law on Personal Data.

4. Basic rights and obligations of subjects of personal data

4.1. Subjects of personal data have the right:

• Obtain confirmation of whether personal data are processed, access to those data and the information required by Article 15 GDPR. Any restriction must have a lawful basis. Protecting other persons’ rights may require redaction rather than refusing the entire request.
• To require the operator to clarify, block or destroy his personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and to take the measures provided for by law to protect their rights.
• To require prior consent when processing personal data in order to promote goods, works and services in the market.
• To withdraw consent to the processing of personal data.
• To appeal to the authorized body for the protection of the rights of subjects of personal data or to the judicial procedure unlawful actions or omissions of the Operator in the processing of his personal data.
• To exercise other rights provided for in Estonian law.

4.2. Subjects of personal data must:

• Provide the Operator with reliable data about themselves
• Inform the Operator about the clarification (updating, modification) of their personal data

4.3. Users must provide accurate information and have a lawful basis for disclosing another person’s personal data. Consent is not the only possible legal basis. Any liability depends on the applicable law and the circumstances of the disclosure.

5. Operator may process the following personal data of the User

5.1. Last name, first name, patronymic.

5.2. E-mail address.

5.3. Phone numbers.

Website analytics may involve personal data, including online identifiers. Such data remains subject to the GDPR whenever an individual can be identified directly or indirectly. Pseudonymisation does not make data anonymous. Only information that no longer permits identification by means reasonably likely to be used can be treated as anonymous. Analytics processing must have an applicable legal basis and comply with the relevant cookie-consent requirements.

5.5. The above data is hereinafter referred to in the Policy as Personal Data.

5.6. Processing of special categories of personal data,  concerning race, nationality, political opinions, religious or philosophical beliefs, intimate life,  The operator shall not.

5.7. Special-category data may be processed only where an Article 6 GDPR legal basis and an applicable Article 9(2) condition are satisfied. Permission to publish data is not a separate exemption from these requirements.

5.8. Where publication of personal data relies on consent, consent must be freely given, specific, informed and unambiguous. The request must identify the data and publication purpose and be distinguishable from other matters. Additional GDPR conditions apply to special-category data.

5.8.1 The User shall give consent to the processing of personal data authorized for dissemination to the Operator directly.

5.8.2. Before requesting consent to publication, the Operator must explain the data concerned, purposes, intended audience and how consent can be withdrawn. Information required by the GDPR must be provided at the applicable statutory time; it cannot be postponed until three working days after consent.

5.8.3. Users may withdraw consent to publication at any time, as easily as they gave it. The Operator may request only information necessary to identify the relevant processing and, where reasonably required, verify identity. Withdrawal must not depend on a prescribed form or unnecessary identity details. Processing based solely on the withdrawn consent must cease.

5.8.4 Consent to the processing of personal data authorized for dissemination shall cease as soon as the Operator receives the request referred to in paragraph 5.8.3. of this Policy concerning the processing of personal data.

6. Principles of Personal Data Processing

6.1. The processing of personal data is legal and fair.

6.2. The processing of personal data is limited to the achievement of specific, predefined and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.

6.3. It shall not be permitted to merge databases containing personal data processed for purposes which are incompatible with each other.

6.4. Only personal data that meet the purposes of processing shall be processed.

6.5. The content and amount of personal data processed correspond to the stated purposes of processing. Redundancy of personal data processed in relation to the stated purposes of processing is not allowed.

6.6. The processing of personal data ensures the accuracy of personal data, its sufficiency, and, where necessary, its relevance to the purposes of processing personal data.  The operator shall take the necessary measures and/or ensure that they are taken to remove or clarify incomplete or inaccurate data.

6.7. Personal data must be retained only for as long as necessary for the relevant lawful purposes, including applicable statutory retention obligations. Retention periods must be justified and reviewed. Data must then be erased or anonymised unless another lawful basis requires continued retention.

7. Purposes of personal data processing

7.1. Purpose of processing the User’s personal data:

• Informing the User by e-mail
• The conclusion, execution and termination of civil contracts
• Providing the User with access to the services, information and/or materials contained on the website.

7.2. Marketing emails to individuals require prior consent unless the statutory existing-customer exception applies. That exception covers our own similar services where contact details were obtained during a sale and a free, easy opt-out was offered both at collection and in every message. Corporate recipients must also receive an easy opt-out. Marketing must stop after an objection.

Website analytics may involve personal data, including online identifiers. Such data remains subject to the GDPR whenever an individual can be identified directly or indirectly. Pseudonymisation does not make data anonymous. Only information that no longer permits identification by means reasonably likely to be used can be treated as anonymous. Analytics processing must have an applicable legal basis and comply with the relevant cookie-consent requirements.

8. Legal grounds for processing personal data

8.1. Each processing activity must have an applicable GDPR legal basis, such as contractual necessity, compliance with a legal obligation, legitimate interests subject to the required assessment, or valid consent. The Operator’s constitutional documents do not independently authorise processing.
8.2. Information submitted through forms or email is processed on the legal basis appropriate to the request. Submission does not constitute blanket consent. Where consent is required, it must be freely given, specific, informed and unambiguous.

8.3. Non-essential cookies and similar tracking technologies require valid prior consent where applicable. Enabling cookies or JavaScript in a browser does not by itself provide that consent. Users must be able to refuse or withdraw consent. Analytics data must not be described as anonymous unless individuals are no longer identifiable.

8.4. The subject of personal data independently decides on the provision of his personal data and gives consent freely, by his will and in his interest.

9. Conditions for processing personal data

9.1. The processing of personal data is carried out with the consent of the subject of personal data for the processing of his personal data.

9.2. The processing of personal data is necessary to achieve the purposes stipulated by the Estonian International Treaty or by law, in order for the operator to carry out the functions, powers and duties assigned by the Estonian legislation.

9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, the act of another body or official, which is subject to enforcement under Estonian law on enforcement proceedings.

9.4. Processing may rely on Article 6(1)(b) GDPR only where it is necessary to perform a contract to which the data subject is a party, or to take steps at that person’s request before entering into a contract. Being a beneficiary or guarantor of another person’s contract does not automatically establish this legal basis.

Processing based on legitimate interests requires a specific lawful interest, necessity of the processing for that interest, and an assessment showing that the individual’s interests or fundamental rights and freedoms do not override it. A generally beneficial or socially significant purpose is not, by itself, a legal basis. Processing under Article 6(1)(e) GDPR requires a public-interest task or official authority grounded in applicable Union or Member State law.

9.6. Public availability of personal data does not itself provide a legal basis for further processing. An applicable GDPR legal basis and all relevant safeguards remain necessary.

9.7. Mandatory publication or disclosure of personal data must be based on an applicable obligation under EU or Estonian law and limited to what that obligation requires.

10. Procedures for the collection, storage, transmission and other processing of personal data

The security of personal data processed by the Operator is ensured by the implementation of legal,  organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

10.1. The operator shall ensure the preservation of personal data and shall take all possible measures to prevent access to personal data of unauthorized persons.

10.2. Personal data of the User shall never, under any circumstances, be transferred to third parties, except in cases,  related to the implementation of the existing legislation or in the case if the subject of personal data has given consent to the Operator to transfer the data to a third person to fulfill obligations under a civil contract.

10.3. In case of detection of inaccuracies in personal data,  The User can update them by sending to the Operator a notification to the e-mail address of the Operator info@rue.ee with the mark «Updating of personal data».

10.4. The period of processing of personal data is determined by the achievement of the purposes for which personal data have been collected, unless another period is stipulated by the contract or the legislation in force.

The User may at any time withdraw his consent to the processing of personal data by notifying the Operator via e-mail to the Operator’s e-mail address info@rue.ee marked «Revocation of consent to the processing of personal data».

10.5. Service providers may act as processors or independent controllers, depending on their role. The Operator remains responsible for its own GDPR obligations, including appropriate processor selection, contractual safeguards and oversight. Third-party terms do not exclude liability imposed by applicable law. Independent controllers must provide information about their own processing.

10.6. Public availability of personal data does not remove GDPR protection. Any processing in the public interest requires an applicable legal basis. Objections and restrictions must be assessed under the relevant GDPR provisions; a general reference to public interest does not override individuals’ rights.

10.7. The operator ensures the confidentiality of personal data when processing personal data.

10.8. Identifiable personal data must be kept only for justified retention periods linked to lawful purposes. Applicable statutory obligations may require continued storage. A contractual term does not by itself permit unnecessary or indefinite retention.

10.9. A condition for terminating the processing of personal data may be the achievement of the purposes of the processing of personal data,  the expiration of the consent of the subject of personal data or the withdrawal of consent by the subject of personal data, as well as detection of illegal processing of personal data.

11. List of actions carried out by the Operator with the personal data received

11.1. The operator shall collect, record, systematize,  accumulate, store, clarify (update, modify),  extract, use, transmit (disseminate,  provide, access), depersonalize, block, delete and destroy personal data.

11.2. The operator performs automated processing of personal data with and/or transmission of the received information through information and telecommunication networks or without.

12. Cross-border transfer of personal data

12.1. Transfers of personal data to recipients outside the European Economic Area must comply with Chapter V of the GDPR, in addition to the other requirements for lawful processing. Transfers may rely on an applicable adequacy decision or appropriate safeguards, such as standard contractual clauses, with the required assessment and supplementary measures where necessary.

12.2. If neither route is available, an Article 49 derogation may be used only where its specific conditions are met. Consent must be explicit and informed about the relevant transfer risks. Contract-related derogations require necessity; a contract or written consent alone does not automatically justify a transfer.

13. Confidentiality of personal data

Operator and other persons who have access to personal data shall not disclose to third parties or distribute

Personal data may be published only on an applicable GDPR legal basis, with the required transparency and safeguards. Where publication relies on consent, that consent must be valid. Special-category data are subject to additional Article 9 requirements.

14. Final provisions

14.1. The User may obtain any clarifications regarding the processing of his personal data by contacting the Operator by e-mail info@rue.ee

14.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced with a new version.

14.3. The current version of the Free Access Policy is available on the Internet at rue.ee.