General Provisions

1.1. This privacy policy governs the principles of collecting, processing, and storing personal data. Personal data is collected, processed, and stored by the data controller (SIA LOTOS PHARMA) (hereinafter referred to as the data controller).

1.2. For the purposes of this privacy policy, a data subject is a customer or any other natural person whose personal data is processed by the data controller.

1.3. For the purposes of this privacy policy, a customer is anyone who purchases goods or services from the data controller’s website.

1.4. The data controller complies with the principles of data processing established in legal acts, including processing personal data lawfully, fairly, and securely. The data controller is able to demonstrate that personal data has been processed in accordance with the applicable legislation.

Collection, Processing, and Storage of Personal Data

2.1. The personal data collected, processed, and stored by the data controller is collected electronically, primarily via the website, e-store, and email.

2.2. By sharing their personal data, the data subject grants the data controller the right to collect, organize, use, and manage personal data for the purposes defined in this privacy policy, either directly or indirectly provided by the data subject when purchasing goods or services through the website.

2.3. The data subject is responsible for ensuring that the data provided is accurate, correct, and complete. Knowingly providing false information is considered a violation of this privacy policy. The data subject is obliged to notify the data controller immediately of any changes to the provided data.

2.4. The data controller is not liable for any damages caused to the data subject or third parties resulting from the data subject providing incorrect information.

Processing of Customer Personal Data

3.1. The data controller may process the following personal data of the data subject:

3.1.1. First and last name;
3.1.2. Date of birth;
3.1.3. Phone number;
3.1.4. Email address;
3.1.5. Delivery address;
3.1.6. Bank account number;
3.1.7. Payment card details;

3.2. In addition to the above, the data controller has the right to collect data about the customer that is available in public registers.

3.3. The legal basis for processing personal data is Article 6(1)(a), (b), (c), and (f) of the General Data Protection Regulation (GDPR):

a) The data subject has given consent to the processing of their personal data for one or more specific purposes;
b) The processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract;
c) The processing is necessary for compliance with a legal obligation to which the data controller is subject;
f) The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, especially if the data subject is a child.

3.4. Processing of personal data by purpose:

3.4.1. Purpose – Security and safety
Maximum retention period – According to the periods specified by law

3.4.2. Purpose – Order processing
Maximum retention period – 1 year

3.4.3. Purpose – Ensuring functionality of the e-store
Maximum retention period – 1 year

3.4.4. Purpose – Customer management
Maximum retention period – 1 year

3.4.5. Purpose – Financial activities, accounting
Maximum retention period – According to the periods specified by law

3.4.6. Purpose – Marketing
Maximum retention period – 1 year

3.5. The data controller has the right to share customer personal data with third parties, such as authorized data processors, accountants, transportation and courier companies, and payment service providers. The data controller is the main data controller. For payment processing, personal data is transferred to the authorized processor Montonio Finance UAB.

3.6. When processing and storing the data subject’s personal data, the data controller applies organizational and technical measures that ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.

3.7. The data controller retains personal data for the duration necessary to achieve the purpose of processing, but no longer than 1 year.

Rights of the Data Subject

4.1. The data subject has the right to access and review their personal data.

4.2. The data subject has the right to receive information regarding the processing of their personal data.

4.3. The data subject has the right to rectify or correct inaccurate data.

4.4. If the data controller processes personal data based on the data subject’s consent, the data subject has the right to withdraw consent at any time.

4.5. To exercise their rights, the data subject may contact the e-store customer support via email at info@lotos-pharma.ee.

4.6. To protect their rights, the data subject may file a complaint with the Data Protection Inspectorate.

Final Provisions

5.1. This privacy policy is prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation), the Personal Data Protection Act of the Republic of Estonia, and other relevant Estonian and EU legislation.

5.2. The data controller has the right to change this privacy policy partially or fully by notifying data subjects through the website www.lotos-pharma.ee.