Privacy policy

Terms for Personal Data Processing

1. Definitions

1.1. Personal Data – any information about an identified or identifiable natural person;

1.2. Processing of Personal Data – any operation performed with personal data or sets of personal data;

1.3. Client – a natural person who visits the Website;

1.4. Willenbrock Baltic OÜ – Willenbrock Baltic OÜ, registration code 11341282;

1.5. Terms – these terms for personal data processing;

1.6. Responsible Processor – Willenbrock Baltic OÜ;

1.7. Website – the website of Willenbrock Baltic OÜ, i.e.,;

1.8. Authorized Processor – a natural or legal person, public sector institution, agency, or other body that processes personal data on behalf of Willenbrock Baltic OÜ.

2. General

2.1. The Terms describe the conditions under which Willenbrock Baltic OÜ processes personal data. The protection of the Client's personal data is important to Willenbrock Baltic OÜ; therefore, it processes personal data only when there is a legal basis and for legitimate purposes, ensuring the security and protection of personal data.

2.2. Willenbrock Baltic OÜ has the right to unilaterally change the Terms, notifying in advance one (1) month through the Website or other means, e.g., via email. Willenbrock Baltic OÜ will always notify of upcoming changes.

3. Objectives and Legal Basis for Processing

3.1. Willenbrock Baltic OÜ processes personal data for the purpose of entering into, fulfilling, and ensuring the fulfillment of a contract with the Client to (i) prepare for entering into a contract with the Client, (ii) fulfill a contract entered into with the Client, (iii) facilitate the sale of goods, including linking the Client's inquiries and offers to their person, (iv) ensure smooth billing, (v) protect Willenbrock Baltic OÜ's rights in case of a dispute, and (vii) provide the Client with information related to the contract.

3.2. Willenbrock Baltic OÜ processes personal data to fulfill obligations arising from legal acts to (i) ensure the protection of rights related to personal data, (ii) retain personal data for fulfilling obligations arising from legal acts, and (iii) fulfill any other obligations arising from legal acts.

3.3. Willenbrock Baltic OÜ processes personal data with the Client's consent to send newsletters and other information about Willenbrock Baltic OÜ's activities and special offers. The Client can opt out at any time.

3.4. Willenbrock Baltic OÜ uses surveillance cameras to protect persons and property. Surveillance cameras only monitor a specific area and its activities. They do not record sound or specifically monitor individuals. The cameras are installed on the exterior walls and interior spaces of Willenbrock Baltic OÜ buildings and provide real-time images, create recordings, and allow for later processing and playback of these recordings. Access to the surveillance camera recordings is restricted to members of the Willenbrock Baltic OÜ board and specialists from the company providing security and IT management services to Willenbrock Baltic OÜ, to the extent necessary for providing the service.

3.5. Willenbrock Baltic OÜ uses cookies on the Website. Cookies are small blocks of text data that are stored in the web browser or the Client's device when visiting the Website. Some cookies are associated with the Website (first-party cookies), and we also use third-party cookies. Cookies are necessary for the correct functioning of the Website and also make the use of the Website more convenient for the Client. Cookies allow, for example, remembering the Client's preferences and collecting data on the Client's use of the Website, enabling personalized content to be offered to the Client and providing input for analytics and statistics. The information accessible to Willenbrock Baltic OÜ via cookies is not linked to any specific natural person.

3.6. To restrict, disable, or delete cookies stored by the Website, the Client can consult their web browser settings. Restricting or disabling cookies may affect the correct functioning of the Website.

3.7. Willenbrock Baltic OÜ is obligated to ask for the Client's consent for processing personal data for purposes not specified in the Terms.

4. Composition of Personal Data

4.1. To achieve the objectives set out in the Terms, Willenbrock Baltic OÜ needs to process some or all of the following personal data: (i) name, (ii) email address, (iii) phone number, (iv) billing account number, (v) copies of customer interactions, (vi) data related to surveillance camera recordings, (vii) data related to Website cookies, and (viii) information collected for fulfilling obligations arising from legal acts. The exact composition of processed personal data varies in each case. Willenbrock Baltic OÜ always adheres to the principle that personal data is processed as little as necessary to achieve the objective.

5. Disclosure and Transmission of Personal Data

5.1. Willenbrock Baltic OÜ has the right to disclose and transmit personal data without prior consent to fulfill obligations arising from legal acts and to Authorized Processors. For the protection of its rights, Willenbrock Baltic OÜ has the right to disclose personal data to third parties, including legal aid providers, auditors, debt collectors, etc.

6. Retention of Personal Data

6.1. Willenbrock Baltic OÜ retains personal data as long as necessary for fulfilling the objectives described herein, for protecting Willenbrock Baltic OÜ's rights, or for fulfilling obligations arising from legal acts.

6.2. Surveillance camera recordings are retained for up to 30 days, after which the recordings are automatically overwritten.

7. Data Subject Rights

7.1. According to legal acts, the Client has the right to (i) request information from Willenbrock Baltic OÜ about the processing of the Client's personal data and, in certain cases, to (ii) request the correction, (iii) deletion, (iv) restriction of processing, or (v) object to processing. If Willenbrock Baltic OÜ processes the Client's personal data based on consent, (vi) the Client can withdraw consent at any time, in which case Willenbrock Baltic OÜ will cease processing personal data. This does not affect processing activities carried out before the withdrawal. Willenbrock Baltic OÜ will respond to the Client's inquiries as quickly as possible, taking into account deadlines arising from legal acts.


8.1. For additional questions, suggestions, and complaints related to the Client's personal data, the Client has the right to contact Willenbrock Baltic OÜ as the responsible processor (Willenbrock Baltic OÜ; Uus-Ringi tee 11, Jüri alevik, Rae vald 75301, Harjumaa, Estonia;