Privacy policy

General Terms and Conditions for Personal Data Processing can be found here.


1.1 This website is operated by Graanul Invest AS (“we” or “ us”). We recognize the importance of your privacy and are committed to protecting your personal data. This privacy notice (“ Notice”) explains the principles on how we collect and use information when you visit the website: („ Website“).

1.2 We process your personal data as described in this Notice and in accordance with applicable legislation, including the European Union’s General Data Protection Regulation (2016/679) and the national data protection laws of the Republic of Estonia, as applicable towards the personal data controller stated in Section 2 of this Notice.

2.1 For the personal data processing purposes brought out in Section 4 of this Notice, the controller of your personal data is:

Registry code: 10990825
Address: Humala str. 2, 10617 Tallinn, ESTONIA

2.2 In case of personal data protection related inquiries, please contact us by writing


3.1 Personal data are information that can be used to directly or indirectly uniquely identify, contact, or locate you as a private individual (“Personal Data”). The source of the collected Personal Data depends on how you interact with us.

3.1.1 If you interact with us via e-mails, we process the following Personal Data: name, e-mail address, phone number, contents of your message. Additionally, we may supplement the Personal Data that you have provided to us directly with information that has been obtained from publicly available resources and registrars („ Communication Data“).

Source: Personal Data you directly provide to us upon contacting and the information we have obtained from publicly available resources and registrars.

3.1.2 Upon visiting the Website, our server processes the following data: IP address, access-provider, referring URL, date, time, access tokens, session key, browser type and version, operating system, amount and state of transferred data (“Technical Data”).

Source: While you are browsing through the Website, the Website itself generates or collects the Technical Data from your device automatically.

3.2 If you do not provide the required information, we may not be able to contact you or fulfil any other purposes provided in Section 4 of this Notice.


4.1 Our legal basis to process your Personal Data depends on the objective and context in which we collect the Personal Data. The following depicts a descriptive list of processing purposes that are linked to the specific data categories and legal basis for processing:

Processing purpose Legal basis for the processing purpose Personal Data used for the processing purpose
Responding to your enquiries and requests submitted via e-mail Our legitimate interest in ensuring effective relations management with potential customers and interested parties.

If you wish to become or are already our client and the enquiry or request is related to your potential or ongoing customer relationship with us, the legal basis is taking and implementing the pre-contractual measures of a contract or performing the contract

Communication Data
Gathering additional information about you (or the entity you represent) from publicly available resources and registrars Our legitimate interest in ensuring effective relations management with potential customers and interested parties
Diagnose and repair problems with the Website Our legitimate interest in providing data security and preventing fraudulent actions related to the Website; ensuring the functioning of the Website Technical Data
Storing information containing Personal Data in our backup systems Our legitimate interest in ensuring the security of data processing operations Communication Data, Technical Data
Data disclosures within Graanul Invest AS and other group companies Our legitimate interest in utilising the shared administrative infrastructure and ensuring effective relations management

4.2 We may process your Personal Data for other purposes, provided that we disclose the purposes and use to you at the relevant time, and that you either consent to the proposed use of the Personal Data, other legal grounds exist for the new processing purposes or the new purpose is compatible with the original purpose brought out above.


5.1 Your Personal Data shall be stored insofar as reasonably necessary to attain the objectives stated in Section 4 of this Notice, or until the legal obligation stipulates that we do so. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the processing purposes and whether we can achieve these purposes through other means, and applicable statutory obligations. Whilst retaining the Personal Data, we take into account the viable need to resolve disputes and enforce the contract between us or anonymize your Personal Data and retain this anonymized information indefinitely.

5.2 After the expiry of the retention period determined in accordance with Section 5.1 of this Notice or the termination of the legal basis for processing purpose, we may retain the materials containing the Personal Data in the backup systems, from which the corresponding materials will be deleted after the end of the backup cycle. We ensure that during the backup period appropriate safeguards are applied and the backed-up materials are put beyond the use.


6.1 We have a legal obligation to ensure that your Personal Data is kept accurate and up to date. We kindly ask you to assist us to comply with this obligation by ensuring that you inform us of any changes that have to be made to any of your Personal Data that we are processing.

6.2 You may, at any time, exercise the following rights with respect to our processing of your Personal Data by contacting us via contact information referred to in this Notice:

6.2.1 Right to access: you have the right to request access to any data that can be considered your Personal Data. This includes the right to be informed on whether we process your Personal data, what Personal Data categories are being processed by us, and the purpose of our data processing;

6.2.2 Right to rectification: you have the right to request that we correct any of your Personal Data if you believe that it is inaccurate or incomplete;

6.2.3 Right to object: you are entitled to object to certain processing of Personal Data, including for example, the processing of your Personal data for marketing purposes or when we otherwise base our processing of your Personal Data on our legitimate interest;

6.2.4 Right to restrict Personal Data processing: you have the right to request that we restrict the processing of your Personal Data if you wish to: (i) object the lawfulness of the processing; (ii) fix unlawful processing of Personal Data; (iii) receive or avoid deletion of Personal Data for establishing or defending against legal claims; or (iv) demand restriction of the processing until assessing the plausibility of our legitimate interest in the specific processing activity;

6.2.5 Right to erasure: you may request your Personal Data to be erased if the Personal Data is no longer necessary for the purposes for which it was collected, or if you consider that the processing is unlawful, or if you consider that the Personal Data has to be erased to enable us to comply with a legal requirement;

6.2.6 Right to data portability: if your Personal Data is being automatically processed with your consent or on the basis of a mutual contractual relationship, you may request that we provide you that Personal Data in a structured, commonly used and machine-readable format. Moreover, you may request that the Personal Data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible;

6.2.7 Right to withdraw your consent: in cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time;

6.2.8 Right to contact the supervisory authority: if you are not satisfied with our response to your request in relation to Personal Data or you believe we are processing your Personal Data not in accordance with the law, you can submit your claim with the Estonian Data Protection Inspectorate (in Estonian Andmekaitse Inspektsioon) (

6.3 Please note that prior answering your request, we may ask you to provide additional information for the purposes of authenticating you and evaluating your request regarding your rights brought out in Section 6.2 of the Notice.


7.1 Your Personal Data will be disclosed to our employees who due to their duties have the necessity to process your Personal Data.

7.2 Only if necessary, for fulfilling our statutory or contractual obligations, we may disclose your Personal Data to the following recipients:

Law enforcement and data protection authorities –

We disclose your Personal Data to law enforcement and data protection authorities only if we are under a duty to disclose or share these data in order to comply with legal obligations (for example, if required to do so under applicable law, by a court order or for the purposes of prevention of fraud or other crime)

Professional advisors (legal advisors, accounting etc. bound to confidentiality) –

In case not operating as data processors, the legitimate interests in conducting and supporting our regular business activities.

IT-service providers –

In case not acting as data processor, for providing IT solutions necessary for daily business functions

Graanul Invest AS and other group entities (if necessary) –

If necessary, your Personal Data may become available to the employees of the Graanul Invest AS and other group entities, for the purposes of utilising the shared administrative infrastructure

7.3 In addition to the third parties brought out in Section 7.2 of the Notice, we may disclose Personal Data to third party service providers who act as data processors and may operate the technical infrastructure that we need to host, store, manage and maintain the daily business. For the purposes of hosting the e-mail communications via the Website, we have engaged an IT-service provider.

7.4 In some cases, we may transfer your Personal Data outside the European Union or European Economic Area, if the respective operational service providers located outside the European Union or European Economic Area. We shall opt to use special Personal Data protection safeguards, in order to ensure the safety of your Personal Data. You have the right to get acquainted with or obtain information on the transferring of your Personal Data outside the European Union or European Economic Area and the safeguards implied thereof by contacting us using the contact information specified in this Notice.


We use ”cookies” on our website. “Cookies” help us improve our Services and use our services in a more convenient manner, market our Services.

We collect data on how users interact with our website and / or application. In addition, we collect information from your computer or device, such as the IP address, browser you are using, and language settings. We also collect information about how the user uses our web pages and applications for statistical purposes to improve our web pages and applications, and to display custom content for the customer.

If you prefer that your personal data will not be processed on our website, you can activate the private browsing feature of Your web browser. This is your choice.


9.1 This Notice may be amended or modified from time to time to reflect changes in the way we process Personal Data and, in such case, the most recent version of the Notice will appear on this page. Please check back periodically, and especially before you provide any new personally identifiable information.