Begin OÜ as the Data Controller

1. Definitions

1.1. Client is a legal entity that has entered into a contract with Begin OÜ or with whom Begin OÜ has communicated for the purpose of using its services.

1.2. Client Representative is a natural person (data subject) representing the Client.

2. General Information

2.1. Begin OÜ is the data controller of personal data. Contact details: Lehtpuu St. 12-3, Tallinn 10912, +372 6007770,

2.2. The email address of the data protection officer is

3. Composition of Processed Data

3.1. Begin OÜ receives or collects data from the Client (including the Client Representative) both from the Client Representative and from third-party sources (Commercial Register, Äripäev AS information bank).

3.2. The processed data includes the Client Representative’s name, personal identification code, phone number, email address, and communication language.

4. Purpose and Legal Basis for Data Processing

4.1. Processing of personal data takes place for the following purposes:

4.1.1. Based on legitimate interest for contacting the Client and making offers;

4.1.2. For the performance of a contract with the Client or for taking pre-contractual measures;

4.1.3. Based on legitimate interest for the protection of our rights;

4.1.4. For compliance with a legal obligation (e.g., providing information to authorities/courts).

5. Categories of Data Recipients

5.1. In processing the data of the Client Representative, Begin OÜ uses customer relationship management software.

5.2. Data transmission to an accountant is necessary for service provision. Additionally, data may need to be transferred to a legal advisor for service provision and to authorities/courts.

6. Data Retention Period

6.1. Begin OÜ retains the data of the Client Representative for 3 - 10 years from the last contact related to the Client (including the termination of the Client’s contract). Begin OÜ follows the statute of limitations for data retention (generally 3 years), after which the Client Representative’s data is deleted or anonymized.

7. Data Subject Rights:

7.1. Receive information about the processing of personal data and access their data;

7.2. Submit a request to Begin OÜ to correct, delete, or restrict the processing of their data;

7.3. Request data portability when the legal basis for processing is consent or a contract and the data is processed automatically. Begin OÜ will transfer the data to another data controller upon request if it is technically feasible;

7.4. Object at any time to the processing of personal data based on legitimate interest;

7.5. Review the assessment of legitimate interest by sending a request to the data protection officer’s email address;

7.6. Lodge a complaint with the Data Protection Inspectorate to protect their rights.

8. Cookies

8.1. Cookies are small text files that are stored on your computer or other device when you visit a website. Cookies help Begin OÜ recognize the device you use on the website.

8.2. Begin OÜ collects the following data about website visitors: IP address, browser, country, language, device type (mobile, tablet, desktop).

8.3. Begin OÜ uses the collected data to ensure:

8.3.1. The best service quality, including providing more convenient options for using the website. This is necessary to display a suitable personalized solution to users;

8.3.2. The protection of rights, including network, information, and cybersecurity considerations. Collecting data allows for a quick response in case of a possible attack on the website (e.g., any deviation from normal behavior).

8.4. Each website visitor can change their browser settings to choose which cookies are allowed and which are not, including accepting or refusing all cookies.

8.5. Not all functionalities of Begin OÜ’s website may work if you disable certain cookies.

Effective from: 01.01.2024