This Privacy Notice explains how Emelum OÜ, registry code 17234831, Nõmme tn 30, Kärdla linn, Hiiumaa vald, 92412, Estonia ("Emelum", "we", "us"), processes personal data in connection with the website at emelum.com (the "Site"), the Emelum newsletter, and inquiries addressed to us. Emelum OÜ is the data controller for this processing.
This notice covers the corporate Site only. Software platforms and products operated by Emelum are governed by their own privacy policies, published on their respective websites; those policies, not this notice, describe how product data is processed.
1. What we collect
a) Inquiries. When you contact us through the Site or by email (hello@emelum.com), we process the data you choose to provide: name, email address, organization, role, and the content of your message and any attachments. Please do not send confidential or proprietary material before a written agreement is in place, as set out in the Terms of Use.
b) Newsletter subscription. When you subscribe to our newsletter or insights, we process your email address, the subscription timestamp, your confirmation of the subscription, and delivery and unsubscribe events.
c) Technical data. When you visit the Site, our hosting infrastructure automatically processes your IP address, browser type and version, operating system, referring page, pages visited, and access timestamps, in server logs, for the operation and security of the Site.
d) Browser storage and consent records. Only as described in the Cookie Notice. Where you record a cookie choice, we store that choice together with a timestamp and a truncated, hashed record of the request, so that the choice can be honored and evidenced.
We do not collect special categories of personal data through the Site and ask that you do not send them to us.
2. Purposes and lawful bases
| Purpose | Data | Lawful basis (GDPR) |
|---|---|---|
| Responding to inquiries | Inquiry data | Legitimate interests (Art. 6(1)(f)); steps prior to entering a contract (Art. 6(1)(b)) where relevant |
| Sending the newsletter you subscribed to | Subscription data | Consent (Art. 6(1)(a)), withdrawable at any time via the unsubscribe link in every issue or by email |
| Operating and securing the Site | Technical data, server logs | Legitimate interests (Art. 6(1)(f)) |
| Recording and honoring cookie choices | Consent record | Legal obligation (Art. 6(1)(c)) |
| Establishing, exercising, or defending legal claims | Any of the above, as necessary | Legitimate interests (Art. 6(1)(f)) |
| Compliance with legal obligations | Any of the above, as necessary | Legal obligation (Art. 6(1)(c)) |
We do not use Site data for automated decision-making producing legal or similarly significant effects, and we do not sell personal data.
3. Retention
- Inquiry correspondence: up to 24 months after the matter is closed, unless a business relationship follows or law requires longer retention.
- Newsletter data: until you unsubscribe; after unsubscribing we retain only the minimal record needed to honor the opt-out.
- Server logs: up to 12 months.
- Cookie consent records: up to 24 months, as evidence of the choice made.
- Data needed for legal claims or statutory obligations: for the applicable limitation or retention period.
4. Recipients and international transfers
We use service providers to host and operate the Site and to deliver email, acting as our processors under data processing agreements. Our hosting and email infrastructure is cloud-based and may process data in the United States. Where personal data is transferred outside the EEA, we rely on European Commission Standard Contractual Clauses or, where the provider is certified, the EU-US Data Privacy Framework. We disclose personal data to authorities only where legally required.
5. Your rights
You have the rights of access, rectification, erasure, restriction of processing, data portability, and objection, and the right to withdraw consent at any time with effect for the future. To exercise any right, email hello@emelum.com; we respond within the timeframes required by the GDPR. You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee) or the supervisory authority of your habitual residence.
6. Children
The Site and newsletter are not directed at children, and we do not knowingly collect children's data through them.
7. Changes
We may update this notice from time to time; the "Last updated" date indicates the current version. Material changes will be indicated on this page and, for newsletter subscribers, in the newsletter.
8. Contact
Emelum OÜ, Nõmme tn 30, Kärdla linn, Hiiumaa vald, 92412, Estonia. Email: hello@emelum.com. Full company details: Legal Notice.