Notice on Cookie Use and Privacy Policy

The Notice on Cookie Use and Privacy Policy (hereinafter referred to as the „Notice“) contains useful information on how and for what purpose the company collects, processes, and shares personal data (data). The Privacy Policy is based on the General Data Protection Regulation (GDPR).

The purpose of the Privacy Policy is to protect the privacy of customers in accordance with the laws of the Republic of Estonia and the legislation of the European Union.

„Personal data“ is any information about an identified or identifiable individual, such as name, address, email address, and information about viewing our website, social media channels, and use of our services.

By using our website, you agree to the use of cookies and the terms of processing personal data as described in our Cookie Use and Privacy Policy.

Valid as of July 22, 2020

  1. Whose data does UBG OÜ process?

The data controller of personal data is UBG OÜ and if you have any questions, please contact us via email at

UBG OÜ shall process the data of its customers and contact persons if they have expressed a wish to consume our services or products or have previously used our services or products.

In certain cases, we process personal data obtained from public sources.

  1. Purposes and Legal Bases for the Processing of Customer’s Personal Data (Data)

We process the personal data of voluntary users of our marketing channels, users of our services, and our customers (including customer representatives) in order to fulfil our contractual obligations as well as to provide potential customers with higher quality services and information.

If UBG OÜ processes personal data for these purposes, the legal basis for the processing is our legitimate interest in ensuring the correct and high-quality provision of our services.

From the marketing channels (including the website) of UBG OÜ, we collect data on their use and the interests of potential customers to understand the actual interests of our customers better, provide higher-quality information, and improve the functionality and user-friendliness of the website.

In this case, the legal basis for processing is our legitimate interest in better understanding the needs of our customers and providing a better service.

For example, UBG OÜ shall process data on a customer’s purchasing behaviour, reading and opening newsletters, and opening advertisements to offer the customer their preferred offers and content.

UBG OÜ shall process personal data for the following purposes:

  • Creation and management of the customer base of UBG OÜ
  • Offering new services to customers
  • Analysis and improvement of the services of UBG OÜ
  • Website management
  • Compliance with legal requirements
  • Responding to customer inquiries
  • Issuance of certifications and certificates
  1. How are the data collected?

In general, we shall collect personal data directly from data subjects and with their consent. Additionally, we use automated data collection tools, including cookies and other tracking tools, to optimise the user experience of our website and provide better services to our customers.

Cookies, Pixel Tags and Their Removal

A cookie is a small text file that is sent to the user’s web browser by a web server and stored on the hard drive of the user’s computer. This makes it possible to remember users’ preferences such as font size, communication language, device information, visitor statistics, and more.

All web browsers are set to allow cookies by default, but browser settings can generally be changed so that the browser would reject all cookies, block third-party cookies, or notify the user of any sent cookies.

Pixel tags are small pieces of website code that allow websites to read and set cookies. They are triggered when a user opens an email or arrives at a website, after which third-party cookies are downloaded or the fact, that the user opened the email, is registered.

UBG OÜ uses the following cookies:

  • Session cookies (temporary cookies), the purpose of which is to enable the use of the service.
  • Persistent cookies (stored on a user’s computer after closing the browser), the purpose of which is to remember customers’ choices at the websites of UBG OÜ.

Specifically, UBG OÜ uses:

  • Analytical cookies that collect information about how the website is used. E.g. which content pages are visited the most or what the visitors search for on the website, etc. These cookies do not collect information that would allow the user of the website to be directly identified. For example, these include Google Analytics and Hotjar cookies.
  • Advertising cookies that help deliver targeted ads based on user interests. For example, Facebook Pixel code has been added to the website and you can disable it if you would like to stop seeing the advertisements of the UBG OÜ website on Facebook. Open and under the „Advertisers you’ve interacted with“ section delete the advertiser called Eurotoetused.
  • Third-party cookies, such as YouTube and Google Maps. Location map and videos are not displayed unless the privacy terms have been accepted. To make it technically possible, we use the privacy_embeds cookie created by Avada design.

The user has the right to refuse to save cookies on the computer. To do so, the user needs to change their browser settings.

Setup instructions for most commonly used web browsers:

Internet Explorer





When blocking cookies, the user must take into account that some functions of the website may no longer be available to them.

  1. Personal Data (including data) Processed by UBG OÜ

UBG OÜ may process the following personal data (including data):

Contact details – name, email address, and telephone number

Data collected and created during the performance of a contract – personal identification code, customer preferences regarding the products and services of UBG OÜ, feedback about our services, information on habits and preferences regarding customer’s work, business processes, or studies.

Automatically collected data – data received from user’s web browser, including browser type, device type, communication language, address of the website that the user arrived from, content pages viewed by the user, as well as user’s IP address and other traffic data.

User interactions with UBG OÜ emails – including data on which emails the user opened, as well as when and how.

Other personal data – data which you have made publicly available or available to us via third-party social networks, such as LinkedIn, Facebook, Google Plus, Instagram, etc.

As a data controller, UBG OÜ shall not process special categories of personal data.

  1. Sharing of Personal Data

UBG OÜ does not transfer customer data outside the European Economic Area (EEA).

UBG OÜ does not share customers’ personal data with third parties, except under the conditions listed below. All data is used only for the purposes of communication and offering a better product or service.

We may share your personal data in the following cases:

  • Debt collection – providers of debt collection services, payment default registers.
  • National supervisory authorities and the police.
  • Public feedback under customer’s consent.
  • To facilitate the processing of payments, the company shall submit necessary personal data to Maksekeskus AS, who shall operate as a data processor.
  1. Security, Use, and Retention of Personal Data (Data)

UBG OÜ may send information about its services, products, newsletters, and offers to customers, if a customer himself or herself has provided us with his or her contact details, but only until the customer asks us to stop the aforementioned activities or leaves the group of newsletter subscribers.

6.1. Security of Personal Data

Secure retention of personal data is the highest security priority of UBG OÜ. We aim to make every effort to prevent unauthorised access, disclosure, and any other unlawful processing. We protect the confidentiality and integrity of personal data and ensure access to the data in accordance with applicable law.

To protect the personal data that we collect and process, we have implemented reasonable and sufficient organisational measures as well as technical and physical restrictions. The measures taken depend on the type of personal data and the possible consequences of their disclosure.

UBG OÜ has implemented the necessary technical, physical, and organisational safeguards to protect customers’ personal data (data) against loss and unlawful processing.

6.2. Retention Period – For how long do we store the personal data?

UBG OÜ shall retain personal data only as long as it is necessary for the purposes for which it was collected. Additionally, the retention period shall be affected by a need to respond to the requests of data subjects, solve problems, and comply with statutory requirements for the retention of documents.

When we no longer need personal data and its retention is not required under the law, we shall erase the relevant personal data.

We may continue to use such data for statistical purposes; however, only in a pseudonymised or anonymised form.

If you have any questions, please contact us via email at

  1. Rights of the Customer (Data Subject)

The customer has the right to access their own personal data that is processed by UBG OÜ and the right to obtain the rectification of inaccurate personal data.

If a customer has any questions about their rights or they feel that UBG OÜ has violated their rights while processing their personal data (data), they are advised to contact the company via email at

If you would like to stop receiving marketing communications from UBG OÜ, you may cancel them by following the instructions at the footer of every marketing communication or by contacting us via our Contacts page.

Rights of the Data Subject

Right to rectification – the data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her.

Right to erasure – the data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay if certain additional conditions have been met.

In some cases, the data subject shall have the right to obtain from the controller restriction of processing of his or her personal data.

The data subject shall have the right to access personal data that we store concerning him or her and that he or she has provided us with, as well as the right to have such data transferred to another data controller if it is technically feasible and the processing takes place based on his or her consent, or a contract, and is automated.

The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on the applicable provisions of the law, including profiling based on those provisions.

Unless otherwise provided by law, the data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

Where the processing is based on the consent of the data subject, the data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Please contact us, if you wish to exercise these rights.

If you are not satisfied with the solutions offered by UBG OÜ, you have the right to contact the Estonian Data Protection Inspectorate and a court.

  1. Other Provisions

UBG OÜ reserves the right to change the Cookie Use and Privacy Policy unilaterally. The latest version of the Cookie Use and Privacy Policy is always available on this webpage.

The laws of the Republic of Estonia apply to this Cookie Use and Privacy Policy. Any and all disputes or claims arising out of or in connection with this Policy will be resolved by the Harju County Court in Tallinn.