This policy describes the procedures followed by Walleteze OÜ (hereinafter "Walleteze” or the "Data Controller") in relation to the processing of personal data collected through the walleteze.com website (hereinafter "Website").

Unless otherwise specified, this policy also applies as information - pursuant to article 13 of Legislative Decree 196/2003 (hereinafter the "Code") and article 13 of Regulation (EU) 2016/679 (hereinafter "GDPR") – rendered to those who interact with the Site (hereinafter "User").

Information on the processing of detailed personal data is reported, where necessary, on the related pages to the individual services offered through the Site. Such information is aimed at defining limits and modalities of the processing of personal data of each service, based on which the User can freely express consent, if necessary, and possibly authorize the collection of data and its subsequent treatment.

Data controller responsible for treatment
The data controller is Walleteze OÜ - registered office: A. Reinvaldi 3-2, Tallinn, Harjumaa, Estonia, email: info@walleteze.com

Responsible for data protection
The person in charge of data protection, as designated by the Data Controller, can be contacted via:
  • ordinary mail: A. Reinvaldi 3-2, Tallinn, Harjumaa, Estonia
  • telephone: +372 56963090
  • e-mail: info@walleteze.com
Types of data processed
Through the Website, it will be possible to collect and process:
  • navigation data;
  • personal data voluntarily provided by the User in forms present on the Site.
Cookies are small text files that a visited site stores in the visitor’s browser, and can be read (only by the originating site) later.

This Website uses technical cookies, both its own and from third-parties. These cookies, being of a technical nature, do not require the prior consent of the User to be installed and used.

In particular, the cookies used on this Site are traceable to the following sub-categories:
  • browsing or session cookies, which guarantee the normal navigation and use of the Site. Not being stored on the User’s computer, these disappear when the browser is closed;
  • analytical cookies, with which statistical information on the number of users and visits to the Site is collected and analyzed;
  • social widgets and plugins: some widgets and plugins made available by social networks can use their own cookies to facilitate interaction with the Site
Below are the third-party cookies installed on the Site. For each of them, there is a link to related information on the processing of personal data and how to deactivate the cookies used. As third-party cookies, the Data Owner is only obligated to provide relevant links to the third-party websites - responsibility for consent and/or refusal of such cookies lays with the data subject.

No third-party cookies are implemented by this Site

Users can disable cookies by changing their browser settings - instructions for doing so are made available by each browser provider, however, doing so will adversely affect the proper operation of this website and may jeopardise the security of the User's account.

Purpose and legal basis of the processing
Personal data collected through the Site will be processed:
  • to handle requests for information or information documents forwarded by the User. The processing of personal data for the aforementioned purposes does not require the consent of the User as the treatment is necessary to fulfill specific requests of the interested party pursuant to article 24, c. 1, let. b) of the Code and of article 6, c. 1, let. b) of the GDPR.
  • only subject to specific and distinct consent by the User (article 6, c. 1, let. a and article 7 of the GDPR), for marketing purposes such as sending by e-mail, mail and/or text messages and/or telephone, newsletters, commercial communications and/or advertising material on products or services offered by the Data Owner.
Provision of data and consequences in case of failure to provide
The provision of personal data for the aforementioned purposes is optional and their non-conferment, as a sole consequence, will render it impossible for the Data Owner to manage and process requests concerned.

Method of treatment
Personal data will be processed electronically, including through insertion and organization in databases, in compliance with the provisions of the Code and the GDPR relating to security measures.

Recipients or categories of recipients
Personal data may be made accessible, brought to the attention of, or communicated to the following subjects, which will be appointed by, as the case may be, those responsible or persons in charge:
  • Group companies to which the Holder (controlling, controlled, affiliated), employees and/or collaborators belong to any title of the owner and/or company of the group to which the Holder belongs;
  • public or private subjects, natural or legal persons, of which the Data Controller makes use for the carrying out activities instrumental to the achievement of the aforementioned purpose, or to which the Holder is required to communicate personal data, pursuant to legal or contractual obligations.
In any case, personal data will not be disclosed.

Retention period
Personal data will be kept for 5 years after last use of Walleteze services by the User.

Access rights, cancellation, limitation and portability
The interested parties are granted the rights referred to in articles 7 of the Code and from 15 to 20 of the GDPR. By title example, each interested party can:
  • obtain confirmation of the processing of personal data concerning him or her;
  • if processing is in progress, obtain access to personal data and information regarding the treatment and request a copy of personal data;
  • ensure the correction of inaccurate personal data and the integration of incomplete personal data;
  • obtain, if one of the conditions foreseen by article 17 of the GDPR is met, the deletion of personal data concerning him or her;
  • obtain, in cases provided for by article 18 of the GDPR, limitation of treatment;
  • receive applicable personal data in a structured format, and request its transmission to another holder if technically doable.
Opposition right
Each interested party has the right to object at any time to the processing of his or her personal data made for the pursuit of a legitimate interest of the owner. In the event of opposition, your data personal data will no longer be processed, provided that there are no legitimate reasons to proceed with the processing that prevail over the interests, rights and freedoms of the data subject or the assessment, exercise or defense of a right in court.

This policy will be subject to updates. The owner therefore invites Users wishing to know how to personal data collected through the Site is processed to visit this page periodically.