In order to better serve you, we may collect personal information, including, but not limited to, your name, email address, postal address, telephone number, direct marketing choices, and technical information transmitted by digital devices (e.g. cookies and similar technologies). We may also process, to the extent reasonably necessary for the purposes of customer service, other necessary personal data for the purposes you have previously notified us of.

We collect your personal data with your consent at the beginning of and during the course of your customer relationship when you purchase and use products and services from us. We will only collect your personal information if you voluntarily provide such information.

We process personal data for the following purposes:

• customer relationship management and customer communication.

• concluding and executing a contract with a client or a contract concluded with a client.

• responding to customer enquiries

• developing and analysing client relationships

• offering products and services

• direct marketing

• legitimate interest

• research into consumer behaviour

• managing and developing services

• using and improving the website

• conducting draws and surveys

• compiling sales statistics

• protection of persons and property

• to comply with their legal obligations.

In some cases, we may use third party service providers (such as software development, marketing, payment and postal service providers) to process your personal information. All third party service providers to whom we transfer your personal information have agreements in place to protect your personal information and to keep the information we transfer confidential. In addition to the foregoing, we are entitled to transfer personal data to supervisory, investigative and law enforcement authorities in the cases provided for by law.

We use state-of-the-art technical and organisational security measures in the collection, storage and processing of your personal data to protect against unauthorised access, alteration, disclosure or destruction of personal data stored in databases and websites. Access to modify and process personal data is restricted to authorised persons.

We may process your personal data for as long as is necessary to fulfil the customer relationship or equivalent relationship between a Group company and you, until you withdraw your consent to the processing of your personal data, or for tax and legal purposes, up to the statutory time limits.

We may, with your consent, use the personal information you provide to send you information about promotions, campaigns and offers and to conduct satisfaction surveys. In the event that you no longer wish to receive direct offers, you have the right to withdraw your consent to the processing of your personal data at any time by following the instructions in the direct mail or by contacting us at info@proswim.ee.

ProSwim.ee website uses cookies. A cookie is a tiny text file that is automatically stored by the browser on the user's device. Cookies are used to collect information about how a user uses the website, with the aim of providing a better user experience.

The following cookies are used on the websites:

• session cookies, which are designed to enable you to use the website;

• loyalty cookies, which are designed to remember the customer's choices on the website;

• first- and/or third-party cookies, which are used to show the user relevant advertising and offers;

• third-party analytics cookies aimed at optimising marketing communications.

Users can delete and/or block cookies stored on their devices by changing the relevant settings on their browser. If cookies are not used, the website may not function as intended and/or some functionalities may not be available to users.

In addition to the use of analytics cookies, websites use pixel tags (web beacons) to track website usage. In doing so, no personally identifiable information is processed.

When you visit the ProSwim.ee website, we may collect non-personally identifiable information from you, such as the date and time of your visit to the website, information downloaded from the website, browser name and operating system information, internet service provider and similar information. This data is processed anonymously and is used to improve the functionality of the website.

We may transfer personal data to third countries (countries that are not part of the European Union or the European Economic Area) only if there is a legal basis for doing so.

We may use your personal data and purchase statistics for profiling purposes in order to better understand your expectations and, consequently, to provide you with a better choice of goods and services. We do not make any legally binding decisions about you as a result of profiling.

At any time, you have the right to ask us for your personal data, to request the correction and transfer of your personal data and to request the deletion of your personal data.

If you have any requests concerning the processing of your personal data, please send an e-mail to info@proswim.ee.

We have the right to refuse your request if your identity cannot be verified or the transmission of your personal data is not secure.We have the right to refuse your request to erase your personal data if the obligation to process your personal data arises from a valid contract, the law or is necessary for the establishment, exercise or defence of legal claims relating to the protection of persons or property.

We reserve the right to change and amend this Privacy Policy. The current privacy policy is always available on our website.

If you believe that we are processing your personal data in breach of your rights, you have the right to contact us at any time. info@proswim.ee, the Data Protection Inspectorate or the courts.

This privacy policy has been updated on 27.02.2019