1. General principles of processing of personal data

1.1. Portal operator processes user's personal data fairly, in a manner and to the extent provided for by the law.

1.2. The portal operator and its employees apply all diligence and security measures required by the law at processing user's personal data to ensure only that it is only done for a purpose and to protect user's personal data against inadvertent or unauthorised use, disclosure or destruction.

1.3. The portal operator enables access to the user's personal data only to a restricted number of its employees who agree to keep user's personal data confidential based on the relevant agreements concerning keeping of professional secret entered into with them for the period of working in the portal operator's organisation as well as after termination of the employment relationship. The portal operator excludes access of the unauthorised third persons to user's personal data and database of the portal operator containing such data.

2. The purpose of processing of personal data

2.1. The portal operator permitted by the law for processing of the personal data. The portal operator excludes the improper processing of user's personal data.

2.2. The portal operator processes the personal data with the goal to ensure the welfare of the users, perform the contracts entered into with and/or between the users and adhere to the requirements prescribed to the portal operator by the law.

2.3. The main goals of the portal operator in connection with processing of user's personal data are as follows:

2.3.1. To ensure the due identification of the user.

2.3.2. To assess the capability of the user to perform immediately the financial obligations of the contracts.

2.3.3. To ensure immediate due performance of the contractual financial duties.

2.3.4. To enable the portal operator to deliver to the user the portal operator's products and related promotional materials and/or notices, also the products and/or promotional materials and/or notices of the persons belonging to the same Group with the portal operator or third party cooperation partners of the portal operator if the user has given his or her prior consent to the portal operator.

2.3.5. To analyse the user satisfaction and preferences towards the products and services of the portal operator and persons belonging to the same Group with it to enable more effective product and service development and marketing activities.

2.4. The portal operator is entitled to process user's personal data also for other purposes if they are necessary for performance of the obligations provided by the law or if such goals are justified for performance of the contracts entered into with and/or between the users.

3. Personal data and their processing

3.1. The processor of the personal data will be the portal operator with the following contact information:

EstateGuru OÜ

Registration Number: 12558919

Address: Kohtu 10-15, Tallinn 10130, Estonia

E-mail info@estateguru.co

3.2. The collection, recording, retention, arrangement, use, amending, delivering, disclosure and deleting of user's personal data by the portal operator is deemed as processing of the personal data, but also other processing activities of personal data provided by the law.

3.3. The portal operator keeps the database about the users' personal data and other information which primarily reflect the following personal data of the users:

- First name and surname

- Personal identification code

- Date of birth

- Gender

- Residence and/or location

- Communication means (phone, e-mail, etc)

- Communication language

- Bank account information

- Data of identity document

- Family-related information

- Education and work-related information

- Financial data (incl information about income, debts and earlier payment behaviour, also information about persons related to the user).

- Other information the user has delivered to the portal operator, or which the portal operator has collected at its own initiative from the sources permitted by legislation (incl via media and Internet).

- User's portal user data (user name, beginning and end of registration in the portal, etc).

- Information about the contracts of the user entered into via the portal and payment behaviour of the user based on these contracts.

3.4. The portal operator may reflect also other user related information in the user database if there is a justified need for it regarding the performance of the contracts and if processing of such data does not contradict the law.

3.5. The moment the user has registered himself or herself as the user of EstateGuru is deemed as giving consent by the user to the portal operator to process personal data (including transfer and disclosure of user's personal data to the extent prescribed in clause 4 of these terms and conditions) described in these terms and conditions.

4. Transfer and disclosure of personal data

4.1. The portal operator is entitled to transfer user's personal data primarily to:

4.1.1. The third persons whose economic or professional activity includes valuation of credit capability or other equivalent activity (including credit information; payment default register).

4.1.2. Credit institutions for identification of the user

4.1.3. Persons whose economic or professional activity includes provision of service of collection of debts and other related services for collection of contractual debt(s) of the user

4.1.4. Other users to facilitate the conclusion and performance of contracts between the users

4.1.5. Persons to who the portal operator is obliged to transfer user's personal data based on the law.

4.1.6. Person providing the accounting services to the portal operator, also the persons providing legal assistance in connection with contracts entered into with or between the users.

4.2. The portal operator is entitled to transfer user's personal data to the third persons in case of cases not described in clause 4.1 of these terms and conditions only when there is justified interest for ensuring the performance of the contracts entered into with or between the users transfer of information to such person shall not contradict the law.

4.3. If the user has separately given such consent to the portal operator, the portal operator is entitled to transfer user's personal data (primarily the user's name and e-mail address) to the persons to who the portal operator has assigned a duty to market and promote portal operator's products to the user.

4.4. In case of financial debt(s) of the contract(s) entered into by the user via the portal, the portal operator and/or persons described in clause 3.1.1 and/or clause 3.1.2 of these terms and conditions is entitled to disclose user's personal data (primarily the name, personal identification code/business ID, amount of debt) in a manner, by procedure and via channels not prohibited by the law. The portal operator and/or the persons described in clause 3.1.1 and/or clause 3.2.2 of these terms and conditions are entitled to disclose user's personal data however not earlier than after 30 (thirty) days from commencement of the debt obligation. If the law prescribes the consent of the user for disclosure of the personal data, it is deemed that the user has given such consent to the portal operator or the persons indicated in clause 3.1.1 and/or clause 3.1.2 of these terms and conditions with registration as the user of EstateGuru.

4.5. Based on the contracts entered into/to be entered into, the portal operator agrees to oblige all third persons to who user's personal data are transferred for the purposes described in this chapter (4) that they process user's personal data only and exclusively for the purposes prescribed in this chapter (4).

5. User rights and obligations in connection with processing of the personal data

5.1. The user agrees to transfer to the portal operator the required personal data described in these terms and conditions, which must be correct, valid and complete.

5.2. The user agrees to inform the portal operator immediately about the changes in the personal data, also about incorrectness or invalidity of personal data by delivering the portal operator also the correct and valid personal data to replace the incorrect and/or invalid ones.

5.3. The user shall be fully responsible for his or her correct and valid personal data during the whole period of use of EstateGuru.

5.4. The user is entitled to demand information from the portal operator at any time about the personal data collected by the portal operator about him or her, also about the persons to who the portal operator has delivered the user's personal data. For that, the user submits relevant application in a format which can be reproduced in writing to the portal operator. The portal operator performs the application within five (5) working days from receiving the application from the user. The portal operator is entitled to refuse from transfer of the above specified information in cases and extent provided by the law.

5.5. The user is entitled to demand finishing of processing of the personal data from the portal operator, and the portal operator is obliged to finish processing of user's personal data if the user has duly performed all obligations of the contracts entered into with the portal operator and/or another user and the user's contracts entered into with the portal operator and/or other user are terminated.

5.6. Despite the provisions of clause 5.5 of these terms and conditions, the user is entitled to demand at any time finishing of processing of user's personal data from the portal operator for the purposes described in clause 4.3 of these terms and conditions.