Effective Date: 08.08.2025
Last Updated: 12.08.2025

1. Scope of This Policy

This Privacy Policy (“Policy”) applies to all personal data collected and processed by Particolar OÜ and/or its affiliates, including all persons belonging to the same corporate group, in connection with:

• Use of our websites, applications, products, and services (“Services”)
• Execution of any agreements or contracts between you (“User”) and Particolar OÜ
• Performance of regulatory obligations under applicable EU and Estonian laws

We process personal data in compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR), PSD2, AML Directives, and the Estonian Personal Data Protection Act.

2. Definitions

Personal Data – any information relating to an identified or identifiable natural person, as defined in GDPR Article 4(1).
Company Information – non-public data relating to a company, such as trade secrets, business strategies, and financial performance.
Processing – any operation performed on personal data (collection, storage, use, disclosure, deletion).

3. Data We Collect

We may collect the following categories of data:

3.1 Identification Data – full name, date of birth, ID/passport details, nationality, personal identification code.
3.2 Contact Data – email address, phone number, postal address.
3.3 Financial Data – bank account details, payment card data (processed via PCI DSS-compliant providers), transaction history.
3.4 AML/KYC Data – proof of address, source of funds, occupation, sanctions and PEP screening results.
3.5 Company Data – corporate name, registration number, address, financial and operational details when required for a project.
3.6 Technical Data – IP address, device type, operating system, browser type, login activity.
3.7 Communications – records of emails, calls, and support tickets.

4. Legal Bases for Processing

Processing is carried out on the following legal grounds under GDPR Article 6:

• Contract Performance – to deliver our Services (Art. 6(1)(b))
• Legal Obligation – AML, PSD2, tax and accounting compliance (Art. 6(1)(c))
• Legitimate Interest – fraud prevention, network security, service improvement (Art. 6(1)(f))
• Consent – for marketing or optional cookies (Art. 6(1)(a))

5. Purposes of Processing

Your data is processed to:

• Provide and maintain our Services
• Verify identity (KYC) and comply with AML regulations
• Process payments and transactions in accordance with PSD2
• Prevent fraud and monitor suspicious activity
• Communicate about changes, updates, or offers (with consent)
• Analyse service usage for improvement

6. Data Retention

We retain data only as long as necessary:

• AML data – minimum 5 years after end of business relationship (per AMLD5)
• Accounting records – 7 years (per Estonian Accounting Act)
• Marketing data – until consent is withdrawn
• Technical and security logs – up to 1 year unless required for investigation

7. Data Sharing

We may share your data with:

• Payment system operators, banks, and card schemes
• KYC/AML verification service providers
• Regulatory authorities (e.g., Estonian FIU)
• IT and hosting providers under data processing agreements

We do not sell personal data.

8. International Transfers

If data is transferred outside the EEA, we implement safeguards such as Standard Contractual Clauses or adequacy decisions.

9. User Rights (GDPR Articles 15–21)

You have the right to:

• Access your data
• Correct inaccuracies
• Request deletion
• Restrict processing
• Data portability
• Object to processing
• Withdraw consent at any time

Requests should be sent to [email protected] and will be processed within 1 month.

10. Security

We implement:

• TLS encryption
• Strong Customer Authentication (SCA) for PSD2 transactions
• Role-based access controls
• Regular security audits

11. Third-Party Websites

This Policy does not cover external websites linked from our Services. We are not responsible for their content or privacy practices.

12. Changes to This Policy

We may update this Policy to reflect changes in law or practice. Updates will be posted with the “Last Updated” date.

Cookie Policy

We use cookies to improve your browsing experience and analyse website usage.

Types of Cookies:

• Strictly Necessary – essential for website operation (e.g., secure login)
• Analytics/Performance – Google Analytics to understand usage patterns (anonymous data)
• Targeting/Advertising – to deliver relevant content and ads (with consent)

You can manage cookies via your browser settings. Blocking cookies may affect website functionality.

Contact

Particolar OÜ
Registry code: 16457865
Harju maakond, Tallinn, Nõmme linnaosa, Rännaku pst 12, 10917, Estonia
Email: [email protected]
Phone: +357 22008830

Information about using of cookies.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or mobile phone if you agree. Cookies contain information that is transferred to your computer's hard drive. We use session cookies which are cookies which expire once you close your web browser.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website and enter into transactions.
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We use Google Analytics cookies. Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit this site. For more information on Google Analytics, please click here.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
• Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.