Privacy policy

Consent to the collection and processing of personal data
Personal data processing policy

1.1. Application. These data protection terms (Pelm Deli data protection terms) set out the general principles on the basis of which Pelm Deli processes the personal data of individual customers and users. The data protection terms apply to all customers and users who purchase Pelm Deli goods and products, consume services, visit Pelm Deli websites, stores, or otherwise consume other Pelm Deli products or services.

1.2. About the relationship when processing data.

Pelm Deli complies with the requirements of the General Data Protection Regulation (GDPR). When contacting a data processor, a data processing agreement is concluded. Pelm Deli stores are data controllers when selling goods in Pelm Deli stores.

1.3. Data protection terms. These Pelm Deli data protection terms are the general terms and conditions for the processing of personal data. Pelm Deli's data protection terms apply to the greatest extent possible to the processing of data by Pelm Deli companies, however, Pelm Deli companies may set out special terms in their privacy notices.

1.4. Contact. For questions regarding the processing of personal data by Pelm Deli, you can contact any Pelm Deli store using the contacts below or by e-mail info@pelmdeli.ee Pelm Deli, location:

• T1 Peterburi tee 2, 11415 Tallinn, +372 600 1111
• Torupilli Selver Vesivärava 37, 10152 Tallinn, +372 601 1616
• Mustakivi Prisma Mustakivi tee 17, 13912 Tallinn, +372 600 4433
• Baltijaam Kopli 1, 10412 Tallinn, +372 600 7706
• Tondi Selver A.H. Tammsaare tee 62, 11316 Tallinn, +372 600 1911

1.5. Other websites and social networks. The content of links on our websites or in social networks is governed by the privacy terms of the respective service providers. Personal data in the various social networks is processed in accordance with the privacy terms of these platforms.

1.6. Cookies. We use cookies on our website. We ask for your permission to use cookies that are not strictly necessary for the operation of the basic functions of our website or to provide the services you request on our website.

1.7. General principles. When processing personal data, we and our partners are guided by the principles set out in the General Data Protection Regulation (lawfulness, fairness, reliability, transparency, purpose limitation, minimum data processing, storage limitation, integrity and confidentiality, as well as standard and comprehensive data protection).

2. What personal data does Pelm Deli process?

2.1. Categories of personal data. Pelm Deli processes your personal data only if necessary and in accordance with the purposes of processing, always having a legal basis for such processing. We collect the following types of personal data:

2.1.1. Personal data provided by you; for example, when providing contact details (including name, postal address, telephone number, e-mail address, preferred method of communication) on our website or elsewhere (e.g. in stores,);

2.1.2. Personal data obtained as a result of ordinary communication (e.g. personal data transmitted during correspondence or in the chat on the website);

2.1.3. Personal data that you have publicly disclosed (e.g. by leaving a comment on the social networks of Pelm Deli enterprises or by leaving a reaction);

2.1.4. Personal data obtained when concluding a contract and its performance (e.g. when placing an order in the online store - name, contact information, shopping list, payment information, choice of delivery method and, where applicable, address);

2.1.5. Personal data arising from the use of services (e.g. when making a purchase or placing an order in our stores, restaurants or online stores, including personal contact details or data on purchasing preferences);

2.1.6. Personal data obtained as a result of visiting and using the website; for example, customer account information or information obtained through cookies when using the website. Cookies are installed based on your choices. More information about the information collected through cookies can be found on the website in the cookie solution;

2.1.7. Personal data obtained from third parties (if applicable), such as information confirming the right of representation of our cooperation partners who are individuals;

2.1.8. Personal data created and combined by us (for example, a list of order histories).

3. Purposes and grounds for data processing

For what purposes and on what grounds is personal data processed?

3.1. General purposes of personal data processing. Pelm Deli processes your personal data in accordance with applicable law primarily for the following purposes:

3.1.1. to conclude and perform the customer agreement, manage the customer account and communicate with the data subject;

3.1.2. to offer customer-oriented goods, products and services, including the loyalty program service (regular customer program);

3.1.3. to develop and analyze customer relationships;

3.1.4. to respond to requests from the data subject;

3.1.5. to offer services and goods to the data subject;

3.1.6. to organize surveys and conduct sweepstakes;

3.1.7. for direct marketing;

3.1.8. to manage and develop services;

3.1.9. to enable the use of the websites and improve them;

3.1.10. for compiling statistics or preparing reports;

3.1.11. for processing legal claims;

3.1.12. for fulfilling obligations arising from legal acts;

3.1.13. for other purposes specified in the Pelm Deli data protection terms or otherwise communicated to the data subject.

4. New purpose

If personal data is processed for a new purpose that differs from the purpose for which we originally collected the personal data, or if the processing is carried out without the consent of the data subject, we carefully assess the admissibility of such new data processing. In order to determine whether the data processing for the new purpose is consistent with the purpose for which we originally collected the personal data, we take into account, among other things: i) the relationship between the purposes for which the personal data were originally collected and the purposes for which the further planned processing is planned; ii) the context in which the personal data was collected, in particular the relationship between the data subject and us; iii) the categories of personal data; iv) the possible consequences of the planned further processing for data subjects; v) the application of appropriate safeguards.

4.1. Grounds for processing personal data and relationship to the purpose. Pelm Deli always processes personal data if there are legitimate grounds for doing so. We may use various grounds for data processing. We rely on the following grounds for data processing:

4.1.1. Consent. Based on consent, we process personal data within the scope of this consent and for the purposes specified in the consent. When consent is requested, it is either stated or made clear which personal data will be processed on the basis of consent. Consent may be given by a specific action, such as ticking a box or clicking the "Next" button, if this action provides consent. For example, we may use consent for the following data processing activities: i) to inform you about news about products, campaigns and future events (newsletter; email address is processed; interest list (if available); fact of subscription to the newsletter); ii) to register you as a customer (name, country, customer type, personal code, contact information); iii) to send you SMS messages informing you that your order is ready; iv) for other data processing activities based on consent, if consent was requested. You can revoke the consent you have given at any time by contacting us, for example, using the contact details provided in Section

1.4. If you do not wish to be included in the newsletter list or to receive information about products or services that may be of interest to you, you can remove yourself from the target group of recipients at any time. The revocation of consent does not affect the lawfulness of the processing that has already been carried out with personal data on the basis of consent before the revocation of consent.

4.1.2. Fulfilment of contractual obligations. We may process personal data if this is necessary based on a contract concluded with you - in other words, if the processing of personal data is necessary for the performance of a contract concluded with you or for taking steps prior to entering into a contract at your request (e.g. customer agreement). For example, to identify the customer to the extent required by the obligation to apply control measures (name of the representative, information on the right of representation, name, if necessary, information on an identification document or information on secure authentication); to fulfil obligations to the customer in connection with the provision of our services (e.g. we use the address or phone number for the delivery of goods; when providing discounts, we may process the purchase history or other necessary preliminary information to provide the discount; order information in the ordering application); to communicate with the customer (contact information) and to ensure compliance with the customer's payment obligations (customer identification information, payment information). The purpose of processing personal data may be additionally specified in the specific Agreement concluded with you.

4.1.3. Fulfilment of legal obligations. We may process personal data to fulfil legal obligations, i.e. if the processing of personal data is necessary to fulfil Pelm Deli's legal obligations. For example, obligations arising from legal acts when processing payments or complying with anti-money laundering regulations, as well as to comply with accounting requirements and obligations arising from labour laws, etc.

4.1.4. In exceptional cases, we may process personal data based on the vital interests of the data subject or on compelling public interest grounds.

4.1.5. Legitimate interest. We may use legitimate interest in connection with the management and administration of Pelm Deli and to ensure that we provide the best possible services or products on the market. Before using legitimate interest, we assess whether the processing of personal data is necessary for the legitimate interest of Pelm Deli or a third party and whether it outweighs any adverse interest of the data subject. We will only use legitimate interest if the outcome of the assessment of legitimate interest is positive. In the case of data processing based on a legitimate interest related to the data subject, the latter has the right to obtain an assessment of the relevant legitimate interest (for this purpose, please contact us using the contact information provided in Section

1.4). We may use legitimate interest in the following situations:

(i) to ensure a trusting relationship with the client, which includes, among other things, the processing of personal data for fraud prevention and the implementation of KYC measures (the person’s full name, personal code, personal identification information, contract information and, if necessary, information on the recommended product/service, verification information – e.g. information on successful authentication/signature are processed);

(ii) to manage and analyze the client base in order to improve the availability, choice, quality of services (including Pelm Deli offers), as well as to offer the client, with his consent, the most personalized offers (client ID, information on the client’s consumption of services/products);

(iii) to send marketing offers if the relevant person has previously purchased similar products/services and if the person has always previously been given the opportunity to easily opt out of such notifications (provided that such data processing is permitted in the relevant jurisdiction) (e-mail address, name, information on the service/product consumed by the client are processed);

(iv) to carry out campaigns (unless consent is given), including to carry out personalized and targeted campaigns, to conduct customer satisfaction surveys and to measure the effectiveness of marketing activities (depending on the specific campaign/study, but typically name, information/reactions provided by the customer (e.g. like/share on social media or review));

(v) ​​to create records. We may record notifications and instructions provided both on our premises and via communication means (e-mail, telephone, etc.), as well as information and other actions taken and, where necessary, use these records to confirm these instructions or other actions;
(vi) to take measures for the purposes of network, information and cyber security. For example, to combat piracy and ensure website security, as well as to create and store backup copies (depending on the situation, but typically this involves the processing of protocol information, network identifier information, other technical information);

(vii) for organizational purposes. Primarily for financial management and for the development of services and products, as well as for business planning and management, the transfer of personal data within the group for internal management purposes, including the processing of personal data of customers or employees (usually non-personalized financial data, but personalized information, such as employee names and positions, may also be used);

(viii) For business and product development and marketing activities, including within Pelm Deli (except in cases based on consent) (usually non-personalized, but there may also be necessary processing of personalized information, such as customer ID, actions within the service);

(ix) we may transfer personal data when we enter into a business transaction or negotiate a business transaction that involves the sale or transfer of our entire business or assets. Such transactions may include any merger, financing, acquisition or bankruptcy proceedings (usually non-personalized information, but may also include names of employees and representatives, positions, remuneration models);

(x) to prepare, exercise or defend legal claims (the data processed depends on the specific situation; usually name, circumstances of the situation);

(xi) if necessary, we also use the data to send you emergency notifications from the manufacturer about risk factors or recall programs (name, fact of purchase of goods/services, email address, notification);

(xii) we use surveillance cameras in our stores and restaurants. The purpose of using cameras and processing the recordings is to protect employees, visitors and property of the enterprises that are part of Pelm Deli; ensuring security; defending and exercising claims; settling claims. Recordings are deleted no later than 30 days after the storage location is filled (unless a longer period is required for the protection of legal claims).

(xiii) If the data subject has refused direct marketing offers, we store this information in order to prevent sending direct marketing offers.

(xiiii) Access to videos and recordings. Access to all video recordings is only available to persons who have the right to view the video recordings by virtue of their job responsibilities. If necessary, upon request or in cases provided by law, records may be transferred to law enforcement agencies.

5. Changes to data protection terms

5.1. Changes. By using our website or filling in the application for a loyalty account, you are deemed to have read and accepted these principles and terms. Pelm Deli reserves the right to change and supplement these data protection terms at any time in order to bring them into compliance with applicable law and the policies and objectives of Pelm Deli. We reserve the right to change the general terms of the data protection policy if necessary, by notifying us of this on our websites and, where possible, by e-mail.

5.2. Data protection contact person. If you have any questions or problems related to the processing of personal data, please contact us at info@pelmdeli.ee

These data protection terms were amended on 24.07.2024.