Last Updated: June, 2024
Introduction
Welcome to SolaInvest OU’s privacy policy.
SolaInvest OU respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
We process personal data of users in accordance with applicable laws - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“Regulation”), as well as other legal acts governing data protection and the right to privacy.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. Important Information and Who We Are
Purpose of this Privacy Policy
This privacy policy aims to give you information on how SolaInvest OU collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up.
This website is not intended for use by anyone under 18 years old and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
SolaInvest OU is the controller and responsible for your personal data (collectively referred to as “we,” “us,” or “our” in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions regarding this privacy policy. If you have any questions about this privacy policy, including any requests to exercise Your Legal Rights, please contact the DPO using the details set out below.
Contact Details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: SolaInvest OU
Email address: privacy@suggie.com
Postal address: Tornimäe tn 7-26, 10145, Kesklinna linnaosa,Tallinn,Harju maakond, Estonia
Telephone number: +371 29842795
You have the right to lodge a complaint with a supervisory authority, in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes this Regulation.
We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Inspectorate so please contact us in the first instance.
Changes to the Privacy Policy and Your Duty to Inform Us of Changes
We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-Party Links
This website might include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymized data.
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use, and share Aggregated Data including statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We collect Special Categories of Personal Data about you, specifically details about your race or ethnicity, sex life, sexual orientation, and Biometric Data in accordance with our Biometric Information Notice and Consent. We do not collect any information about criminal convictions and offenses. By choosing to submit special or sensitive data and by agreeing to our Biometric Information Notice and Consent, you hereby consent to our processing of that data.
If You Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you do not provide that data when requested, we might not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. How is Your Personal Data Collected?
We use different methods to collect data from and about you, including through:
We will receive personal data about you from various third parties as set out below:
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Visit the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before collecting Special Categories of Personal Data or sending third-party direct marketing communications to you by email or text message. You may withdraw consent to processing Special Categories of Personal Data or marketing at any time by contacting us.
Purposes for Which We Will Use Your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To process and manage your account, including to register you as a new user and to allow you to main a profile and provide information about yourself | All information user inputs when registers – unless not deleted by user or profile is active, including: (a) Identity (b) Contact (c) Financial (d) Content (e) Profile | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) With your explicit consent for Special Categories of Personal Data (d) Legitimate interests (system’s integrity requirements) |
To verify your identity and age | (a) Identity (b) Biometric | (a) Necessary for our legitimate interests (to verify identity and age) (b) Necessary to comply with a legal obligation (c) With your explicit consent for Special Categories of Personal Data |
To monitor your use of our website including: (a) Reviewing content before publication to ensure that it is not illegal and does not otherwise violate law (b) Engage in real-time monitoring and removal of content being streamed (c) Monitoring compliance with the website’s legal documents or for quality assurance purposes | Content | (a) Performance of a contract with you (b) Necessary for our legitimate interests (c) Necessary to comply with a legal obligation |
To process and deliver your order including: (a) Manage payments, fees, and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To pay money owed to you | (a) Identity (b) Contact (c) Financial (d) Transaction | Performance of a contract with you |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Communicate with you about your account (c) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To show you relevant matches and profiles and to send you notification about matches | (a) Identity (b) Contact (c) Profile | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to provide you products and services that you have requested) |
To enable you to participate in our website’s interactive, social media, or other similar features, including enabling communications and interactions between users | (a) Identity (b) Technical (c) Content (d) Profile (e) Usage (f) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to provide you products and services that you have requested) |
To enable you to partake in a prize draw, competition, or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, and grow our business) |
To administer and protect our business and this website (including security, fraud, troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To make suggestions and recommendations to you about goods or services that might be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
To help law enforcement and respond to subpoenas | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical (f) Content (g) Profile (h) Usage | Necessary to comply with a legal obligation |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional Offers from Us
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased digital goods or services from us and you have not opted out of receiving that marketing.
Opting Out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience, or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website might become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie policy
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so or will ask you for your consent.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table (Purposes for Which We Will Use Your Personal Data) above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may share or transfer your personal data outside of the European Economic Area (EEA).
If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation regarding our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for seven years after they stop being customers for tax purposes or to comply with law.
Regarding Biometric Data, please see our Biometric Information Notice and Consent.
In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.
In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What We May Need from You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
US state consumer privacy laws might provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, visit CCPA. California’s “Shine the Light” law (Civil Code § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to nonparties for their direct marketing purposes. To make that request, please send an email to privacy@suggie.com.
Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
Colorado, Connecticut, and Virginia also provide their state residents with rights to:
To exercise any of these rights, please send an email to privacy@suggie.com. To appeal a decision regarding a consumer rights request, please send an email to privacy@suggie.com.
Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out right may submit a request to this designated address: privacy@suggie.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
Notice to Illinois, Texas, and Washington Residents
The Illinois Biometric Information Privacy Act, the Business Code of Texas on the Capture or Use of Biometric Identifiers, and the Washington Biometric Privacy Law regulates the collection, storage, use, and retention of “biometric identifiers'' and “biometric information.” “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions including height, weight, hair color, or eye color. “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual.
We collect certain biometric identifiers and biometric information, namely face scan information (face geometry information and information based on that), during the identity and age verification and content moderation process. Collection of this information is required to verify your identity and age or authenticate your identity against data already obtained about you to comply with law and credit card association standards. This information is only retained for the period required for the verification and moderation process, but this data will not be retained for more than three years after your last interaction with us for Illinois residents and more than one year after your last interaction with us for Texas residents. By providing your consent for the verification and moderation process, you consent to providing us with biometric information and identifiers and for us to use and store that information for verifying and authenticating your identity and age, for content moderation purposes, and disclosure of your Biometric Data to our service providers to provide the service.
We use reasonable standards of care within our industry to store, transmit, and protect from disclosure your Biometric Data, in a manner that is the same as or more protective than the manner in which we store, transmit, and protect other confidential and sensitive information. We will not sell, lease, trade, or otherwise profit from biometric information and identifiers.
Lawful Basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed, and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third Parties
External Third Parties
We use the following categories of third parties to process your data and deliver services for the purposes shown. All of these processors have access to some of your personal data as appropriate for the delivery of the purpose specified.
Processor Category | Purpose |
Management/Moderators | Service management (such as email notifications, 2FA, etc.), monitoring, and accounting |
Age Verification | Identity and age verification services |
Content Moderation | Content moderation services |
Technical Management | Website technical and support services |
Hosting | Secure data center and hosting services |
Software Development | Service development and improvement |
Online Services | Website apps and features for users |
Payment Service Providers | Telecom PSP, credit/debit card PSP, banking, and other financial services |
Your Legal Rights
You may:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.