Privacy policy
1. General Provisions
1.1. This Privacy Policy governs the principles of collection, processing, and storage of personal data. Personal data is collected, processed, and stored by the data controller DBLE OÜ (hereinafter referred to as the "Data Controller").
1.2. For the purposes of this Privacy Policy, a data subject is a client or any other natural person whose personal data is processed by the Data Controller.
1.3. For the purposes of this Privacy Policy, a client is any person who purchases goods or services from the Data Controller’s website.
1.4. The Data Controller follows the principles of personal data processing established by law and ensures that personal data is processed lawfully, fairly, and securely. The Data Controller is able to confirm that personal data is processed in accordance with applicable legislation.
2. Collection, Processing, and Storage of Personal Data
2.1. Personal data collected, processed, and stored by the Data Controller is obtained electronically, primarily through the website and email communication.
2.2. By providing their personal data, the data subject grants the Data Controller the right to collect, organize, use, and manage personal data for the purposes defined in this Privacy Policy, whether the data is provided directly or indirectly when purchasing goods or services through the website.
2.3. The data subject is responsible for ensuring that the information they provide is accurate, correct, and complete. Knowingly providing false information is considered a violation of this Privacy Policy. The data subject is obliged to promptly notify the Data Controller of any changes to the submitted data.
2.4. The Data Controller shall not be held liable for any damage caused to the data subject or third parties resulting from the submission of incorrect data by the data subject.
3. Processing of Customers’ Personal Data
3.1. The Data Controller may process the following personal data of the data subject:
3.1.1. First and last name;
3.1.2. Date of birth;
3.1.3. Phone number;
3.1.4. Email address;
3.1.5. Delivery address;
3.1.6. Bank account number;
3.1.7. Payment card details;
3.1.8. Prescription data (including visual acuity information, sphere, cylinder, axis, pupillary distance, and other vision-related data), which are classified as special category personal data.
3.2. In addition to the above, the Data Controller has the right to collect information about the client that is available in public registers.
3.3. The legal basis for processing personal data is Article 6(1)(a), (b), (c), and (f) of the General Data Protection Regulation (GDPR), and in the case of special category data, Article 9(2)(a):
a) the data subject has given explicit consent to the processing of their personal data (including prescription and health-related data) for one or more specific purposes;
b) the processing of personal data is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
c) the processing of personal data is necessary for compliance with a legal obligation to which the Data Controller is subject;
f) the processing of personal data is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, in particular where the data subject is a child.
3.4. Processing of personal data according to the purpose of processing:
3.4.1. Purpose – security and safety. Maximum retention period – in accordance with statutory deadlines.
3.4.2. Purpose – order processing. Maximum retention period – until the order is fulfilled and up to 3 years after completion, to ensure warranty services, dispute resolution, or repeat order management. Prescription data is stored only for the fulfillment of the order and up to 3 years after completion, unless the client has given consent for their retention for a longer period for the purpose of repeat orders.
3.4.3. Purpose – ensuring the operation of the online store. Maximum retention period – up to 1 year.
3.4.4. Purpose – customer management. Maximum retention period – until the end of the customer relationship + 3 years.
3.4.5. Purpose – financial activities, accounting. Maximum retention period – in accordance with statutory deadlines.
3.4.6. Purpose – marketing. Maximum retention period – until consent is withdrawn.
3.5. The Data Controller has the right to share customers’ personal data with third parties, such as authorized processors, accountants, transport and courier companies, and payment service providers. The Data Controller is the controller of personal data. The Data Controller forwards the personal data necessary for payment processing to the authorized processor Maksekeskus AS.
3.6. In processing and storing personal data, the Data Controller applies organizational and technical measures that ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, or any other unlawful processing. For the protection of special category personal data (prescriptions), the Data Controller applies additional security measures, including restricted access, encryption, and need-to-know based processing.
3.7. The Data Controller retains data subjects’ personal data depending on the purpose of processing, but not longer than 7 years. Upon expiry of the retention period, the data will be deleted or anonymized in a way that does not allow the data subject to be identified.
4. Rights of the Data Subject
4.1. The data subject has the right to access and review their personal data.
4.2. The data subject has the right to obtain information regarding the processing of their personal data.
4.3. The data subject has the right to supplement or correct inaccurate data.
4.4. Where the Data Controller processes personal data on the basis of the data subject’s consent, the data subject has the right to withdraw such consent at any time.
4.5. To exercise their rights, the data subject may contact the Online Store’s customer support at info@specler.ee
4.6. The data subject has the right to lodge a complaint with the Estonian Data Protection Inspectorate to protect their rights.
4.7. The data subject has the right to request restriction of processing of their personal data in accordance with Article 18 of the GDPR.
4.8. The data subject has the right to request the transfer of their personal data to another controller, where technically feasible, in accordance with Article 20 of the GDPR.
5. Final Provisions
5.1. These data protection terms have been prepared in accordance with Regulation (EU) No 2016/679 of the European Parliament and of the Council (General Data Protection Regulation), the Personal Data Protection Act of the Republic of Estonia, and other applicable legislation of the Republic of Estonia and the European Union.
5.2. The Data Controller has the right to amend these data protection terms in part or in full, informing data subjects of such changes through the website specler.ee
Effective Date: 01/07/2025
DBLE OÜReg. Code 14769690
VAT no. EE102281073
Vae tn 2, 76401