Last Updated: 04.10.2023
This Privacy Policy, as amended or otherwise changed from time to time (the "Privacy Policy" or
"Policy"), explains the manner in which ASTUDYPL OÜ, 16832725, Harju maakond, Tallinn,
Kesklinna linnaosa, Tornimäe tn 5, 10145 (hereinafter "ASTUDYPL OÜ" or the "Company")
maintains and discloses user information obtained through its website
(the "Site"). The terms "we," "us," and "our" refer to the Company. By using the Site, you ("User")
consent to the data practices prescribed in this Privacy Policy.
Your Personal Data is processed under this Privacy Policy and in accordance with applicable
legislation, including the General Data Protection Regulation (2016/679) ("GDPR") and the
applicable national data protection laws ("Data Protection Law").
The Company acts as data controllers of your Personal Data.
On occasion, the Company may revise this Privacy Policy to reflect changes in the law, our
personal data collection and use practices, the features on the Site, or advances in technology. If
material changes are made to this Privacy Policy, the changes will be prominently posted on the
What if I do not want to accept this Privacy Policy?
By using this Site, you signify your acceptance of this Policy. If you do not agree to this Policy,
please do not use our Site. Your continued use of the Site following the posting of changes to
this Policy will be deemed as your acceptance of those changes.
In case you disclose any Personal Data regarding any third person (e.g. your employee,
management board member, co-worker, contracting party, etc.) to us, you are obliged to refer
them to this Policy.
What information does the Company collect?
We collect Personal Data and Anonymous Data, as described below.
We may collect Personal Data from you, such as:
● first and last name
● e-mail and mailing addresses
● date of birth
● photos
● gender
● phone number
● other
If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address,
as well as any other content included in the e-mail, in order to send you a reply.
Some information is collected automatically by our servers:
● Our servers (which may be hosted by a third-party service provider) collect information
from you, including your browser type, operating system, Internet Protocol ("IP") address
(a number that is automatically assigned to your computer when you use the Internet,
which may vary from session to session), domain name, and/or a date/time stamp for
your visit.
● As is true of most websites, we gather certain information automatically and store it in
log files. This information includes IP addresses, browser type, Internet service provider
("ISP"), referring/exit pages, operating system, date/time stamp, and clickstream data.
● Like many online services, we use cookies to collect information. "Cookies" are small
pieces of information that a website sends to your computer's hard drive while you are
viewing the website.
● We retain information on your behalf, such as transactional data and other session data
linked to your account.
We do not collect any Special Categories of Personal Data about you (this includes details
about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health and genetic and biometric
How does the Company use the information it collects?
In general, Personal Data you submit is necessary for contacting you in the context of the
delivery of products or services and administering such products and services. Also, we use your
Personal Data in the following ways:
● identify and perform identity verification through a service provider
● provide improved administration of Site and services
● improve the quality of experience when interacting with Site and services
● send a welcome e-mail to verify ownership of the e-mail address provided when account
was created
● other
● notify about important changes to Terms and Conditions
● identify, prevent, and report potentially suspicious, fraudulent, or illegal activities
● send administrative e-mail notifications, such as account activity, transaction
processing, security or support, and maintenance advisories
The Company does not sell user and/or Anonymous Data to any third party.
Marketing and newsletter subscriptions.
We collect information about your behaviour within the application to oer you interesting
information and oers regarding our services and products. This information includes your profile
information and user status. This information is processed automatically and you as a user will
notice it by seeing more relevant content when signed in. We do not share this information with
third parties. The processing of such personal data is based on our legitimate interest to develop
and promote our services and products. If you have subscribed to our mailing list, we will send
you information on our new activities, events, and products. We can also send special oers
directed to a special user group, users of a certain region, etc. Adding you to our mailing lists is
based on your consent. You may also unsubscribe from the mailing list anytime by clicking the
unsubscribe link at the bottom of each message.
Customer support.
In case you need to contact our customer support, our support personnel will handle your
contact information and the contents of your communication. Please do not share any sensitive
data in your communication with our customer support. You can contact our customer support
through various means. Depending on the means of communication you choose, we'll process
the following contact details: - Your IP address (chat support) - Phone number (phone support,
SMS support) - Email (email support) - User ID of an instant messaging app (QR code, support
through an instant messaging app). We keep a record of the contents of the support tickets to
make sure that you receive quality service and to develop our products and services. If you
contact us by calling our support number, please note that we also record the phone calls for the
same purposes. The processing of your personal data in connection with your communication
with our customer service is based on the service agreement between you and the Company as
well as our legitimate interest to follow up on the quality of our customer service, to verify the
actions taken based on your request and to develop our service in the future.
How does the Company share my Personal Data?
It may be necessary to disclose your information to comply with any law, court orders, or
government request, defend against claims, investigate or bring legal action against illegal or
suspected illegal activities, enforce our Terms, or protect the rights, safety, and security of the
Company, our users, or the public.
Other than as stated in this Privacy Policy, the Company does not disclose any of your personal
information to third parties unless required to do so by law enforcement, court order, or in
compliance with legal reporting obligations.
All third-party service providers that we share your data with shall be requested to only process
your data in accordance with instructions from us and comply fully with this Privacy Policy, any
applicable data protection laws and any other appropriate confidentiality and security measures.
We may also share your personal data with competent authorities when this is necessary to
comply with a legal obligation, court order or comparable ocial order issued by an authorized
We may share some or all of your Personal Data in connection with or during negotiation of any
merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer,
divestiture, or disclosure of all or a portion of our business or assets. In the event of an
insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business
If another company acquires our company, business, or assets, that company will possess the
Personal Data collected by us and will assume the rights and obligations regarding your Personal
Data as described in this Privacy Policy.
The Site may contain links to other third-party websites which are regulated by their own privacy
policies. The Company is not responsible for the privacy policies of these third-party websites
even if they were accessed using the links from our site.
How long do we store your personal data?
We keep the data you have provided to us on your user account for the whole period of your
customer relationship and as long as it is necessary with regard to the purposes of the
processing described above.
How we transfer collected information internationally?
We may transfer the collected information we obtain from you to recipients in countries other
than the country in which the information was originally collected. Those countries may not have
the same data protection laws as the country in which you initially provided the information. The
collected information may be transferred to a destination outside the European Economic Area
("EEA"). All data transfers outside the EEA are made under agreements and include all necessary
standard data protection clauses adopted by a supervisory authority. These providers acting in a
fully-compliant manner with GDPR.
What legal rights do you have in relation to your information?
Under certain circumstances, you have the following rights under data protection laws in relation
to your personal data:
● Request access to your personal data.
● Request correction of your personal data.
● Request erasure of your personal data.
● Object to processing of your personal data.
● Request restriction of processing your personal data.
● Request transfer of your personal data.
● Right to withdraw consent.
You also have the right to lodge a complaint with a Data Protection Authority ("DPA") if you think
that your Personal Data is being processed incorrectly or your rights have been violated by the
Company. The Estonian Data Protection Inspectorate is available at
You will not have to pay a fee to access your personal data (or to exercise any of the other
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 aect 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.
Please note that in certain circumstances it may be still lawful for us to continue processing your
information even where you have withdrawn your consent if one of the other legal bases is
How can you send requests regarding your information?
You can make a request regarding your information by emailing
Unless you have made a corresponding request, we will retain your information for as long as
your account has not been closed or as needed to provide you access to your account.
If you wish to close your account, please contact support team via e-mail. We will retain and use
your information as necessary to comply with our legal obligations, resolve disputes, and enforce
our Terms.
Where do we store your Personal Data?
The information we collect is primarily stored on secure servers Estonia. We will take all steps
reasonably necessary to ensure that personal information is treated securely and in accordance
with this Privacy Policy and that any third parties that we share your information with are bound
to employ similar organizational and technical measures to ensure your information's security.
What security precautions does the Company take to protect me?
We take the protection of your personal information seriously. We use industry-standard data
encryption technology and have implemented restrictions related to the storage of and the
ability to access your personal information. However, despite all of our eorts, please note that
no transmission over the Internet or method of electronic storage can not be guaranteed to be
100% secure.
Contacting Us
If you have any questions about our Privacy Policy as outlined above, please contact us at
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