PRIME SUSHI TAKE AWAY (VALVIT OÜ) – PRIVACY POLICY

Effective Date: October 13, 2025
Last updated: October 13, 2025

1. INTRODUCTION

This Privacy Policy describes how Prime Sushi Take Away (Valvit OÜ) ("we", "our", "us") collects, uses and protects your personal data when you use our online ordering website and related digital services ("Services").

We value your privacy and are committed to protecting your personal data in accordance with the EU General Data Protection Regulation (GDPR) 2016/679 and applicable Estonian data protection legislation.

By using our Services, you agree to this Privacy Policy and consent to the processing of your personal data as described below.

2. INFORMATION ABOUT THE COMPANY

• Data controller: Valvit OÜ
• Commercial name: Prime Sushi Take Away
• Registration code: 17314932
• Legal address: Ümera tn 11-124, Lasnamäe district, 13816 Tallinn, Harju County, Estonia

Email: velnagap@gmail.com

Legal form: Private limited company (Osaühing)
Registration date: August 29, 2025

3. PERSONAL DATA WE COLLECT

We may collect and process the following categories of personal data when you use our Services:

a) Identification data: first and last name.
b) Contact information: e-mail, telephone number and delivery address.
c) Order data: products ordered, payment data (processed securely by third-party providers), order history.
d) Technical data: IP address, device information, browser type, cookies.
e) Communication data: messages or feedback sent via feedback forms or customer support channels.

We collect data directly from you or automatically through cookies when you use our website.

4. PURPOSES AND LEGAL BASIS OF PROCESSING

We process your data for the following purposes:

• Purpose Legal basis
• Registration and processing of orders, payments and deliveries Performance of the contract (Article 6(1)(b) GDPR)
• Contacting you regarding orders, support or inquiries Legitimate interests (Article 6(1)(f) GDPR)
• Sending marketing offers and promotions (only with your consent) Consent (Article 6(1)(a) GDPR)
• Maintaining and improving the website, preventing fraud, ensuring security Legitimate interests (Article 6(1)(f) GDPR)
• Compliance with a legal obligation (e.g. accounting, taxes) Legal obligation (Article 6(1)(c) GDPR)

5. COOKIES AND TRACKING TECHNOLOGIES

We use cookies to improve user experience, analyze site traffic, and support functionality (such as saving a shopping cart).

Cookies are small data files stored on your device. You can disable them in your browser settings, but this may limit the website's functionality.

We use both essential cookies (necessary for the website to function) and optional cookies (analytics and marketing – only with your consent).

6. DATA STORAGE

We store personal data only for as long as necessary:

• Order and accounting data: 7 years (according to Estonian law)
• Correspondence with clients: up to 2 years after last contact
• Marketing data: before consent is withdrawn
• Technical data/cookies: cookie lifespan or until consent is revoked

7. DISCLOSURE OF PERSONAL DATA

We can only transfer data to trusted partners and providers:

• Payment systems (Stripe, PayPal, Maksekeskus)
• Delivery services (couriers, logistics)
• IT and hosting providers (website, email)

All partners are bound by data processing agreements and comply with the GDPR.
We do not sell or rent your data to third parties.

8. DATA TRANSFER OUTSIDE THE EEA

Your data is generally stored within the European Economic Area (EEA).
If the transfer takes place outside of our jurisdiction, we provide protection through EU Standard Contractual Clauses (SCCs) or equivalent measures.

9. DATA SECURITY

We use modern technical and organizational measures:

• Encrypted connections (SSL/TLS)
• Secure data storage and restricted access
• Regular monitoring and system updates

However, complete security of data transmission over the Internet cannot be guaranteed.

10. YOUR RIGHTS UNDER THE GDPR

You have the right to:

• Access: Request a copy of your data.
• Corrections: make changes or additions.
• Deletion: request deletion of data (“right to be forgotten”).
• Restrictions: temporarily restrict processing.
• Portability: obtain data in machine-readable format.
• Objections: object to processing for marketing purposes or based on legitimate interests.
• Withdrawal of consent: You can withdraw your consent to marketing at any time.

Contact us: velnagap@gmail.com

We respond to all inquiries within 30 days.

Complaints can be submitted to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon):

🌐 www.aki.ee

📧 info@aki.ee

11. MARKETING MESSAGES

You can receive emails or SMS with promotions if you have given your consent.
You can unsubscribe at any time via the "Unsubscribe" link or by contacting us.

We do not send unwanted advertisements.

12. MINORS

Our Services are not intended for individuals under 18 years of age.
We do not knowingly collect data from children.
If your child has sent data, please contact us to have it deleted.

13. POLICY CHANGES

We may update the Privacy Policy from time to time.
The current version is always available on our website with the effective date indicated.

14. CONTACTS

If you have any questions about the Privacy Policy or data processing:

📧 velnagap@gmail.com

🏢 Valvit OÜ (Prime Sushi Take Away)
Ümera tn 11-124, Lasnamae district, 13816 Tallinn, Estonia