DRAFT: needs a lawyer's review before real customer data is used
Privacy notice (draft)
Hõbekase Saalid
1. Who processes your data
The venue "Hõbekase Saalid" has not yet entered its company details (legal name, registry code, address), so we cannot show them here. The controller of your request and booking data is that venue. For questions and requests about your rights, write to the venue: demo-owner@hobekase.invalid.
The booking system Saalo is provided to the venue by [Codename OÜ legal name - owner to confirm] (registry code [Codename OÜ registry code - owner to supply], [Codename OÜ address - owner to supply], [Codename OÜ contact email - owner to supply]), which processes this data as the venue's processor, on the venue's instructions.
2. What data is processed and where it comes from
- Request and booking: name, email, phone, company and registry code, event time, number of guests, messages and notes. The venue gets them from you or your company.
- Quote and billing: quote contents, amounts, payment status, invoices.
- Quote acceptance (if the venue has published terms): name, email, time, IP address and browser data, the version of the terms accepted.
- Attendees: name, email, reply, dietary requests. The venue gets them from the event organiser or from you through the invitation link.
- Gift voucher: buyer's name and email, recipient's name and greeting. The venue gets the recipient's details from the buyer.
- Waitlist (with your consent), room viewings and feedback (rating, comment).
- SMS messages: phone number, if the venue uses its own SMS provider.
- Request source: where you came from (utm parameters, referring page address).
- Newsletter: name and email, only with your consent.
3. Purposes and legal bases
| Purpose | Legal basis (GDPR Art. 6(1)) |
|---|---|
| Answering your request, quoting, performing the booking, where you are the contracting party | (b) contract or pre-contract steps |
| The same, where you are a company contact or event attendee | (f) the venue's interest in performing the contract with your company or the organiser |
| Booking reminders and organisational messages | (b); otherwise (f): the event has to run smoothly |
| Proving a quote acceptance (time, IP, browser) | (f) the venue's interest in proving that the contract was made |
| Asking for feedback after the event | (f) improving the service |
| Waitlist | (a) consent |
| Statistics on the request source | (f) the venue's interest in knowing where requests come from |
| Accounting and tax law duties | (c) |
| Security of the system and preventing abuse | (f) protecting the data and the service |
| Newsletter | (a); you can withdraw consent at any time |
The venue may set certain bookings to be confirmed automatically under its own rules, with no staff involvement. In that case you have the right to contact the venue's staff, state your view and contest the decision.
Sensitive data. Dietary and allergy information can reveal your health. Please do not write health data the venue does not need into free-text fields. If an event organiser fills in details for you, they must have agreed that with you.
4. Who receives the data
Saalo's service providers (sub-processors):
- Hetzner Online GmbH, Germany: hosting and database.
- Resend: sending and receiving email.
- Anthropic: AI assistant, only if the venue uses it (see below).
Services the venue has connected itself (only if the venue uses them): Montonio (payments); Mailchimp (newsletter, only with your consent); the venue's SMS provider; Google Calendar and Microsoft Outlook (booking time, room, number of guests and a title or name in the venue's calendar); Slack and Microsoft Teams (a booking notice to the venue's staff with your name); accounting and e-invoicing software (invoice recipient details); the venue's own integrations. The venue can tell you which of these it uses.
AI assistant. If the venue uses the assistant, Anthropic may receive the free text of your message, request or change request (up to 6,000 characters), the subject and body of a request sent by email, event details (time, rooms, number of guests, extras, menus and dietary totals) and staff notes. Your name, email, phone and company fields are not sent separately. Before sending, email addresses and phone numbers in free text are replaced, but the email subject, event title and free text may still contain names and other personal data, so do not write sensitive data there. The assistant does not set prices or confirm bookings.
We do not sell data.
5. Transfers outside the European Economic Area
Resend (USA) and Anthropic (USA) process data mainly in the USA. Mailchimp (USA) receives data only if the venue uses the newsletter and you consented. The transfer safeguards (standard contractual clauses or an adequacy decision) are still to be confirmed by a lawyer; ask the venue about the safeguards.
6. Retention
- A customer's name and contact details are anonymised 36 months after the end of their last booking if there are no future bookings. The venue can change this period in its settings. The original text of requests and the contents of sent emails and SMS are cleared after the same number of months from when they were created.
- Some free-text fields (for example a booking title and notes) may remain; ask the venue to delete them.
- Accounting source documents (invoices) are kept for the 7 years the law requires.
- Sign-in links are deleted 7 days after use or expiry.
7. Your rights
You have the right to know what data about you is processed, to get a copy, to have it corrected or erased, to restrict its processing and to receive the data you provided in a machine-readable form. Where the venue relies on consent, you can withdraw it at any time; this does not affect earlier processing.
Right to object. Where the venue processes data on the basis of a legitimate interest, you can object at any time on grounds relating to your situation. You can always object to direct marketing.
Send your request to the venue (contact at the top of this page). If you write to Saalo, Saalo passes it on to the venue. The venue replies within one month; for a complex request this may be extended by two months, and the venue will tell you. Accounting documents cannot be deleted before the legal deadline.
You can lodge a complaint with the Estonian Data Protection Inspectorate (www.aki.ee) or the supervisory authority of your country of residence.