Privacy Policy

Effective Date: 01.April.2026
Last Updated: 01.April.2026

Promna OÜ (“Promna”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, and protect personal data when you visit our website, contact us, create an account, or use our platform.

1. Who We Are

Controller: Promna OÜ
Registered in: Estonia
Email: info@promna.com

2. Scope of This Privacy Policy

This Privacy Policy applies to personal data collected through:

• our website;

• any contact forms, email communications, or other messages sent to us;

• account registration and use of our platform;

• cookies and similar technologies, where applicable.

Our website may be visited by any users, including prospective buyers, prospective sellers, and other business visitors. Access to certain parts of the platform may be restricted to registered users approved by us.

3. What Personal Data We Collect

Depending on how you interact with us, we may collect:

Information you provide directly

• name;

• email address;

• phone number;

• company name;

• job title;

• account credentials;

• information you include in forms, inquiries, or other communications.

Information related to your use of the website or platform

• account registration details;

• profile information;

• preferences and settings;

• activity related to your use of the platform;

• communication history with us.

Technical information

• IP address;

• browser type and device information;

• operating system;

• website usage data;

• log data;

• cookie-related data;

• approximate location based on IP.

4. How We Use Personal Data

We use personal data to:

• operate, maintain, and improve our website and platform;

• create and manage user accounts;

• communicate with you about your inquiries, account, or use of our services;

• provide support and respond to requests;

• protect the security and integrity of our website and platform;

• monitor usage and improve user experience;

• maintain internal records and logs;

• comply with legal obligations;

• protect our legal rights and prevent misuse.

Under GDPR, personal data must be processed lawfully, fairly, and transparently, and only for specified purposes.

5. Legal Bases for Processing

We rely on one or more of the following legal bases:

• performance of a contract — where processing is necessary to provide services to you;

• legitimate interests — for operating, securing, improving, and administering our website and platform;

• consent — where required, for example for certain cookies or optional communications;

• legal obligation — where processing is necessary to comply with applicable law.

6. Cookies and Similar Technologies

We may use cookies and similar technologies to ensure the website functions properly, remember your preferences, analyze usage, and improve performance.

Some cookies may be strictly necessary for the operation of the website. Other cookies, such as analytics or marketing cookies, may require your consent depending on applicable law.

You can manage cookies through your browser settings and, where available, through our cookie banner or settings tool.

7. Sharing of Personal Data

We may share personal data with:

• hosting, cloud, email, analytics, CRM, and IT service providers;

• professional advisers, including legal, accounting, and audit advisers;

• regulators, courts, law enforcement, or public authorities, where required by law;

• actual or potential investors, acquirers, or successors in connection with a corporate transaction, subject to appropriate confidentiality measures.

We require service providers to process personal data only as necessary for the relevant services and subject to appropriate safeguards.

8. International Data Transfers

Some of our service providers may process personal data outside the European Economic Area.

Where this happens, we take appropriate steps to protect personal data, including reliance on adequacy decisions or appropriate contractual safeguards where required. Transfers outside the EEA require a valid transfer mechanism under EU data protection rules.

9. Data Retention

We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide services, maintain records, resolve disputes, enforce agreements, and comply with legal obligations.

When personal data is no longer needed, we delete it or anonymize it where reasonably possible.

10. Data Security

We use reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

However, no website, platform, or method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Your Rights

Subject to applicable law, you may have the right to:

• access your personal data;

• request correction of inaccurate data;

• request deletion of your data;

• request restriction of processing;

• object to certain processing;

• request data portability;

• withdraw consent where processing is based on consent;

• lodge a complaint with a supervisory authority.

These rights are part of the GDPR framework for individuals in the EU.

To exercise your rights, please contact us at: [PRIVACY EMAIL]

12. Complaints

If you believe your personal data has been handled unlawfully, you may lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).

We would appreciate the opportunity to address your concerns first.

13. Third-Party Links

Our website or platform may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties.

14. Children

Our website and platform are intended for business users and are not directed to children.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any updated version will be posted on this page with a revised “Last Updated” date.

16. Contact

If you have questions about this Privacy Policy or our processing of personal data, please contact us at:

Promna OÜ, Estonia, info@promna.com