PRIVACY POLICY
Last updated: 08/04/2026

At Touchary OÜ, we are committed to protecting your privacy and handling your personal data with transparency, care, and integrity.

This Privacy Policy explains how we collect, use, and protect your personal data when you visit or make a purchase from our website.

1. DATA CONTROLLER

The data controller responsible for your personal data is:

Touchary OÜ
Registered in Estonia
Harju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 15551
Email: [email protected]

2. PERSONAL DATA WE COLLECT

We may collect and process the following types of personal data:

Information you provide directly:

• Full name
• Email address
• Billing and shipping address
• Phone number
• Order details

Payment-related information:

Payments are processed securely by third-party providers. We do not store full payment details.

Automatically collected data:

• IP address
• Device and browser information
• Website usage data (pages visited, interactions)
• Cookies and tracking technologies

3. HOW WE USE YOUR DATA

We use your personal data to:

• Process and deliver your orders
• Provide customer support
• Communicate with you regarding your purchases
• Manage returns, refunds, and complaints
• Improve our website and services
• Prevent fraud and ensure security
• Send marketing communications (only with your consent)

4. LEGAL BASIS (GDPR)

We process your data based on:

• Contract performance (to fulfill your order)
• Legal obligations (e.g. tax and accounting requirements)
• Legitimate interests (website improvement, fraud prevention, security)
• Consent (for marketing and non-essential cookies)

5. DATA SHARING

We may share your personal data with trusted third parties, including:

• Payment providers (e.g. Stripe, PayPal or similar)
• Shipping and logistics partners
• Website hosting providers
• Analytics providers (e.g. Google Analytics)
• Marketing platforms (e.g. Meta / Facebook Pixel)

All third parties are required to process your data securely and in accordance with applicable data protection laws.

We do not sell your personal data.

6. INTERNATIONAL DATA TRANSFERS

Your data may be transferred outside the European Economic Area (EEA) via trusted service providers.

Where this occurs, we ensure appropriate safeguards are in place in accordance with GDPR, including the use of Standard Contractual Clauses (SCCs) or equivalent legal mechanisms.

7. DATA RETENTION

We retain your personal data only for as long as necessary:

• Order and transaction data → for legal and tax obligations
• Customer communication → for support and dispute resolution
• Marketing data → until you withdraw your consent

8. YOUR RIGHTS (GDPR)

You have the right to:

• Access your personal data
• Request correction
• Request deletion (“right to be forgotten”)
• Restrict processing
• Object to processing
• Withdraw consent at any time
• Request data portability

To exercise your rights, contact us at: [email protected]

You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate.

9. COOKIES & TRACKING

We use cookies and similar technologies to:

• Ensure website functionality
• Analyze performance
• Improve user experience
• Deliver personalized advertising

Non-essential cookies are only used with your consent.

For more details, please refer to our Cookie Policy.

10. EMAIL MARKETING

If you subscribe to our newsletter, we may send you updates, promotions, and brand news.

You can unsubscribe at any time by clicking the unsubscribe link in our emails.

11. AUTOMATED DECISION-MAKING

We do not use your personal data for automated decision-making or profiling that produces legal or significant effects.

12. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal data, including:

• SSL encryption
• Secure payment processing
• Restricted data access

13. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Updated versions will be published on this page.

14. CONTACT

For any questions regarding this Privacy Policy, please contact:
[email protected]

This Privacy Policy should be read together with our Terms & Conditions, Cookie Policy, and Return & Refund Policy, which together form the complete legal framework governing your use of our website.

Touchary — designed to be worn, kept, and remembered.