Privacy Policy

1. Introduction
At Kaelase Manor, we treat your privacy with the same care and attention as every aspect of your stay.
This Privacy Policy explains how Tockumbeck OÜ collects, uses, and protects your personal data when you visit our website or submit a booking request.
We are committed to processing your data transparently, fairly, and in accordance with the General Data Protection Regulation (GDPR).

2. Data Controller
The data controller responsible for your personal data is:
Tockumbeck OÜ
Registry code: 11551648
Rüütli, Maidla küla, 78115 Märjamaa vald, Rapla maakond, Estonia
Email: niklas.pohjanvirta@kolumbus.fi

3. Personal Data We Collect
3.1 Data you provide directly
When submitting a booking request, we collect:

• Full name
• Email address
• Telephone number
• Arrival date
• Departure date
• Number of guests
• Special requests or additional information

3.2 Technical and usage data
When you visit our website, certain information may be collected automatically:

• IP address
• Browser type and version
• Device information
• Pages visited and interaction data

This data is used for security, analytics, and website functionality.

4. Purpose of Processing
We process your personal data for the following purposes:

• To receive and manage booking requests
• To communicate with you regarding availability and details of your stay
• To prepare and provide our services
• To improve our website and user experience
• To comply with legal and regulatory obligations

We do not use your data for automated decision-making or profiling.

5. Legal Basis for Processing
We rely on the following legal bases under GDPR:

• Consent (Art. 6(1)(a)) — when you submit a booking form
• Pre-contractual measures (Art. 6(1)(b)) — to respond to your request and prepare a booking
• Legal obligations (Art. 6(1)(c)) — where required (e.g., accounting, compliance)
• Legitimate interests (Art. 6(1)(f)) — for maintaining and improving our website and ensuring its security

6. Data Retention
We retain personal data only as long as necessary:

• Booking inquiries: up to 12–24 months after last interaction
• Confirmed bookings: as required for legal and accounting purposes (typically up to 7 years)

After this period, data is securely deleted or anonymised.

7. Data Sharing and Processors
We do not sell, rent, or disclose your personal data for commercial purposes.
We may share data with carefully selected service providers, including:

• Website hosting providers
• Email and communication services
• IT and security providers

All processors are contractually bound to process data in compliance with GDPR.

8. International Data Transfers
Some of our service providers may be located outside the European Economic Area (EEA).
In such cases, we ensure appropriate safeguards, such as:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by the European Commission

9. Your Rights
You have the following rights under GDPR:

• Right of access
• Right to rectification
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to object to processing
• Right to data portability
• Right to withdraw consent at any time

To exercise your rights, contact us at:
niklas.pohjanvirta@kolumbus.fi
You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or your local supervisory authority.

10. Data Security
We implement appropriate technical and organizational measures to protect your data, including:

• Secure hosting environments
• Access control and authentication
• Data minimization principles

Despite these measures, no system can be completely secure, and we encourage users to exercise caution when sharing information online.

11. Cookies and Tracking Technologies
Our website may use cookies and similar technologies to:

• Ensure proper website functionality
• Improve user experience
• Analyze website performance

Where required, you will be asked to provide consent via a cookie banner.
You can manage your preferences through your browser settings.

12. Third-Party Links
Our website may contain links to third-party websites.
We are not responsible for the privacy practices of such external websites.

13. Changes to This Policy
We may update this Privacy Policy from time to time.
Any changes will be published on this page with an updated effective date.

14. Contact
For any questions regarding this Privacy Policy or your personal data:
Tockumbeck OÜ
Email: niklas.pohjanvirta@kolumbus.fi

Cookie Policy

1. Introduction
At Kaelase Manor, we use cookies in a minimal and respectful way, solely to ensure that our website functions properly.
This Cookie Policy explains what cookies are, how we use them, and what options you have regarding their use.

2. What Are Cookies
Cookies are small text files stored on your device when you visit a website.
They help websites operate efficiently and provide basic functionality such as remembering your session or enabling form submissions.

3. How We Use Cookies
We use only strictly necessary cookies, which are essential for the operation of our website.
These cookies enable:

• Proper functioning of the booking form
• Basic website security
• Session management and stability

We do not use cookies for analytics, advertising, or tracking purposes.

4. Legal Basis
Our use of cookies is based on:

• The ePrivacy Directive (Cookie Law)
• The General Data Protection Regulation (GDPR)

Strictly necessary cookies do not require prior user consent.

5. Third-Party Cookies
We do not use third-party cookies for tracking or marketing purposes.
Some technical service providers (such as hosting infrastructure) may process limited data strictly necessary for website functionality.

6. Managing Cookies
Most web browsers allow you to control cookies through their settings.
You can choose to block or delete cookies at any time.
Please note that doing so may affect the functionality of the website.

7. Data Retention
Cookies used on this website are:

• Session-based (deleted when you close your browser), or
• Stored for a limited period necessary for functionality

8. Updates to This Policy
We may update this Cookie Policy from time to time to reflect changes in legal requirements or website functionality.
The latest version will always be available on this page.

9. Contact
If you have any questions about our use of cookies, please contact:
Tockumbeck OÜ
Email: niklas.pohjanvirta@kolumbus.fi