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Privacy Policy

Effective from: 01.11.2025

INTRODUCTION

The following privacy policy (“Privacy Policy”) addresses the practices of Porrulans OÜ regarding the collection, processing, and sharing of personal data. It explains how and for what purposes we collect, use, and share personal data when you visit our websites https://katiorav.com/ and https://imperfectlinemovement.com/ (“Websites”), consume our other products and services (e.g., courses, books, free materials, newsletters), or contact us.

This Privacy Policy is based on the General Data Protection Regulation (GDPR), and its purpose is to protect the privacy of our customers in accordance with the laws of the Republic of Estonia and the legislation of the European Union.

Personal Data is any information about an identified or identifiable natural person (e.g., name, e-mail address, location) and information about visiting our websites and using our services.

By using our Websites, you agree to the use of cookies and the processing of personal data as described in this Privacy Policy.

1. Who is the Data Controller?

The controller of personal data is Porrulans OÜ.

For questions regarding the processing of your personal data, please contact us at kati@kating.ee.

We process the data of our customers and contacts who have expressed a wish to consume our services or products (e.g., subscribed to the newsletter, purchased a book or course, downloaded the “Starter Kit”) or have used our services in the past.

2. Purposes and Legal Bases for Processing Personal Data

We process the personal data of customers and users to fulfill our contractual obligations (e.g., when selling a product, conducting a course) and to provide potential customers with quality service and information. For these purposes, the legal basis for processing is our legitimate interest to ensure the correct and high-quality provision of our services or the performance of a contract.

We collect data from our Websites about their use and the interests of potential customers to better understand the actual interests of our customers, provide higher-quality information, and improve the functionality of the websites. In this case, the legal basis for processing is our legitimate interest to better understand customer needs.

When you subscribe to our newsletter (e.g., “Imperfect Line Movement Insider”) or download free materials (e.g., the “Starter Kit”), the legal basis for processing is your consent.

The main purposes of processing are:

  • Creating and managing the customer base;
  • Providing services to the customer (e.g., course access, sending a physical book);
  • Sending newsletters and marketing information (with your consent);
  • Analyzing and improving the services of Porrulans OÜ;
  • Managing and analyzing the Websites;
  • Complying with legal requirements (e.g., accounting laws);
  • Responding to customer inquiries and emails.

3. How We Collect Data

As a rule, we collect personal data directly from you (the data subject) and with your consent. This happens, for example, when you enter your data to subscribe to a newsletter, purchase a product, register for a course, or contact us via email.

Additionally, we use automatic data collection tools, including cookies and other tracking tools, to optimize the user experience of our Websites.

4. What Personal Data Do We Process?

Porrulans OÜ may process the following personal data:

  • Contact details: name, e-mail address, phone number, postal address (for invoicing or sending physical products), and information on the nearest parcel locker.
  • Contract performance data: purchase history, order details, billing information, feedback, responses to course-related surveys.
  • Automatically collected data: data received from the user’s web browser (including browser type, device type, communication language), the website address from which the user arrived, visited content pages, user’s IP address, and other traffic data.
  • Marketing data: user actions related to our emails (e.g., email opens and clicks).
  • Other information: other personal data that you have made publicly available (e.g., in social media comments) or provided to us.

5. Sharing and Transfer of Personal Data

Porrulans OÜ does not share the customer’s personal data with third parties, except under the conditions listed below.

We use partners (authorized processors) to manage our Websites and provide services. These are service providers who assist us, for example, with list and customer data management (e.g., newsletter software), email delivery, data hosting, payment processing, web analytics, and marketing management (e.g., Google, Facebook).

We ensure that these service providers access personal data only for the purposes designated by us, confidentially, and in accordance with GDPR rules. If data is transferred outside the European Economic Area (e.g., to the USA), we ensure that appropriate safeguards (e.g., Standard Contractual Clauses) are applied.

Additionally, we may share your personal data in the following cases:

  • For debt collection (e.g., collection agencies).
  • Upon a lawful request from public authorities and the police.
  • As public feedback (only with your explicit consent).

6. Data Security and Retention

Security: The secure storage of personal data is our priority. We implement reasonable and sufficient organizational, technical, and physical measures to prevent unauthorized access, disclosure, and other unlawful processing.

Retention Period: Porrulans OÜ retains personal data only for as long as it is necessary to achieve the purpose of its collection (e.g., contract fulfillment, sending a newsletter) or as required by law (e.g., accounting act). When we no longer have an ongoing legal or business need to process your data, we will either delete it or anonymize it.

7. Cookies and Tracking Technologies

A cookie is a small text file that a web server sends to the user’s web browser and which is stored on the user’s computer’s hard drive. We use cookies to simplify the use of the site and provide a better experience.

Porrulans OÜ uses:

  • Analytical cookies: Collect information about how the Website is used (e.g., which pages are visited). They do not directly identify the user. This includes, for example, Google Analytics cookies.
  • Advertising cookies: Help to provide advertisements targeted to the user’s interests (e.g., on Facebook and Google).
  • Third-party cookies: Our pages may contain content from third parties, e.g., YouTube and Google Maps, which may set their own cookies.

The user has the right to refuse the storage of cookies on their computer. To do so, the user must change their web browser settings. Blocking cookies may result in some website functions no longer being available.

Instructions for configuring web browsers:

8. Your Rights (Data Subject Rights)

You have the right at any time to access your personal data processed by Porrulans OÜ and to request the correction of inaccurate data.

You have the following rights under the GDPR:

  • Right to rectification: The right to demand that incorrect personal data related to you be corrected.
  • Right to erasure (“right to be forgotten”): The right to demand that your personal data be deleted if certain additional conditions are met (e.g., we no longer have a legal basis to process it).
  • Right to restriction of processing: In certain cases, you have the right to restrict the processing of your personal data.
  • Right to data portability: The right to receive the personal data you have provided to us and to transfer this data to another controller.
  • Right to object: The right to object to the processing of your personal data that is based on our legitimate interest.
  • Right to withdraw consent: If the processing is based on your consent (e.g., sending a newsletter), you have the right to withdraw that consent at any time.

Opting out of marketing: All recipients of our newsletter have the right to opt out of further communication at any time. This can be done by clicking the “Unsubscribe” link at the bottom of every email.

If you wish to exercise these rights or have questions, please contact us at kati@kating.ee.

If you find that our proposed solution does not satisfy you, you have the right to appeal to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee) and the courts.

9. Other Provisions

Porrulans OÜ reserves the right to change these privacy terms unilaterally. The latest version is always available on our Websites.

The laws of the Republic of Estonia govern these privacy terms. Disputes or claims arising from the policy will be resolved in the Tartu  County Court in Tartu.