Privacy policy
At ELQ Investments, our mission is to strengthen Ukraine’s energy security, sovereignty, and resilience through the rapid restoration and modernization of its energy infrastructure.
Privacy Policy of ELQ Investments OÜ
Definitions
The terms used in this Policy have the following meanings:
Administrator – ELQ Investments OÜ, Tallinn, Kesklinna linnaosa, Narva mnt 13-27, 10151;
Personal Data – any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name and surname, identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;
Policy – this privacy policy;
PUODO – the President of the Personal Data Protection Office (Poland);
GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
Website – the website available at the domain: https://elqinvestments.com;
User – a natural person using the Website.
Administrator
The administrator of personal data is ELQ Investments OÜ, Tallinn, Kesklinna linnaosa, Narva mnt 13-27, 10151 (hereinafter also referred to as “ELQ Investments OÜ”).
Address:
ELQ Investments OÜ
Tallinn, Kesklinna linnaosa
Narva mnt 13-27
10151 Estonia
For matters concerning the processing of Personal Data, you may contact us by email at info@elqinvestments.com or by traditional mail at the above correspondence address.
III. Security of Personal Data
ELQ Investments OÜ ensures the security and confidentiality of the processing of personal data and enables data subjects to exercise their rights, including access to information on processing.
ELQ Investments OÜ processes data using appropriate technical and organizational measures necessary to ensure the security of such data. Personal data are processed exclusively by persons authorized by ELQ Investments OÜ or by processors cooperating with ELQ Investments OÜ.
ELQ Investments OÜ processes only the Personal Data necessary for the proper functioning and performance of tasks related to its business activity, fulfilling obligations under the law, while respecting the principles of:
lawfulness, fairness, and transparency,
purpose limitation,
data minimization,
accuracy,
storage limitation,
integrity and confidentiality, and
accountability.
At the time of collecting Personal Data, ELQ Investments OÜ provides information about the processing of personal data, in particular the purpose and legal basis of processing, unless the law provides otherwise.
Bases and Purposes of Personal Data Processing on the Website
(including contact via contact forms, telephone, and use of the Website, as well as visits to ELQ Investments OÜ’s profiles on social media platforms)
The Administrator processes personal data:
to provide services by electronic means, making Website content available to Users and ensuring proper Website functionality (including the use of necessary cookies) – legal basis: necessity of processing for the performance of a contract – Art. 6(1)(b) GDPR;
to handle inquiries and correspondence – legal basis: legitimate interest of the Administrator, consisting of responding to inquiries addressed to the Administrator and maintaining necessary contact – Art. 6(1)(f) GDPR;
for analytical and statistical purposes, to improve the Website and adapt its content to Users’ preferences – legal basis: legitimate interest of the Administrator, consisting of developing the Website, its functionalities, and adjusting Website content to Users’ preferences – Art. 6(1)(f) GDPR;
for advertising purposes, including promoting the ELQ brand and providing information on ELQ Investments OÜ’s current offers (including marketing information tailored to Users’ interests via advertising cookies) – legal basis: legitimate interest of the Administrator – Art. 6(1)(f) GDPR;
to ensure security and pursue claims – legal basis: legitimate interest of the Administrator, consisting of ensuring the security of Website Users and pursuing ELQ Investments OÜ’s rights – Art. 6(1)(f) GDPR;
to send commercial information to newsletter subscribers – legal basis: consent of the User;
to manage social media profiles (Facebook, Instagram, LinkedIn), including informing Users about ELQ Investments OÜ’s activities and promoting events, services, and products – legal basis: legitimate interest of the Administrator (Art. 6(1)(f) GDPR), consisting of brand promotion.
Detailed information on the purposes and scope of personal data processing by social media platforms can be found at the following links:
Facebook: https://www.facebook.com/policy.php
Instagram: https://help.instagram.com/519522125107875
Bases and Purposes of Personal Data Processing in Business Relations with Clients and Contractors
The Administrator processes Personal Data in business relations with clients and contractors in connection with the provision of services for clients or by contractors, ongoing contact with persons acting on behalf of a client or contractor, and establishing business relationships with potential clients or contractors.
Personal Data are processed for the following purposes:
to establish business cooperation, present offers, and conclude and perform contracts related to ELQ Investments OÜ’s business activity – Art. 6(1)(b) GDPR;
to fulfill ELQ Investments OÜ’s legal obligations (Art. 6(1)(c) GDPR), including tax obligations, bookkeeping, and retention of accounting records;
to pursue legitimate interests of ELQ Investments OÜ (Art. 6(1)(f) GDPR), including responding to letters and requests, establishing, exercising, or defending claims, contacting persons designated as contact persons or responsible for contract performance, and handling ongoing matters.
Appropriate information clauses regarding Personal Data processing are provided during or after the conclusion of a contract between ELQ Investments OÜ and its client or contractor.
Bases and Purposes of Personal Data Processing in Recruitment
Information on how ELQ Investments OÜ processes Personal Data in connection with recruitment processes or unsolicited applications will be provided during correspondence with ELQ Investments OÜ.
VII. Data Retention Period
The period of data processing depends on the purpose of processing. Personal Data are processed:
for the time necessary to perform a contract, and after its termination – for the time required to establish, exercise, or defend claims or as required by law, whichever is longer;
for the duration of service provision, and after termination – for the time required to establish, exercise, or defend claims or as required by law, whichever is longer;
until the end of the recruitment process or until consent is withdrawn;
until consent is withdrawn, where the basis for processing is consent;
until a valid objection is lodged, where the legal basis for processing is the Administrator’s legitimate interest.
After the main purpose ceases, Personal Data may be stored if processing is necessary to establish or pursue claims or defend against claims. After the retention period expires, Personal Data are deleted.
VIII. Recipients of Personal Data and Transfers Outside the EEA
Personal Data may be transferred to appropriate recipients, including external entities such as IT and hardware service providers, providers of analytical and marketing tools, accounting entities, legal advisors, couriers, and processors under data processing agreements.
The level of Personal Data protection outside the European Economic Area (EEA) may differ significantly from European standards. Therefore, the Administrator transfers Personal Data outside the EEA only when necessary and while ensuring an appropriate level of protection, in particular by:
cooperating with processors located in countries subject to an adequacy decision by the European Commission;
using standard contractual clauses issued by the European Commission;
applying binding corporate rules approved by a competent supervisory authority.
The Administrator informs about transfers of Personal Data outside the EEA at the stage of data collection.
Rights of Data Subjects
Every person whose Personal Data are processed by the Administrator has the following rights:
the right of access to data, including one free copy of the data;
the right to rectify personal data;
the right to restrict processing of personal data;
the right to request deletion of personal data;
the right to data portability, where data are processed based on consent or for the performance of a contract and processing is carried out by automated means;
the right to withdraw consent at any time (without affecting the lawfulness of processing carried out prior to withdrawal);
the right to object to processing, where processing is based on the Administrator’s legitimate interest;
the right to lodge a complaint with the President of the Personal Data Protection Office.
Cookies
Cookies collect information that facilitates the use of the Website. ELQ Investments OÜ uses both its own cookies (installed directly by the Website) and third-party cookies (from domains other than the Website’s domain).
The Website uses cookies in particular to:
ensure proper operation of the Website,
remember User preferences,
analyze and track Website traffic and tailor advertising content to Users’ interests (subject to User consent).
Users can choose between three privacy levels:
Basic – the highest level of privacy. Data are used only for essential operations and shared with third parties solely for ensuring security and Website operation on your device.
Balanced – a balanced level of privacy. Data are used to personalize content and optimize the Website. Data may be shared with third parties for tracking and storing preferences related to this Website.
Advanced – the highest level of personalization. Data are used to increase the relevance of advertising and media. Data may be shared with third parties to track you across this and other websites.
Types of cookies used:
Essential cookies – collect necessary data for secure operation of the Website (e.g., login sessions, privacy settings).
Functional and analytical cookies – collect User preference data, enabling profile creation and behavior monitoring. Used for personalized content and service improvements. Consent is required.
Advertising cookies – collect data to tailor advertising content to User interests and may be shared with ELQ Investments OÜ’s advertising partners to create cross-site User profiles. Consent is required.
More information can be found via the Website’s footer under the “adjust” option.
If you consider cookies an invasion of privacy, you may disable them at any time in your browser settings. Instructions are available from your browser’s provider. Remaining on the Website without disabling cookies constitutes consent to their use.
Further details are available in the “Help” section of your browser or at http://wszystkoociasteczkach.pl.
Analytical and Marketing Tools Used by ELQ Investments OÜ Partners/Providers
Google Tag Manager
A tool enabling management of scripts on the Website without editing source code. It allows installing scripts related to User consents, analytics (e.g., Google Analytics), and advertising conversions (e.g., Google Ads). Google collects aggregated data on script usage without identifying Users.
More information: https://www.google.com/analytics/terms/tag-manager/
Google Ads
A tool for measuring the effectiveness of advertising campaigns run by the Administrator, analyzing data such as keywords or unique User counts, and displaying ads to Users who previously visited the Website.
More information: https://ads.google.com/
Final Provisions
ELQ Investments OÜ regularly reviews this Policy and updates it when necessary.
Before launching the newsletter, ELQ Investments OÜ will prepare the required consent text, include references to the Policy, and provide information at the end of each newsletter email, including the option to unsubscribe.