GOLDMANSONS PRIVACY POLICY
These Personal Data Processing Terms (hereinafter Terms) describe the procedures by which SilverBridge OÜ processes Personal Data. These Terms apply when the Customer uses, has used, or intends to use SilverBridge OÜ services, or is otherwise connected to the services provided by SilverBridge OÜ, including relationships with the Customer established before these Terms came into effect. If you wish to exercise your rights as a data subject, please contact SilverBridge OÜ as described in Section 10 of these Terms.
Definitions
Customer: any natural or legal person who uses, has used, or has expressed a wish to use the services offered by SilverBridge OÜ. A Customer may also be a person otherwise connected to the use of services, as well as a person who has any relationship with SilverBridge OÜ that arose before these Terms came into effect.
Personal Data: any information that can be used to directly or indirectly identify the Customer.
Processing of Personal Data: any action or set of actions performed on Personal Data, including collection, recording, registration, storage, modification, organisation, granting of access, transmission, use, anonymisation, and deletion. Actions may or may not be performed by automated means.
Data Controller: SilverBridge OÜ (registry code 16221673), located at J. Vilmsi tn 47, Tallinn (hereinafter also referred to as SilverBridge).
Data Processor: any person who processes Personal Data on behalf of the Data Controller.
Recipient: any person, including public authorities or other bodies, to whom SilverBridge OÜ is entitled to disclose Personal Data. The categories of recipients are listed in these Terms.
EU / EEA: European Union / European Economic Area.
Services: all services, including consultations and product sales, provided by SilverBridge OÜ to the Customer through its website www.goldmansons.ee, by telephone, email, or other channels.
Legislation: legislation applicable to SilverBridge OÜ, relating primarily to anti-money laundering, economic activity, data protection, taxation, accounting, payment services, trade secrets, and financial activities.
General Provisions
2.1. These Terms describe how SilverBridge OÜ processes Personal Data. In addition to these Terms, information related to the processing of Personal Data may be described in contracts concluded with cooperation partners, other service-related documents, and on the SilverBridge OÜ website www.goldmansons.ee.
2.2. In accordance with applicable legislation, SilverBridge OÜ ensures the confidentiality of Personal Data during processing and implements appropriate technical and organisational measures to protect Personal Data against unauthorised access, unlawful processing or disclosure, accidental loss, modification, or destruction. SilverBridge OÜ processes Personal Data only on the legal bases specified by law.
2.3. SilverBridge OÜ has the right to engage third parties (Data Processors) in the processing of Personal Data. In such cases, SilverBridge OÜ takes all necessary measures to ensure that such processors process Personal Data in accordance with SilverBridge OÜ’s instructions and applicable legislation, including the implementation of appropriate security measures.
Categories of Personal Data
| Category | Data |
|---|---|
| Identification and verification data | Name, personal identification code, identity document details (e.g. passport or ID card number, expiry date; copy of document) |
| Contact data | Address, telephone number, email address |
| Financial data | Information on completed transactions (e.g. bank account details, payment orders) |
| Customer relationship data | Data collected in application of “know your customer” principles. For example, information on the purpose of the customer relationship and whether the Customer or a related person is a politically exposed person |
| Business relationship data | Data provided by the Customer or obtained by SilverBridge OÜ from public databases on whether a person is a member of the governing body, beneficial owner, or founder of a legal entity |
| Communication data | Data obtained from or contained in messages sent by the Customer, email correspondence, or telephone communications |
| Residence and citizenship data | Information on country of residence, taxpayer status, citizenship, and country of birth |
| Service-related data | Performance or non-performance of concluded agreements, completed transactions, use of payment methods, concluded and rejected transactions, submitted applications, requests, and complaints |
| Delivery-related data | Photograph of identity document upon delivery, digital signature confirming receipt of goods by the authorised person |
Purposes and Legal Bases for Processing Personal Data
4.1 Performance of Transactions
The performance of transactions is one of the primary legal bases on which SilverBridge OÜ processes Customer Personal Data. Examples of processing purposes include:
- Performing actions necessary for carrying out transactions initiated by the Customer;
- Managing relationships with Customers and providing access to services and transactions;
- Verifying completed transactions and their details;
- Identifying and verifying the Customer’s identity and keeping Personal Data up to date.
4.2 Fulfilment of Legal Obligations
To fulfil legal obligations arising from legislation, SilverBridge OÜ is required to process Personal Data for purposes such as:
- Preventing, detecting, investigating, and reporting money laundering and terrorist financing;
- Identifying, investigating, or reporting potentially suspicious transactions;
- Fulfilling other obligations arising from legislation.
4.3 Legitimate Interest
In some cases, the purposes of processing Customer Personal Data are based on the legitimate interest of SilverBridge OÜ, which is consistent with the interests or fundamental rights and freedoms of the Customer as a data subject. Examples of processing purposes based on legitimate interest include:
- Offering additional services to the Customer and direct marketing activities through various channels;
- Preventing misuse or unlawful use of services;
- Enforcing legal claims and retaining information necessary for that purpose.
4.4 Consent
In certain cases, SilverBridge OÜ requests the Customer’s consent for the processing of Personal Data, and Personal Data is processed solely on the basis of the Customer’s consent. In such cases, the Customer is informed separately of the specific processing purpose. If the Customer provides their email address on their own initiative, for example to receive notifications, newsletters, and special offers from SilverBridge, the processing of Personal Data takes place on the basis of the Customer’s clearly expressed consent. The Customer may withdraw their consent at any time.
Cookies
SilverBridge OÜ uses cookies on its website. The cookies used and related information are specified in the cookie policy, available on the website www.goldmansons.ee.
Recipients of Personal Data
In the course of providing services, SilverBridge OÜ may transfer Customer Personal Data to recipients for the purpose of providing services to the Customer and fulfilling legal obligations. Such recipients are primarily:
- Institutions and officials (supervisory authorities, tax authorities, law enforcement agencies);
- Payment service providers;
- Legal advisors, auditors, or other service providers;
- Logistics service providers;
- IT service providers.
SilverBridge OÜ transfers Personal Data only to the extent necessary and not more than is required to achieve the purpose of processing. Recipients may process Personal Data as either data controllers or data processors. Where a recipient processes Customer Personal Data on its own responsibility, the recipient is responsible for providing information to data subjects about such processing. In such cases, SilverBridge recommends that the Customer contact the recipient directly for additional information on the processing of Personal Data. Where a recipient acts as a data processor, SilverBridge is responsible for providing information related to such processing.
Geographic Area of Processing
Customer Personal Data is processed within the EU/EEA. SilverBridge OÜ does not transfer personal data outside the EU/EEA.
Data Retention
The retention period for Personal Data depends on the purpose of data collection or the requirements set out in legislation. SilverBridge OÜ processes Personal Data as long as there is a business relationship with the Customer. After the business relationship ends, SilverBridge OÜ retains Personal Data in accordance with the retention periods set out in legislation. Where the processing of Personal Data is based on the Customer’s consent, Personal Data is retained as long as the consent is valid. Where Personal Data is processed on the basis of SilverBridge OÜ’s legitimate interests, such as the assertion, exercise, or defence of legal claims, other retention periods arising from legislation may apply. In all cases, SilverBridge OÜ limits the processing of Personal Data to the greatest extent possible.
Data Subject Rights
In accordance with data protection legislation, the Customer has data subject rights in connection with the processing of Personal Data by SilverBridge OÜ. The data subject (Customer) has the right to:
- Receive information about whether SilverBridge OÜ processes their Personal Data and, if so, to request access to such data;
- Request the correction of their Personal Data if it is inaccurate, incomplete, or incorrect;
- Request the deletion of their Personal Data where there is a legal basis for doing so;
- Restrict the processing of their Personal Data;
- Object to the processing of their Personal Data where processing is based on the legitimate interest of SilverBridge OÜ;
- Object to the processing of their Personal Data for direct marketing purposes;
- Withdraw consent for the processing of Personal Data.
SilverBridge processes most of the information provided by the Customer during transactions. Generally, the Customer provides data to SilverBridge personally, but in certain cases SilverBridge also processes Personal Data obtained from various databases.
Given the volume of information processed by SilverBridge, data subjects are asked to specify as precisely as possible the time period covered by the request, describe the processing activity, and provide any other relevant information when exercising their rights.
Customers may exercise their data subject rights by submitting a request in person at a SilverBridge office or by sending a digitally signed request to info@goldmansons.ee. A response to the data subject’s request is provided within one month of receiving the request. Depending on the volume or complexity of the request, SilverBridge may unilaterally extend this period by up to two months.
If the Customer believes that the processing of their Personal Data by SilverBridge violates their rights and/or interests under applicable legislation, the Customer may file a complaint with the Data Protection Inspectorate.
Contact Details
The Customer may contact SilverBridge OÜ at any time regarding questions about the use of Personal Data, withdrawal of consent, requests, exercise of data subject rights, and complaints by email at info@goldmansons.ee.
Validity and Amendment of Terms
SilverBridge OÜ may unilaterally amend these Terms at any time in accordance with applicable laws and regulations, notifying the Customer of the relevant changes on the SilverBridge OÜ website, by email, or by other means at least one month before the changes take effect.
The current version of these Terms takes effect on 1 January 2025, and the latest version is available on the SilverBridge website.
