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Privacy Policy – massage services

Privacy Policy – Massage Services

1. General

This privacy policy explains how we process your personal data when you book or use the services of our massage salon via massage.focusestonia.ee or in person. It supplements the website's general privacy policy (https://massage.focusestonia.ee/privacy-policy/) and applies to the processing of data related to our services. We process data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Estonian Personal Data Protection Act.

2. Data controller

Taastus & Teraapia Clinic OÜ, registry code 17448696, address Kadaka tee 42b, Mustamäe linnaosa, 12915 Tallinn, Harju maakond, email administraator@focusestonia.ee, phone +372 5880 8212.

3. What data we collect

  • Contact details: name, phone number, email address.
  • Booking details: selected service, time, therapist, your notes.
  • Payment and billing details: invoice data, fact and amount of payment (we do not store bank card details).
  • Health data (special category): contraindications, injuries, surgeries, pregnancy, allergies, chronic conditions, pain areas – only if you provide them so that we can deliver the service safely.
  • Communication: your emails, messages and feedback.
  • Technical data: IP address, device and browser data, cookies (see the website's general policy).

4. Purposes and legal bases

  • Receiving and confirming bookings and providing the service – performance of a contract (GDPR Art. 6(1)(b)).
  • Assessing safety and adapting the service based on health data – your explicit consent (Art. 9(2)(a)).
  • Invoicing and accounting – compliance with a legal obligation (Art. 6(1)(c)).
  • Handling complaints, defending legal claims, securing our systems – legitimate interests (Art. 6(1)(f)).
  • Newsletters and offers – your consent or cases permitted by applicable law; consent may be withdrawn at any time (Art. 6(1)(a)).

5. Health data

Providing health data is voluntary, but without it we may be unable to deliver the service safely and may decline to do so. We use it only to assess the suitability of massage and to adapt it. Access is limited to the therapist serving you and, where necessary, the manager. You may withdraw consent at any time; this does not affect the lawfulness of prior processing.

6. Retention

  • Booking and contact data: up to 12 months after your last visit.
  • Health questionnaire: up to 36 months after your last visit or until consent is withdrawn.
  • Accounting documents: 7 years (Estonian Accounting Act).
  • Marketing data: until consent is withdrawn.

After the retention period, data is deleted or anonymized.

7. Sharing of data

We share data only as necessary with trusted processors: booking-system and hosting providers, payment service providers, our accountant and IT service providers. Data may be disclosed to public authorities where required by law. We do not sell your data. If data is transferred outside the EU/EEA, we ensure safeguards required by the GDPR.

8. Security

We apply appropriate technical and organizational measures: restricted access, password protection, secure data transmission and staff confidentiality obligations.

9. Your rights

You have the right to access your data, request rectification or erasure, restrict processing, object to processing, request data portability and withdraw consent. Send requests to [email]; we will respond within 1 month. If you believe your rights have been violated, you may contact the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon: info@aki.ee, +372 627 4135, www.aki.ee).

10. Minors

We provide services to minors (under 18) only with the consent and presence of a legal representative (unless the salon's rules provide otherwise). Health data of a minor is processed with the consent of the legal representative.

11. Changes and contact

We may update this policy; the new version will be published on the website with its date. Questions: administraator@focusestonia.ee, phone +372 5880 8212.