Privacy Policy

This Privacy Policy explains how we collect, use and protect personal data when you visit DiscGolfEstonia.com, contact us, suggest an update to the course database or interact with analytics and advertising technologies used on the website.

The website is primarily informational. At the date of this Privacy Policy, DiscGolfEstonia.com does not offer user accounts, online payments or newsletter subscriptions.

This Privacy Policy should be read together with our Cookie Policy.

1. Who is responsible for your personal data?

The data controller responsible for DiscGolfEstonia.com is:

Laanekivi Invest OÜ
Registry code: 16699462
Laanekivi tee 7/1-6
Haabneeme alevik, Viimsi vald
Harju maakond 74001
Estonia

Email: info@discgolfestonia.com

Laanekivi Invest OÜ decides why and how personal data is processed through DiscGolfEstonia.com.

2. What personal data do we collect?

The personal data we process depends on how you use the website.

Contact form

When you contact us through the website, we may collect:

• your name
• your email address
• the subject or type of enquiry
• the content of your message
• any other information you choose to include

We use this information to review and respond to questions, requests for local information, partnership enquiries, media enquiries and similar messages.

Please do not include sensitive personal data or unnecessary personal information about other people in your message.

Suggest a Course Update form

When you suggest a correction or update to a course page, we may collect:

• the name of the course
• information that you believe needs updating
• the correction or change you suggest
• a source or supporting link
• your name if you choose to provide it
• your email address if you choose to provide it
• course information automatically carried over from the course page
• any other information you choose to include

Your name and email address are optional for course update submissions. They may be used to contact you if we need clarification or further information.

Submitted updates are reviewed manually before changes are made.

Factual information accepted as a course correction may be added to the public DiscGolfEstonia.com course database. Your name, email address, IP address or other submission metadata will not be published as part of the course information unless there is a separate lawful reason and appropriate notice for doing so.

Form submission metadata

Our website uses Fluent Forms for the Contact form and Suggest a Course Update form.

When a form is submitted, Fluent Forms stores the submission in the website’s WordPress database. A copy is also sent to our email address.

Submission records may include technical information associated with the submission, including:

• IP address
• browser information
• device information
• the page from which the form was submitted
• submission date and time

We use this information where reasonably necessary to manage submissions, identify technical problems, prevent misuse and protect the website.

Technical and server data

DiscGolfEstonia.com is hosted by Zone Media OÜ.

When you visit the website, the hosting infrastructure automatically processes technical information needed to deliver and secure the website. Web server logs may contain information such as:

• IP address
• date and time of the request
• requested page or file
• browser or user-agent information
• referring page
• technical response information
• errors and security-related information

This information is used to operate the website, investigate technical problems, prevent abuse and protect the website and its visitors.

Analytics and advertising technologies

With your consent, DiscGolfEstonia.com uses or intends to use:

• Google Analytics
• Google Ads measurement technologies
• Meta Pixel

These technologies may process information such as:

• online and cookie identifiers
• IP and approximate location information
• browser and device information
• pages visited
• interactions with the website
• referring websites
• advertising campaign information
• information about whether particular website actions took place

We use Google Analytics to understand how visitors use the website and improve its content and usability.

Google Ads and Meta Pixel may be used to measure advertising performance and support advertising-related functionality.

These non-essential technologies are not intended to be activated for visitors who have not provided the required consent.

Google Search Console is also used to understand how DiscGolfEstonia.com appears in Google Search. Search Console does not itself require us to place tracking cookies on visitors’ devices merely because they visit the website.

3. Course information and public sources

Most information in the DiscGolfEstonia.com course database concerns disc golf courses, facilities, locations, layouts and organisations. This information is generally factual and does not identify individual people.

Course information may be researched from sources including:

• official course operators and course websites
• disc golf clubs and organisations
• Discgolfirajad.ee
• Disc Golf Metrix
• UDisc
• Eesti Discgolfi Liit
• municipality and tourism websites
• other publicly available sources
• local player knowledge
• information submitted directly to us

Where appropriate, DiscGolfEstonia.com links visitors to original and official sources.

In limited situations, course information may contain the name or professional contact information of a person acting on behalf of a course, club or organisation.

We prefer organisational contact information wherever reasonably possible.

We do not normally republish private personal email addresses or private personal telephone numbers collected from third-party websites simply because they are publicly visible.

Where limited personal information about an official or professional contact is used, we only use information that is relevant to their public or organisational role and reasonably necessary for providing useful course information.

If personal data is obtained from a publicly available source rather than directly from the individual, the source may include an official course website, club or organisation website, public authority website or established disc golf platform.

Where the GDPR requires us to provide information directly to a person whose personal data we have obtained from another source, we will do so in accordance with the applicable requirements.

If you are identified in a course listing and would like your information corrected or removed, contact info@discgolfestonia.com.

4. Why do we process personal data?

We process personal data only where there is an appropriate legal basis under the General Data Protection Regulation.

Responding to enquiries

We normally process Contact form information on the basis of our legitimate interests under Article 6(1)(f) of the GDPR.

Our legitimate interest is to communicate with visitors, answer enquiries and manage correspondence relating to DiscGolfEstonia.com.

If you ask us to take specific steps before entering into a contract with you as an individual, processing may instead be necessary under Article 6(1)(b) of the GDPR.

Reviewing course updates

We process course update submissions on the basis of our legitimate interests under Article 6(1)(f) of the GDPR.

Our legitimate interest is to maintain an accurate and useful course database, review submitted corrections and contact submitters where clarification is necessary.

Limited professional contact information

Where limited personal information concerning a person acting publicly or professionally for a course, club or organisation is necessary for the course directory, we may process it on the basis of our legitimate interests under Article 6(1)(f) of the GDPR.

Our legitimate interest is to provide accurate and useful information that helps visitors identify or contact the appropriate course operator or organisation.

We take into account the nature of the information, the individual’s reasonable expectations and their privacy rights before relying on this basis.

Operating and securing the website

Technical information, server logs and relevant submission metadata may be processed on the basis of our legitimate interests under Article 6(1)(f) of the GDPR.

Our interests include maintaining a reliable website, detecting technical problems, preventing spam and misuse and protecting the website and its visitors.

Analytics and advertising

Where consent is required, Google Analytics, Google Ads measurement technologies and Meta Pixel are used on the basis of your consent under Article 6(1)(a) of the GDPR.

Non-essential cookies, tracking pixels or similar technologies that require consent are not activated before the appropriate consent has been provided.

You can withdraw or change your consent at any time through the website’s cookie settings.

Withdrawal of consent does not affect the lawfulness of processing that took place before consent was withdrawn.

Legal obligations and legal claims

We may process personal data where necessary to comply with a legal obligation under Article 6(1)(c) of the GDPR.

We may also retain or use limited information where reasonably necessary to establish, exercise or defend legal claims. Where applicable, this processing is based on our legitimate interests under Article 6(1)(f) of the GDPR.

When we rely on legitimate interests, we consider whether the processing is necessary and whether our interests are overridden by the rights and freedoms of the individual concerned.

5. Is providing personal data mandatory?

You are not legally required to use either website form.

The Contact form requires enough information for us to understand your message and respond. If you do not provide a working email address, we may not be able to reply.

You may suggest a course update without providing your name or email address. However, we may be unable to clarify or verify an update if the submitted information is incomplete.

Consent to analytics and advertising technologies is voluntary.

Refusing analytics or advertising consent does not prevent you from accessing the main content and functions of DiscGolfEstonia.com.

6. Cookies and similar technologies

DiscGolfEstonia.com uses a consent-management system to manage cookies and similar technologies.

Strictly necessary technologies may be used where they are required for website operation, security or a service specifically requested by you.

Non-essential analytics and marketing technologies are subject to consent where required by law.

These may include technologies associated with:

• Google Analytics
• Google Ads
• Meta Pixel

You can accept, reject or manage non-essential technologies through the cookie banner.

You can later change or withdraw your choices through the cookie settings available on the website.

Our separate Cookie Policy provides more detailed information about the cookies and similar technologies in use, their purposes, providers and relevant storage periods.

7. Who can access personal data?

Access to personal data is limited to people and service providers that need the information for the purposes described in this Privacy Policy.

At the date of this Privacy Policy, Laanekivi Invest OÜ does not provide routine WordPress administrator or form-submission access to external agencies or freelancers.

Zone Media OÜ

Zone Media OÜ provides our:

• website hosting
• server infrastructure
• WordPress database hosting
• email hosting
• technical infrastructure
• system backups

Information submitted through Fluent Forms is stored in our WordPress database hosted by Zone and is also sent to our email account hosted through Zone.

Zone processes customer-hosted information on our behalf when providing these services.

Google

With your consent, Google services may receive information through Google Analytics and Google Ads technologies.

Depending on the particular Google service and processing activity, Google may process information as a processor, independent controller or under another role defined in its applicable data-protection terms.

Meta

With your consent, Meta may receive information through Meta Pixel.

Depending on the particular processing activity and applicable Meta terms, Meta and Laanekivi Invest OÜ may have separate or shared responsibilities for certain processing.

Consent management

Our cookie consent system operates within our WordPress website. It is used to record and apply visitor choices so that non-essential technologies can be enabled or disabled according to those choices.

Authorities and legal claims

We may disclose personal data if required by law, a competent authority or a court.

Information may also be disclosed where reasonably necessary to establish, exercise or defend legal claims.

We do not sell personal data.

8. International data transfers

Our website, WordPress database, forms and email are hosted through Zone Media OÜ.

Zone states that customer server data is processed within the European Union or European Economic Area. We do not independently transfer Contact form or Course Update form submissions outside the EEA as part of the normal website workflow.

Google and Meta operate internationally.

When you consent to Google Analytics, Google Ads or Meta Pixel, information may be processed by these providers or their group companies in countries outside the EEA, including the United States.

Where GDPR rules on international transfers apply, transfers must be covered by a recognised legal mechanism. Depending on the provider and processing activity, this may include a European Commission adequacy decision, the EU-US Data Privacy Framework where applicable or European Commission Standard Contractual Clauses together with other required safeguards.

Further information about these providers’ processing and international transfers is available in their respective privacy and data-protection documentation.

9. How long do we keep personal data?

We keep personal data only for as long as reasonably necessary for the purpose for which it was collected.

Contact enquiries

Contact form submissions and related correspondence are normally retained until the enquiry has been resolved and for up to 12 months after resolution.

This applies to copies held in WordPress and related email correspondence unless there is a legitimate reason or legal requirement to retain particular information for longer.

Course update submissions

Personal contact information submitted with a course correction is normally retained until the update has been reviewed and any necessary follow-up has been completed.

It is deleted or anonymised no later than 6 months after the update has been resolved, unless longer retention is reasonably necessary for a legal or documented operational reason.

Factual course information that has been accepted into the course database may remain for as long as it continues to be accurate and useful.

The submitter’s personal contact details do not need to be retained merely because the factual correction remains in the database.

Server and security logs

Routine technical and server logs are retained according to Zone Media OÜ’s normal hosting and security log-rotation procedures.

We do not intentionally create long-term archives of routine visitor server logs.

Analytics

Google Analytics data is retained according to the retention settings configured in our Google Analytics account.

For the MVP, our intended user-level and event-data retention setting is 14 months.

Aggregated statistics that no longer identify individual visitors may be retained for longer.

Advertising services

Information processed through Google Ads or Meta advertising services is retained according to our account settings and the relevant provider’s applicable retention rules.

We retain information accessible to us only for as long as reasonably necessary for campaign measurement, website improvement, compliance and related legitimate business purposes.

Backups

Zone creates system backups of the website, databases and email once per day and retains these backups for 14 days.

Information deleted from the active website or mailbox may therefore remain temporarily in a backup until the relevant backup is automatically overwritten or deleted.

Backups are intended for disaster recovery and are not used as an active source of personal data.

We may retain specific information longer where this is required by law or reasonably necessary for the establishment, exercise or defence of legal claims.

10. External websites and services

DiscGolfEstonia.com contains links to third-party websites and services including:

• Discgolfirajad.ee
• Disc Golf Metrix
• UDisc
• Eesti Discgolfi Liit
• Google Maps
• official course websites
• tourism websites
• other useful external resources

These are normal external links rather than embedded third-party content at the date of this Privacy Policy.

When you follow an external link, you leave DiscGolfEstonia.com.

The third party may process information under its own privacy policy and terms. We do not control the privacy practices of external websites.

11. Data security

We take reasonable technical and organisational measures to protect personal data against accidental or unlawful loss, destruction, alteration, disclosure or access.

Measures relevant to the current website include:

• limiting administrative access
• using reputable hosting infrastructure
• maintaining WordPress and plugins
• website and server security measures
• regular system backups
• limiting access to form submissions
• using spam-prevention measures
• using encrypted HTTPS connections

No website or electronic storage system can guarantee absolute security.

If a personal data breach occurs, we will assess it and take the actions required under applicable data-protection law, including notifying the Estonian Data Protection Inspectorate or affected individuals where legally required.

12. Your data-protection rights

Depending on the circumstances and the legal basis used, you may have the right to:

• ask whether we process your personal data
• request access to your personal data
• ask us to correct inaccurate or incomplete personal data
• request deletion of your personal data
• request restriction of processing
• object to processing based on legitimate interests
• receive certain personal data in a portable format where the right to data portability applies
• withdraw consent at any time where processing is based on consent
• lodge a complaint with a data-protection authority

These rights are not absolute and may not apply in every situation.

To exercise your rights, contact:

info@discgolfestonia.com

Please describe your request clearly.

We may ask for limited additional information where reasonably necessary to verify your identity before acting on a request.

We will respond without undue delay and normally within one month of receiving a valid request.

Where permitted by the GDPR, this period may be extended by up to two additional months where necessary because of the complexity or number of requests. If an extension is required, we will inform you within the initial one-month period.

13. Complaints

If you believe that your personal data has been processed unlawfully, you may contact us first so that we can try to resolve the issue.

You also have the right to lodge a complaint with a competent data-protection authority.

In Estonia, the supervisory authority is:

Andmekaitse Inspektsioon
Estonian Data Protection Inspectorate

Tatari 39
10134 Tallinn
Estonia

Email: info@aki.ee
Website: aki.ee

You may also have the right to complain to the data-protection authority in the EU or EEA country where you usually live or work or where you believe an infringement took place.

14. Children’s personal data

DiscGolfEstonia.com is intended for a general audience and is not designed to collect personal data from children.

Please do not submit unnecessary information about children through the website forms.

If we become aware that unnecessary personal data about a child has been submitted, we will take reasonable steps to delete it.

15. Automated decision-making

DiscGolfEstonia.com does not currently use personal data collected through the website for decisions based solely on automated processing that produce legal effects or similarly significant effects on individuals.

Course update submissions are reviewed manually before information in the course database is changed.

16. Changes to this Privacy Policy

We may update this Privacy Policy when the website, service providers, legal requirements or our personal-data processing activities change.

We will review the policy before introducing a feature that materially changes how personal data is collected or used.

Examples may include a newsletter, user accounts, paid services, additional advertising technologies, an AI trip planner involving personal data or new third-party integrations.

The date at the top of this page shows when the Privacy Policy was last updated.

17. Contact

For questions concerning this Privacy Policy or the processing of personal data by DiscGolfEstonia.com, contact:

Laanekivi Invest OÜ
Registry code: 16699462
Laanekivi tee 7/1-6
Haabneeme alevik, Viimsi vald
Harju maakond 74001
Estonia

Email: info@discgolfestonia.com