ALTMER ENERGY OÜ PRIVACY POLICY

Last updated: 12 August 2026This Privacy and Personal Data Processing Policy explains how Altmer Energy OÜ collects, uses, stores and transfers the personal data of visitors to the website altmerenergy.ee, persons submitting enquiries, prospective and existing customers, and representatives of business customers.Altmer Energy OÜ processes personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, GDPR), the Estonian Personal Data Protection Act and other applicable laws and regulations of Estonia and the European Union.The purpose of this Policy is to ensure transparent and lawful processing of personal data and to protect the privacy of our customers and website visitors.1. Data ControllerThe controller of personal data is:Altmer Energy OÜ Registry code: 14263861 Address: Kadaka tee 63, 12915 Tallinn, Estonia Phone: +372 5855 0010 E-mail: ue.ygreneremtla%40ofni Website: altmerenergy.eeFor questions concerning the processing of personal data, please contact us at:ue.ygreneremtla%40ofni2. What Is Personal DataPersonal data means any information relating to an identified or identifiable natural person.Personal data may include, for example: • first and last name;  • telephone number;  • e-mail address;  • address of the property or installation site;  • IP address;  • information about the user’s activity on the website;  • information provided when submitting an enquiry;  • other information that may directly or indirectly identify a natural person. Information relating solely to a legal entity is not personal data. However, information concerning its representatives, employees and contact persons may constitute personal data.3. Whose Personal Data We ProcessAltmer Energy may process the personal data of: • visitors to altmerenergy.ee;  • persons who complete an enquiry form on the website;  • persons who contact us by telephone or e-mail;  • prospective customers;  • existing and former customers;  • representatives of business customers;  • representatives of partners and suppliers;  • persons who interact with Altmer Energy through social media;  • other persons who voluntarily provide us with their personal data. 4. What Personal Data We CollectThe scope of personal data processed depends on the nature of the interaction with Altmer Energy.4.1. Data Provided Through the WebsiteWhen completing a form on altmerenergy.ee, we may process the following information: • name;  • telephone number;  • e-mail address;  • address of the property or installation site;  • type of property – residential or commercial;  • information on whether an agreement for selling electricity to the grid is in place;  • electrical connection parameters;  • information on the need for solar panels;  • preferred installation method;  • annual electricity consumption;  • information about the desired energy storage system;  • other information voluntarily provided by the user when submitting an enquiry. This information is used to understand the customer’s needs and to prepare a suitable energy solution or quotation.4.2. Data Obtained When Communicating With Altmer EnergyWhen communicating by e-mail, telephone or other communication channels, we may process, for example: • contact details;  • the content of the enquiry;  • correspondence;  • information about the property or installation site;  • documents, photographs, drawings, diagrams or invoices provided by the customer;  • information about requested products and services. 4.3. Customer DataWhen entering into or performing a contract, we may additionally process: • contract information;  • quotations;  • order information;  • project information;  • delivery and installation information;  • payment and accounting information;  • service history;  • warranty and maintenance enquiries. 4.4. Automatically Collected DataWhen visiting the website, certain technical information may be processed automatically, including: • IP address;  • browser type;  • device type;  • operating system;  • browser language;  • date and time of the visit;  • pages visited;  • duration of the visit;  • source from which the user reached the website;  • user activity on the website;  • technical identifiers;  • cookies and similar technologies. 5. How We Obtain Personal DataAltmer Energy may obtain personal data: • directly from the data subject;  • through forms on altmerenergy.ee;  • by e-mail;  • by telephone;  • through social media;  • during consultations;  • when entering into and performing contracts;  • from the organisation represented by the person;  • from partners or service providers where there is a lawful basis for the transfer;  • in certain cases, from lawfully available public sources in the context of business relationships. Where personal data has not been obtained directly from the data subject, Altmer Energy complies with the applicable information obligations under the GDPR.6. Purposes of Processing Personal DataAltmer Energy processes personal data only for specified and lawful purposes.The main purposes of processing are as follows.6.1. Handling EnquiriesPersonal data may be processed in order to: • respond to an enquiry;  • contact a prospective customer;  • provide consultation;  • identify the customer’s needs;  • carry out a preliminary assessment of the property or installation site;  • select suitable equipment;  • prepare calculations;  • prepare a quotation. 6.2. Entering Into and Performing a ContractPersonal data may be processed in order to: • prepare a contract;  • fulfil an order;  • carry out design and engineering work;  • supply equipment;  • arrange installation;  • connect and configure equipment;  • prepare the necessary documentation;  • provide warranty and maintenance services;  • communicate with the customer in connection with the project. 6.3. Compliance With Legal ObligationsPersonal data may be processed for: • accounting purposes;  • tax accounting;  • compliance with statutory requirements;  • retention of mandatory documentation;  • disclosure of information to public authorities where required by law. 6.4. Development and Improvement of ServicesPersonal data may be used for: • analysing the quality of our services;  • improving the website;  • analysing users’ interests;  • improving the customer experience;  • developing products and services;  • analysing the effectiveness of marketing channels. 6.5. Security and Protection of Legitimate InterestsPersonal data may be processed for: • ensuring the security of the website and information systems;  • preventing misuse or abuse;  • protecting the property and rights of Altmer Energy;  • establishing, exercising or defending legal claims;  • resolving disputes. 6.6. MarketingWhere an appropriate legal basis exists, Altmer Energy may use contact details to send information about: • products and services;  • solar power systems;  • energy storage systems;  • special offers;  • new products;  • support measures and subsidies;  • events;  • company news. Recipients have the right to opt out of direct marketing at any time.7. Legal Bases for ProcessingDepending on the circumstances, Altmer Energy processes personal data on the following legal bases.Performance of a Contract or Steps Taken Prior to Entering Into a ContractFor example, where a person submits an enquiry requesting a calculation or quotation, or enters into a contract with Altmer Energy.Compliance With a Legal ObligationWhere processing is necessary to comply with legal obligations, including accounting and tax requirements.Legitimate Interests of Altmer EnergyFor example: • development of services;  • customer service;  • ensuring security;  • protection of legal interests;  • management of relationships with business customers and partners. When processing personal data on the basis of legitimate interests, Altmer Energy considers and balances the rights and interests of the data subject.ConsentConsent may be used, in particular: • for certain forms of direct marketing;  • for analytical cookies;  • for advertising and marketing cookies;  • in other situations where prior consent is required by law. Where processing is based on consent, the individual has the right to withdraw their consent at any time.Withdrawal of consent does not affect the lawfulness of processing carried out before the consent was withdrawn.8. Direct MarketingAltmer Energy may send electronic marketing communications to natural persons where a lawful basis for doing so exists.Where prior consent is required by law, marketing communications will not be sent before the relevant consent has been obtained.Where permitted by applicable law, Altmer Energy may inform existing customers about its own similar products or services, provided that the customer is given a simple opportunity to opt out of such communications.Every electronic marketing communication must provide the recipient with an easy way to opt out of further similar communications.Direct marketing can also be declined at any time by contacting:ue.ygreneremtla%40ofniOpting out of marketing does not affect communications required for responding to an enquiry, performing a contract, providing warranty services or fulfilling other contractual obligations.9. Cookies and Similar TechnologiesAltmer Energy uses cookies and similar technologies on its website to ensure the operation of the website, analyse its use and, where the user has provided consent, measure and optimise advertising campaigns.A cookie is a small file or technical identifier that is stored on or read from the user’s device when the website is visited.Cookies may be used, for example, to: • ensure the technical operation of the website;  • remember user preferences;  • ensure security;  • analyse website traffic;  • identify which pages are most relevant to users;  • analyse referral sources;  • measure the effectiveness of advertising campaigns;  • measure conversions;  • compile advertising statistics;  • display more relevant advertising. 10. Types of Cookies10.1. Strictly Necessary CookiesStrictly necessary cookies are required for the proper functioning of the website and its essential features.They may be used, for example, for: • technical operation of website pages;  • operation of forms;  • ensuring security;  • storing the user’s cookie consent preferences. Separate consent is not required for strictly necessary cookies to the extent permitted by applicable law.10.2. Analytical CookiesAnalytical cookies are used to obtain statistical information about the use of the website.They may be used to analyse, for example: • the number of visitors;  • pages visited;  • duration of visits;  • referral sources;  • user interaction with website content. Analytical cookies that are not strictly necessary for the operation of the website are used only after obtaining the user’s prior consent.10.3. Marketing and Advertising CookiesThese cookies may be used, among other purposes, to: • measure advertising effectiveness;  • record advertising conversions;  • determine which advertisement directed the user to the website;  • create advertising audiences;  • optimise advertising campaigns;  • display more relevant advertising. Such cookies are used only after obtaining the user’s prior consent.11. Analytics and Advertising ServicesDepending on the current technical configuration of the website, Altmer Energy may use analytics and advertising technologies provided, for example, by: • Google – for web analytics, conversion measurement and evaluation of advertising campaign performance;  • Meta Platforms – for measuring the effectiveness of advertising on Facebook and Instagram, analysing conversions and creating advertising audiences. Depending on the website configuration, tools such as Google Analytics, Google Ads and Meta technologies may be used.Optional analytics and advertising tools are activated only in accordance with the user’s cookie consent choices.An accurate and up-to-date list of cookies used on the website, including their purpose, provider and duration, is displayed or made available to the user through the “Cookie settings” section of the website.The user may change or withdraw previously given consent at any time.12. Managing Cookie ConsentWhen visiting the website for the first time, the user is given the opportunity to: • accept optional cookies;  • reject optional cookies;  • select individual categories of cookies. Rejecting analytical or advertising cookies does not prevent the use of the website’s essential functions.The user must be able to change their choice later through the:“Cookie settings”link available on the website.Withdrawing consent must be as easy as giving it.Users may also delete stored cookies through their web browser settings.13. Social MediaAltmer Energy uses social media platforms, including Facebook and Instagram.If a user interacts with Altmer Energy accounts on social media, for example by: • following a page;  • liking content;  • leaving a comment;  • sending a message;  • interacting with an advertisement, the relevant social media platform may also process the user’s personal data in accordance with its own privacy policy.Altmer Energy processes data available through social media only to the extent necessary for communication, marketing, performance analysis and customer service.14. Disclosure of Personal Data to Third PartiesAltmer Energy does not sell customers’ personal data.To carry out its activities, Altmer Energy may use service providers and business partners that may have access to personal data only to the extent necessary for providing the relevant service or performing the relevant task.Such recipients may include: • hosting providers;  • IT service providers and website developers;  • CRM system providers;  • e-mail and cloud service providers;  • analytics service providers;  • advertising platforms;  • accounting and financial service providers;  • legal and other professional advisers;  • designers and engineers;  • installation companies and subcontractors;  • equipment suppliers and manufacturers;  • electricity network operators;  • organisations involved in support programmes where the customer has requested the relevant service;  • public authorities and supervisory authorities where disclosure is required by law. Altmer Energy transfers only the personal data necessary for the relevant purpose.Where a third party processes personal data on behalf of Altmer Energy, appropriate contractual and organisational safeguards are applied.15. Transfers of Personal Data Outside the European Economic AreaSome providers of digital, analytics, advertising or cloud services may process personal data outside the European Economic Area.Where such transfers take place, Altmer Energy ensures that a lawful transfer mechanism under the GDPR is in place, such as: • an adequacy decision adopted by the European Commission;  • Standard Contractual Clauses approved by the European Commission;  • another safeguard permitted under applicable law. 16. Retention of Personal DataAltmer Energy retains personal data only for as long as necessary for the purposes for which it is processed or to comply with legal obligations.The retention period depends on the category of personal data.Information relating to an enquiry from a prospective customer may be retained for a reasonable period after the last contact in order to continue communication concerning the enquiry and to protect the legitimate interests of the parties.Customer information and contractual documentation may be retained for the duration of the contractual relationship and thereafter for as long as necessary to comply with warranty, accounting and legal obligations.Accounting records are retained for the period required by applicable law.Personal data used for direct marketing is processed until: • consent is withdrawn;  • an objection to direct marketing is submitted;  • the relevant purpose of processing ceases to exist. Data collected through cookies is retained for the period specified for the relevant cookie in the cookie settings.After the applicable retention period expires, personal data is deleted or anonymised unless continued retention is required by law.17. Security of Personal DataAltmer Energy applies appropriate technical and organisational measures to protect personal data against: • accidental or unlawful loss;  • destruction;  • alteration;  • unauthorised access;  • unlawful disclosure;  • unlawful use. Access to personal data is granted only to persons who require such information in order to perform their employment or contractual duties.Altmer Energy requires its service providers to ensure an appropriate level of confidentiality and data protection.18. Rights of the Data SubjectIn the circumstances and to the extent provided by the GDPR, individuals have the right to: • obtain information about the processing of their personal data;  • access their personal data;  • obtain a copy of the personal data being processed;  • request correction of inaccurate or incomplete personal data;  • request deletion of personal data;  • request restriction of processing;  • object to processing based on legitimate interests;  • object at any time to the processing of personal data for direct marketing purposes;  • receive their personal data in a structured, commonly used and machine-readable format where applicable;  • withdraw previously given consent;  • lodge a complaint with a supervisory authority. To exercise these rights, please contact:ue.ygreneremtla%40ofniAltmer Energy may request additional information where reasonably necessary to verify the identity of the person making the request.19. Right to ErasureIndividuals have the right to request the deletion of their personal data in the circumstances provided for by the GDPR, for example where: • the personal data is no longer necessary for the purpose for which it was collected;  • consent has been withdrawn and there is no other legal basis for processing;  • the individual validly objects to the processing;  • the personal data has been unlawfully processed. The right to erasure is not absolute.Altmer Energy may continue to retain personal data where this is necessary, for example: • to comply with a legal obligation;  • to perform a contract;  • to establish, exercise or defend legal claims;  • in other circumstances permitted by applicable law. 20. Right to Object to Direct MarketingThe data subject has the right at any time and without providing a reason to object to the processing of their personal data for direct marketing purposes.After receiving such an objection, Altmer Energy will no longer process the relevant personal data for direct marketing purposes.21. Automated Decision-MakingUnless the user is specifically informed otherwise, Altmer Energy does not use personal data collected through the website for decisions based solely on automated processing that produce legal effects concerning an individual or similarly significantly affect them.Automated calculators, analytical tools or preliminary calculations do not in themselves constitute a final decision regarding the customer’s project.22. ComplaintsIf an individual believes that Altmer Energy has infringed their rights in connection with the processing of personal data, they may first contact us at:ue.ygreneremtla%40ofniIndividuals also have the right to lodge a complaint with the Estonian data protection supervisory authority:Andmekaitse Inspektsioon Estonian Data Protection Inspectorate Tatari 39 10134 Tallinn Estonia23. Links to Third-Party WebsitesThe Altmer Energy website may contain links to third-party websites or services.Altmer Energy does not determine how personal data is processed on such third-party websites.When visiting a third-party website, users should review the privacy policy of the relevant service provider.24. Changes to This Privacy PolicyAltmer Energy may update this Privacy Policy where there are changes to: • applicable legislation;  • methods of personal data processing;  • information systems used;  • website functionality;  • analytics or advertising tools used;  • the company’s services. The current version of this Privacy Policy will always be published on altmerenergy.ee.The date of the latest update is stated at the beginning of this document.25. Language VersionsThis Privacy Policy may be published in Estonian, Russian and English.In the event of any discrepancy between the language versions, the Estonian-language version shall prevail, unless mandatory applicable law provides otherwise.26. Contact InformationFor all questions relating to privacy and the processing of personal data:Altmer Energy OÜ Registry code: 14263861 Kadaka tee 63 12915 Tallinn EstoniaPhone: +372 5855 0010 E-mail: ue.ygreneremtla%40ofni Website: altmerenergy.ee