Privacy Policy

Lugpal operates the website https://www.lugpal.com and is responsible under data protection law for the data processing described in this privacy policy. This privacy policy applies to the website https://lugpal.com (hereinafter referred to as the “website”).

Thank you for your interest in our online presence. In compliance with Art. 13 GDPR, we provide you with detailed information about how we process your data and your rights in regard to this data processing. Protecting your privacy is a priority for us, and we aim to maintain a business relationship based on trust. Information may be collected directly from you, through your entries and actions, or automatically when you access our services. Providing your data is voluntary; however, some data may be necessary to access certain services (e.g., contacting us).

We follow data protection practices in accordance with the EU General Data Protection Regulation (GDPR), in conjunction with applicable laws.

1. Data Processing During Use of the Website

1.1 Visiting Our Website

You can visit our website without disclosing personal information about yourself. Visiting the website for informational purposes does not allow us to link data to you personally. Automatically processed data does not personally identify you. However, IP addresses are considered personal data under the GDPR.

Server Log Files (Access Data)
For technical reasons (e.g., ensuring a functioning and secure website), we process the data that your browser automatically sends to us in server log files.

The access data we process includes:

The name of the website you are accessing
The browser type and version used
Your operating system
The site you visited before accessing ours (referrer URL)
The time of the server request
The amount of data transferred
The host name and IP address of the accessing computer (anonymized)

This data is used solely for statistical analyses, to operate and improve our website, and for security. It is sent exclusively to our website provider and not linked or aggregated with other data sources. In cases of suspected unlawful website use, we reserve the right to examine this data. This data processing occurs based on our legitimate interest in maintaining a technically fault-free, optimal website, as per Art. 6 para. 1 lit. f GDPR.

Access data is deleted once it has served its purpose, unless further storage is required for evidence purposes, in which case the data is stored until the respective incident is resolved.

1.2 Hosting

In hosting our website, we store all data essential for website operation. This is required for the website to function properly. Therefore, we process this data under our legitimate interest in optimizing our website, as per Art. 6 para. 1 lit. f GDPR. We use the services of Zone Media OÜ to facilitate website access, and this data is processed per Art. 28 GDPR.

1.3 Non-Binding Requests and Inquiries While Visiting the Website

When you contact us, we use the information you provide to process and handle your request based on our legitimate interest (Art. 6 para. 1 lit. f GDPR) in ensuring a functioning contact system. Contact data is necessary for us to process and answer your inquiries; failure to provide this data may prevent us from responding fully.

You may contact us via the contact form on our website, providing necessary details. Alternatively, you may contact us directly through the contact information listed on our website, such as in the imprint or in this privacy policy. We delete your request and contact information once the inquiry is definitively answered, unless legal obligations require data retention (e.g., due to a contractual relationship). Data is generally deleted when no contact is made for six (6) consecutive months.

2. Use of Cookies

We use cookies to make our website as user-friendly as possible. Cookies are small data files exchanged between your browser and our web server during a site visit.

Cookies contain:

The cookie name
The server name where the cookie originates
A unique cookie ID
Expiration date, after which the cookie is deleted

Cookies are classified as:

Technically Necessary Cookies for basic website functions
Statistics Cookies for anonymous user data analysis
Marketing Cookies for personalized advertising based on user interests

The legal basis for technically necessary cookies is our legitimate interest in ensuring the website’s technical functionality (Art. 6 para. 1 lit. f GDPR). The use of statistics and marketing cookies requires your consent per Art. 6 para. 1 lit. a GDPR.

More information about specific cookies and their purposes can be found in our detailed cookie policy. You may withdraw consent for cookies at any time, and you can also adjust your browser settings to block or delete cookies.

3. Transfer of Your Personal Data

For the purposes described in this privacy policy, we may transfer your personal data to the following recipients:

Within our organization, access to your data is restricted to employees and entities that require it to fulfill contractual obligations or to comply with legal responsibilities related to managing our business activities. Access is granted solely on a need-to-know basis and in accordance with our legitimate business interests.

Additionally, your data may be shared with (external) data processors contracted by us, as needed for them to perform their duties. All data processors are contractually obligated to treat your data confidentially and process it solely to provide the specified services. The types of data processors with whom we may share data include:

Customer Management Services
Analytics Tools Providers
IT Service Providers and Support Services
Marketing Management Services

We maintain an updated list of data recipients and processors, available upon request. Specific processors involved are detailed in the relevant sections of this privacy policy.

Some of these recipients may be located outside the EU. To ensure that all recipients meet appropriate data protection standards, we implement safeguards such as standard contractual clauses, which are available upon request. We may also use suppliers in countries deemed to have an adequate level of data protection by the European Commission.

Any data processors we engage are bound by our data protection guidelines and treat your personal data as strictly confidential. Without your explicit consent, these processors will not transfer your data to third parties or use it for any purpose other than fulfilling their obligations to us.

Finally, we may transfer data to independent controllers when necessary to provide our services, which could include authorities or courts within their jurisdiction, as required.

4. Data Subject’s Rights

Data protection law provides you with certain rights regarding your personal data. We will respond to your requests promptly, generally within one (1) month. To exercise your rights, please contact us at:

hello@lugpal.com

You have the following rights:

Right to Information: Upon request and absent any legal restrictions, we will provide comprehensive information about our processing of your data, including copies of data records and details on processing purposes, data categories, recipients, storage limits, and data origin.
Right to Correction: You may request that we correct inaccurate, outdated, or incomplete information about you. During the evaluation of your request, you may also request restricted processing.
Right to Deletion: You can request data deletion in cases where processing is no longer necessary, consent is withdrawn, a legitimate objection is raised, improper processing occurred, legal requirements for deletion apply, or data involves minors under the age threshold (16 or as applicable by jurisdiction).
Right to Restriction of Processing: In certain cases, you can request restricted processing, meaning the data will be stored but not processed further. This may apply during data correction evaluations, periods of unlawful processing (where deletion is not requested), or during the assessment of an objection.
Right to Withdraw Consent: If data processing is based on your prior consent, you may withdraw this consent at any time, affecting future processing. However, prior processing based on valid consent remains lawful.
Right to Object: You may object to data processing at any time, especially if processing is based on Lugpal’s legitimate interests.
Right to File Complaints: You have the right to file complaints with supervisory authorities.
Right to Data Portability: You are entitled to receive data you provided in a structured, standard, machine-readable format or to have it transferred directly to another controller, if technically feasible. This applies to data processed based on your consent.

Please note that certain requests may not be fulfilled due to protected processing reasons (such as legal obligations or legitimate interests). Excessive or unfounded requests may result in a fee.

5. Data Security and Data Deletion

Lugpal uses technical and organizational measures to ensure that personal data is processed to the minimum extent necessary. These measures include limits on data access, retention periods, and storage. Only essential employees or service providers have access to personal data, and they are bound to confidentiality.

We employ safeguards such as backups and encryption to secure data against loss, theft, destruction, unauthorized access, modification, or distribution. Employees are trained on applicable data protection laws and our internal data security measures, and processors we engage must adhere to our privacy standards.

In compliance with GDPR, all data collected through our website is stored only as long as necessary for its purpose, unless a longer retention period is legally mandated. We follow an internal data deletion policy, details of which are available upon request.

6. Links to Third-Party Websites

Our website contains links to third-party sites, including partner websites and social media platforms (e.g., Facebook, Instagram, YouTube). Clicking these links will take you to the respective external site, and the operator of that site will receive the information that you came from our website. For more information, please refer to the privacy policies of these third-party sites.

These links are provided solely for user convenience, and we do not endorse the content or assume liability for the availability, accuracy, or legality of these external sites.