Privacy Policy

MANIMAMA OÜ cares about the privacy of your data and is committed to protecting it. This Privacy Policy (hereinafter referred to as the “Policy”) explains who we are, how we collect, share and use Personal Data, and how you can exercise your privacy rights. Personal Data is any information relating to an identified or identifiable natural person.

MANIMAMA OÜ processes Personal Data about you as a Client, Opponent, Representative of an Opponent, and so on as part of our client and case management in conjunction with our legal services and business operations, when you visit our Website https://manimama.eu/, subscribe to our Telegram Channel, and so forth.

We recommend that you read this Policy in full to ensure you are fully informed. However, to make it easier for you to review the parts of this Policy that apply to you, we have divided up the document into sections that are specifically applicable to the Clients, Potential Clients, Opponents and Representatives of an Opponent(s), Visitors of the Website, Visitors of the Telegram Channel and Visitors who submit LinkedIn Lead Generation Forms. Please note that you can combine several statuses, for example, Visitor of the Website and Opponent.

The data controller is MANIMAMA OÜ, a company incorporated under the laws of Estonia under registered number 14803352. If you have any questions about MANIMAMA’s processing of your Personal Data or you wish to exercise your rights, you are always welcome to contact us: Legal and business address: Harju maakond, Tallinn, Kesklinna linnaosa, Pärnu mnt 158/2-88, 11317, Estonia; Tel.: +48 731853714 Email: support@manimama.eu

If you are dissatisfied, you have the right to lodge a complaint with the supervisory authority for data protection issues – Estonian Data Protection Inspectorate (AKI), Tatari 39, Tallinn, 10134, Estonia, (e-mail: info@aki.ee/phone: 627 4135) or bring proceedings before a competent court. We would, however, appreciate the chance to deal with your concerns before you approach the AKI so please contact us in the first instance.

1.1. We collect Personal Data from you when you become our Client, respond to a survey or marketing communication, fill out a form on our Website, or in any other circumstance listed in

1.2.3. Business operations. In connection with MANIMAMA’s business operations as a legal services company, we process Personal Data concerning our suppliers and business partners. The Personal Data we process may include: – name; – place of work and contact information; as well as – information about the relationship and correspondence.

The legal basis is MANIMAMA’s legitimate interests in managing and providing legal services and conducting its business operations (Article 6(1)(f) of the GDPR). In some cases, the legal basis is Article 6(1)(b) of the GDPR, according to which processing is necessary for the performance of a contract to which the data subject is a party.

1.3. Please note that you must provide complete, accurate and correct details and you hereby confirm the details you provided are correct. We may refuse to enter into an agreement with you if you do not provide us with the requested data that is necessary for each activity. If you provide false, incorrect, or outdated information or only partial information, it may impair our ability to contact you.

2.1. MANIMAMA primarily obtains Personal Data directly from the Clients but may also obtain Personal Data from publicly available sources, public authorities and Opponents (Representatives of Opponents).

2.2. Information for the prevention of money laundering and financing of terrorism is generally obtained from the Client but may also be obtained from public registers.

2.3. We obtain information in connection with marketing from you as a data subject.

2.4. Please note that when you visit our website, you may provide information about your activities and use of the Website to MANIMAMA and, where applicable, third-party service providers, subject to the relevant legal requirements and your consent where required (read more in our Cookie Policy and Section 5).

3.1. MANIMAMA keeps Personal Data for as long as it is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).

3.2. In connection with client management, case management and legal advice, MANIMAMA generally stores your information for five years from the end of the year in which the case was closed unless otherwise required according to legislation or in case of original documents.

3.3. If no case has been created and we have registered information about you only in connection with creating a possible relationship, we will store your information for up to six months after ending the correspondence.

3.4. Information for money laundering control purposes, etc. is stored for five years following the termination of the business relationship, where applicable, in accordance with § 47 of the Estonian Money Laundering and Terrorist Financing Prevention Act. Records relating to transactions and reporting obligations are retained for the applicable statutory periods, subject to any legally permitted extensions or exceptions.

3.5. Information about you as a supplier or cooperating partner is stored for up to five years after the end of the year during which the delivery took place or the cooperation was terminated.

3.6. We will erase your Personal Data without undue delay where one of the following grounds applies and no applicable legal exception or overriding retention obligation requires or permits further processing:

3.6.1. the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

3.6.2. you withdraw consent on which the processing is based and where there is no other legal ground for the processing;

3.6.3. you object to the processing and there are no overriding legitimate grounds for the processing (for example where Personal Data are processed for direct marketing purposes, you shall have the right to object at any time to processing of Personal Data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing);

3.6.4. the Personal Data have been unlawfully processed;

3.6.5. the Personal Data have to be erased for compliance with a legal obligation in Union or Member State law to which MANIMAMA is subject.

4.1. Users are afforded certain rights regarding their Personal Data:

4.1.1. the right to contact us for confirmation of whether we are processing your Personal Data and to find out:

4.1.1.1. the purpose of the processing;

4.1.1.2. what categories of your Personal Data we process;

4.1.1.3. to whom we transfer your Personal Data and / or categories of such recipients;

4.1.1.4. the period of storage of Personal Data, or, where the exact period cannot be specified, the criteria used to determine that period;

4.1.1.5. the sources of our obtaining your Personal Data if we did not receive the Personal Data from you.

Most of these questions can be answered in this Policy;

4.1.2. right to access your Personal Data – you have the right to request from us a copy of your Personal Data that we process. The first copy will be free of charge, and for further copies requested by you, we may charge a reasonable fee based on administrative costs, in accordance with Article 15(3) of the GDPR;

4.1.3. the right to object to the processing of Personal Data – you have the right to object to our processing of your Personal Data. You have an unconditional right to object to our processing of your Personal Data for direct marketing purposes, in particular with the aim of adapting content, recommendations and advertising to your interests. In other cases, we have the right to continue processing your Personal Data if we have legal grounds to do so. If the basis for processing Personal Data is a legitimate interest, we have the right to continue processing Personal Data only if we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or where processing is necessary for the establishment, exercise or defence of legal claims, in accordance with Article 21 of the GDPR;

4.1.4. the right to rectify your Personal Data – you have the right to ask us to correct your Personal Data that you believe is inaccurate. If you believe that your data is incomplete, you also have the right to contact us with a request to complete your data by providing us with the missing information. If, based on our purposes for the processing of Personal Data, we do not need such additional information, we can deny you this request;

4.1.5. you have the right to receive your Personal Data that you have provided to us in a structured, commonly used and machine-readable format and you can transfer it to another controller if:

4.1.5.1. processing is carried out on the basis of your consent or is necessary for the performance of a contract to which you are a party, pursuant to Article 6(1)(b) of the GDPR;

4.1.5.2. processing is carried out using automated means. This right applies to processing based on consent or contract and carried out by automated means, subject to the conditions and limitations of Article 20 of the GDPR. It allows you to easily move, copy or transfer Personal Data from one IT environment to another in a secure and reliable way, without interfering with usability;

4.1.6. the right to delete your Personal Data. We have described our policy for retention and deletion of Personal Data in section 3;

4.1.7. the right to withdraw consent to the processing of Personal Data. If the basis for the processing of your Personal Data was your consent, you have the right to withdraw that consent at any time. Such revocation will not affect the legality of the processing prior to revocation. However, this may affect the number of services we can provide to you. For example, if we needed your consent to provide some of the services, then after you revoke it, we will no longer be able to provide you with such services.

4.1.8. The right to restriction of processing – you have the right to request restriction of processing of your Personal Data in the circumstances specified in Article 18 of the GDPR.

4.1.9. The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except in the circumstances permitted under Article 22 of the GDPR.

4.2. You may exercise any of your rights in relation to your Personal Data by contacting us at email support@manimama.eu. You must note that prior to accessing and making changes to your Рersonal data, we may request additional information necessary to confirm your identity where we have reasonable doubts concerning your identity, in accordance with Article 12(6) of the GDPR. We will respond to requests concerning your rights within the periods prescribed by Article 12 of the GDPR. These rights are subject to the conditions and exceptions established by applicable law.

5.1. Your Personal Data is disclosed where necessary for case management, legal advice, business operations, compliance with applicable legal obligations or other purposes described in this Policy, provided that an appropriate legal basis applies. You can always withdraw your consent by contacting MANIMAMA via the above contact information where processing is based on consent. Personal Data may be disclosed to the following parties:

5.1.1. the parties to your case;

5.1.2. public authorities, including courts, tax authorities, prosecuting authority, banks, etc;

5.1.3. in connection with auditing;

5.1.4. third party organizations that provide applications/functionality, data processing or IT services to us;

5.1.5. external legal professionals and other professional service providers engaged in connection with the provision of services to our Clients, where necessary and permitted by applicable law.

5.2. For verifying the identity of our Clients, we use our internal KYC department and may engage external identity verification or due diligence service providers, subject to applicable AML/CFT legislation and data protection requirements. Where such providers act as processors on our behalf, appropriate data processing arrangements shall be established in accordance with Article 28 of the GDPR. Where we rely on customer due diligence measures carried out by third parties, the applicable requirements governing third-party reliance under AML/CFT legislation shall apply.

5.3. For behavior statistics and business intelligence we use the service by Google LLC (hereinafter referred to as “Google Analytics”), a company located in the United States. Personal Data that we may provide to Google Analytics may include your IP address and that data is used by Google Analytics to generate information about your usage of our Website. Google Analytics cookies and related technologies that require consent are used only after you have provided such consent, as further described in our Cookie Policy. Any transfers of Personal Data outside the European Economic Area are subject to the applicable requirements of Chapter V of the GDPR.

5.4. For tracking server errors, we use an internal self-hosted monitoring system accumulating stacktraces, logs and metrics.

5.5. For processing notification information, we use chatbots and e-mail notifications.

5.6. MANIMAMA may transmit Personal Data to third countries, complying with the requirements set out in the legislation, and by adopting appropriate measures to ensure data security. Where we transfer personal data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement that covers the EU requirements for the transfer of personal data outside the EEA, such as the European Commission approved standard contractual clauses, or another lawful transfer mechanism under Chapter V of the GDPR, where applicable. The European Commission approved standard contractual clauses are available here.

5.7. Any disclosure of Personal Data is carried out in strict accordance with the requirements of the law. When we disclose your Personal Data to a Third Party, we take all reasonable steps to ensure that those Third Parties are bound by confidentiality and privacy obligations with respect to the protection of your Personal Data. The disclosure is conducted in compliance with legal requirements, including entering into data processing agreements with the relevant Third Parties where they act as processors on our behalf, to ensure that Personal Data is only processed in accordance with our instructions, applicable law and regulations and for the purpose specified by us and to ensure adequate security measures.

6.1. We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

6.2. Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visits as safe as possible. Your Personal Data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.

6.3. Our Website uses an HTTPS protocol that ensures the security of data exchanged via Transport Layer Security (TLS) protocol. The TLS provides three layers of protection: encryption, data integrity and authentication.

7.1. This Policy will be updated on an ongoing basis so that it is always up-to-date. Below you can always find the date of the last updated version of this Policy.

7.2. When we update our Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

7.3. We will obtain your consent to any material Policy changes if and where this is required by applicable data protection laws. THANK YOU!