ABAE Auction Platform Privacy Policy



1.1 In processing personal data, the Organizer proceeds from the principles of lawfulness, minimality, purposefulness, and transparency. This means that the Organizer processes personal data as little as possible and as much as necessary, does so only on lawful grounds arising from legislation and for legitimate purposes, and informs data subjects of both the methods and purposes of processing of personal data.
1.2 Questions and requests concerning processing of personal data may be submitted to the Organizer by e-mailing [email protected]. Should the data subject have any complaints, they can also contact the Republic of Estonia Data Protection Inspectorate.


2.1 Organizer is the Animal Breeders’ Association of Estonia (ABAE; registry code 10064515; address Koogimäe tee 4, Keava alevik, Kehtna vald, Rapla maakond 79005, Estonia; e-mail [email protected]).
2.2 Platform is the Organizer’s online solution through which animal sale actions are held; the Platform’s Internet address is https://pullioksjon.etky.ee.
2.3 Privacy Policy is this privacy policy which regulates processing of personal data.
2.4 User is a natural person that registers for actions through the Platform as a Customer (self-employed person) or a Customer’s representative.
2.5 Customer is a natural person (self-employed person) or a corporate body that makes a purchase within the framework of their economic and professional activity.
2.6 Cookie is a small text file that during a visit to the Platform is saved in the User’s computer or mobile device.
2.7 Data protection laws are the General Data Protection Regulation¹ , the Republic of Estonia Personal Data Protection Act² , and other applicable legislation which pertain to personal data protection.
2.8 The terms “personal data”, “data protection”, “processing”, “restriction of processing”, “profiling”, “controller”, “third party”, “consent” of the data subject, and “international organization” are used in this Policy in the meaning provided for in Article 4 the General Data Protection Regulation.


To enable the Platform and sell animals, the Organizer as the Controller processes the following personal data:
(a) the forename and surname, telephone number and e-mail of a User that represents a Customer, and information pertaining to confirmations given upon registration;
(b) the forename and surname, telephone number, address, and e-mail of a Customer (self-employed person), and information pertaining to confirmations given upon registration;
(c) cookies required for the functioning of the “WooCommerce” online store software; and
(d) cookies other than said required cookies, and cookies required to use the “Google Analytics” web analytics service.


4.1 The legal grounds for processing of data noted in items 3(a) and 3(b) are taking of measures that precede the conclusion of relevant agreement and performance of the agreement as well as performance of the Organizer’s legal obligation; relevant purpose is preparation of the conclusion of the agreement and performance of the Organizer’s obligations arising from the Republic of Estonia Accounting Act and rules laid down based thereon.
4.2 The legal grounds for processing of data noted in item 3(c) is taking of measures that precede the conclusion of relevant agreement and relevant purpose is ensuring of functionality of the Platform.
4.3 The legal grounds for processing of data noted in item 3(d) is the User’s consent.
4.4 Based on legitimate interest, the Organizer may send to the e-mail address submitted upon registration information concerning similar new auctions or use consent for sending auction related information.


5.1 The Organizer stores data noted in items 3(a) and 3(b) during and after expiry of the term of the agreement to be concluded for as long as it is necessary to prove possible legal claims of parties to the agreement. If this data is reflected in the Organizer’s accounting documents, the Organizer stores said data during the term provided for in the Republic of Estonia Accounting Act and relevant accounting rules.
5.2 Data noted in items 3(c) and 3(d) is stored in the computer used by the User to visit the Platform or in another device from where the User can delete said data whenever they wish or where said data is automatically deleted in adherence to relevant term.


6.1 The Organizer will not transmit personal data to third parties, third countries, or international organizations, except if such transmission is necessary based on legislation or the Organizer’s legitimate interest and there are legal basis for the transmission.
6.2 The Organizer will not use personal data for automated individual decision-making or for profiling.


7.1 The User has the right to submit requests to the Organizer using the postal address or e-mail address noted in item 2.1 so as to demand from the Organizer, in cases provided for in data protection laws, access to personal data concerning the User and rectification or erasure of such data or restriction of processing or to object to processing of said personal data or to demand information on the right of data portability.
7.2 The Organizer responds to requests noted in item 7.1 at first reasonable opportunity but no later than within one month as from receipt of the request. If possible, the Organizer responds to electronically submitted requests electronically.
7.3 If the User finds that their rights have been violated, they may file a complaint to the Republic of Estonia Data Protection Inspectorate whose contact details are provided at https://aki.ee/.
7.4 The Organizer has the right to amend the Privacy Policy at any time. Amended Privacy Policy takes effect upon publication thereof at the Platform.


8.1 At the Platform, Organizer may collect data concerning the User, to that end using cookies (i.e. small pieces of data stored by the User’s browser on the hard drive of the User’s computer or other device) or other similar technologies (e.g. IP-address, device data, location data), and process such collected data.
8.2 Organizer uses collected data to enable use of the Platform; ensure best quality; inform the User and the Customer of relevant content and make suggestions; make advertisements more relevant and marketing efforts more efficient; facilitate login and data protection. Collected data is also used to count Users and establish their User habits.
8.3 Organizer uses session cookies, persistent cookies, and advertising cookies. Session cookies are deleted automatically after each visit; persistent cookies persist through recurrent use of the Platform; and advertising and third party cookies are used by such web sites of the Organizer’s partners which are related to the Platform. The Organizer does not control the emergence of the latter cookies and, consequently, information concerning these cookies is available from relevant third parties.
8.4 Users agree to the use of cookies at the Platform or web browser. Most web browsers allow cookies. If cookies are not fully allowed, the web site’s functions will not be available to the User. The User controls whether cookies and other similar technologies are allowed or prohibited through the User’s web browser settings.


¹ Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation); available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0679

² The Republic of Estonia Personal Data Protection Act; available at https://www.riigiteataja.ee/en/eli/ee/Riigikogu/act/523012019001/consolide.