Privacy Policy
Last updated: 10.10.2026
1. Data Controller
This privacy policy describes how Gloss Estate OÜ (registry code 14790744, hereinafter “we” or “Gloss Estate”) processes personal data collected through our website www.elenatomson.ee and in the course of providing real estate brokerage services.
Contact details: Gloss Estate OÜ Registry code: 14790744 Email: elena.tomson@uusmaa.ee
If you have any questions regarding the processing of your personal data, please contact us at the email address above.
2. What data we collect
Through our website, when you submit an inquiry regarding buying, selling, or renting real estate, we collect the following data:
- Name
- Phone number
- Email address
- Content of your inquiry (e.g. information about your preferences provided in the message)
In addition, we automatically collect technical data related to your use of the website (e.g. IP address, device and browser information, on-site browsing behaviour) via Google Analytics.
In the course of a real estate transaction (outside the website, e.g. upon signing a brokerage agreement), we may also collect additional data, including identity document details, as required under the Money Laundering and Terrorist Financing Prevention Act.
3. Purposes and legal basis for processing
Purpose | Legal basis |
Responding to your inquiry and establishing contact (purchase, sale, rent) | Steps taken prior to entering into a contract (GDPR Art. 6(1)(b)) |
Providing brokerage services and performing the contract | Performance of a contract (GDPR Art. 6(1)(b)) |
Client identification and due diligence measures | Compliance with a legal obligation under money laundering prevention legislation (GDPR Art. 6(1)(c)) |
Website usage statistics and traffic analysis (Google Analytics) | Legitimate interest in improving the website (GDPR Art. 6(1)(f)) |
Client communication and service quality assurance | Legitimate interest (GDPR Art. 6(1)(f)) |
If you submit an inquiry to us, providing your name, phone number, and email address is necessary for us to be able to contact you and address your request. Without this data, we are unable to respond to your inquiry.
4. Who we share data with
We may share your personal data with the following parties, only to the extent necessary for providing our services:
- Third parties involved in a transaction (e.g. notaries, banks, the Land Register), if you choose to proceed with a transaction through us
- IT service providers who maintain our website and databases
- Google Analytics (Google Ireland Limited) — for website usage analysis
- Accounting and legal advisors, where necessary to fulfil legal obligations
- Supervisory authorities, where required by law
We do not sell your personal data to third parties.
5. Transfers outside the European Union/EEA
Google Analytics may process data outside the European Union/European Economic Area (e.g. in the USA). In such cases, Google applies Standard Contractual Clauses to ensure an adequate level of protection for personal data.
6. Data retention period
- Data from inquiries submitted through the website is retained for up to 24 months after the last contact, if no transaction results from it
- Data related to signed brokerage agreements and completed transactions is retained in accordance with accounting law requirements (generally 7 years)
- Client identification data collected under money laundering prevention legislation is retained for 5 years after the end of the business relationship
- Google Analytics usage data is retained according to Google’s own data retention settings
7. Your rights
Under the General Data Protection Regulation (GDPR), you have the right to:
- access the personal data we hold about you;
- request correction of inaccurate data;
- request deletion of your data (“right to be forgotten”), where no other legal basis for retention applies;
- request restriction of processing;
- request data portability in a machine-readable format;
- object to the processing of your data, including for direct marketing purposes;
- withdraw any consent given at any time, without affecting the lawfulness of processing carried out before the withdrawal.
To exercise your rights, please contact us at elena.tomson@uusmaa.ee.
8. Cookies
Our website uses cookies, including Google Analytics cookies, to collect anonymous statistics about website usage (e.g. traffic, user behaviour on the site). This helps us improve our website and enhance the user experience.
You can manage or disable cookies in your browser settings. Please note that disabling cookies may affect certain functions of the website.
9. Data security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse.
10. Filing a complaint
If you believe that we have processed your personal data in violation of applicable law, you have the right to lodge a complaint with:
Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon): Tatari 39, 10134 Tallinn, Estonia Email: info@aki.ee Website: www.aki.ee
11. Changes to this privacy policy
We reserve the right to amend this privacy policy as needed. In the event of changes, we will update the date shown on this page. We recommend reviewing this privacy policy from time to time.
For questions, please contact us at: elena.tomson@uusmaa.ee