Privacy Policy



By creating a user profile or using the website ("Website") and services associated therewith ("Services")("Website" and "Services" together referred as "Ekofolio"), you agree to this notice ("Privacy Notice") for the processing of your personal data by us. If you do not agree with the terms of this Privacy Notice, you should immediately stop using Ekofolio.

The controller of your personal data is:

Ekofolio S.à r.l., registry code B2323241, legal address at 18, rue du Laboratoire, L-2557 Luxembourg, LUXEMBOURG (hereinafter referred to as "Service Provider" or "we" or "us")

  1. Collected personal data
    1. The Service Provider collects personal data from you when you create a profile and register as a user on the Website and also during your use of the Services. We may also gather personal data when you request additional information from us.
    2. As you navigate the Website, we may also collect information through the use of commonly used information gathering tools, such as cookies (see our Terms and Conditons). It includes standard information from your web browser (such as browser type and browser language), your Internet Protocol ("IP") address, geolocation and the actions you take on the Website. We also collect information through the web visits of users.
    3. Personal data that the Service Provider collects may include names, surnames, dates of birth, e-mail addresses, credit card information, billing address, phone number and bank account information.
    4. Any personal data that we collect is processed only in accordance with the applicable EU requirements and regulations on personal data.
  2. Purpose and legal basis
    1. We use personal data for several general purposes:
      • to provide the Services to you;
      • to provide you with service information and news about Ekofolio;
      • to support the Services offered by us;
      • to contact you for feedback about our Services;
      • to conduct research about our customer base or Services;
      • to fulfil your reservation and purchase requests;
      • to process your payments, including credit checks and collection;
      • to notify you of technical updates or changes in policy;
      • to contact you for our own marketing and promotional purposes or
      • to process contests, sweepstakes or other promotions and fulfil any related awards or discounts.
    2. We may send you promotional emails for our services similar to the ones you are registered to use. Any other promotional emails are sent only upon your consent. You may withdraw your consent for direct marketing at any time by sending an email to
    3. The lawful bases we rely on for processing personal data are:
      • contractual obligation to process personal data if you sign up as a user;
      • legal obligation to process personal data arising out of laws and regulations (such as anti-money laundering regulations);
      • consent in order to receive promotional emails and to gather personal data through Website navigation.
  3. Storage and transmission of personal data
    1. Personal data is stored on servers located in the European Union. We take every reasonable precaution and measure to ensure secure processing according to the terms laid down by applicable legislation.
    2. During the provision of our Services, some personal data may be transferred outside of EEA but such transfers are always covered with appropriate safeguards such as Privacy Shield in the case of USA.
    3. Transmission of data online presents certain risks and even though we put in place suitable security levels, we are not able to guarantee that the transmission of data is completely secure. Any online data transfer is carried out at your own risk. As soon as we receive your data in our systems, we shall apply all measures and procedures put in place to avoid unauthorised access or any damage, on a reasonable basis.
  4. Security
    1. It is important for us that your personal data is kept secure. We have strict security procedures for the collection, storage and transfer of personal data to prevent unauthorized access and to comply with applicable law. Our security standards are checked regularly. The information you provide is stored on our own or one of our business partners’ secure servers within the EU. We encrypt your personal data before you send it to us.
    2. We have taken necessary technical and organizational security measures to protect your personal data against accidental or unlawful destruction, loss or alteration and against the unauthorized disclosure, abuse or other processing in violation of applicable law. We store and process your personal data on IT systems with controlled and limited access. The systems are located on servers in secured premises. We use industry standards such as firewalls and authentication protection to safeguard your personal data.
    3. If a password has been allocated for your access to certain features of the Services, please keep it secret and do not share it with anyone. Passwords are an essential tool for maintaining appropriate security conditions.
  5. Disclosure to Third Parties
    1. We use third party service providers to perform the technical operation of Ekofolio. Such third parties act as data processors in relation to personal data, and Service Provider is the data controller. Such data processing is mainly carried out within the European Union. Some personal data may be transferred outside of EEA but such transfers are covered with necessary safeguards such as Privacy Shield. The data processors we use are:
      • Amazon Web Services
      • Google
      • A2 Hosting
      • MailChimp
      • Intercom
    2. Data processors act solely on our instructions. The data processors have taken necessary technical and organizational security measures to protect data against accidental or unlawful destruction, loss or alteration and against the unauthorized disclosure, abuse or other processing in violation of applicable law.
    3. We may disclose your personal data to other companies or people under any of the following circumstances:
      • if sharing the information is reasonably necessary to provide or otherwise make available our Services and any feature of Ekofolio that you have requested;
      • to keep you up to date on the latest product announcements, software updates, special offers or other information we assume you should hear about either from us or from our business partners (unless you have opted out of these types of communications). Note that you will not be able to opt out of service announcements that contain important information relevant to your use of Ekofolio and are not promotional in nature;
      • if we are required to do so by law, in connection with litigation, to prevent a crime or to protect personal property, the public or ourselves;
      • in order to register, prevent or otherwise protect against address fraud, security or technical issues;
      • in connection with a sale or merger with another entity, consolidation, restructuring, sale of company assets, financing or other corporate change, including during the course of any due diligence process or if the Service Provider should ever file for bankruptcy or related proceedings. You acknowledge that any such transfer may occur and that any acquirer of Ekofolio may continue to use your personal data on the terms described in this Privacy Notice;
      • if the Service Provider otherwise has your consent to share the information.
    4. We may also share data which does not constitute personal data with third parties (e.g. aggregated or demographic data).
  6. Rights in relation to personal data
    1. In relation to our processing of personal data you have certain rights on personal data we process in connection with your relation to us. We will take all appropriate measures to ensure that you are provided with information that is to be provided in connection with our processing of personal data and that requests from you in relation to the processing of personal data are handled effectively and with due care.
    2. Right of access - you have a right to receive confirmation as to whether or not personal data concerning you is being processed and where that is the case, access the personal data (as a main rule, a copy of such data will be provided).
    3. Right of rectification - your personal data may be edited at any time by you via the functionality created for this purpose on Ekofolio. Information that proves inaccurate or misleading will be promptly rectified or erased. You are responsible for providing us with information to help ensuring the correctness of your personal data.

      You have the right to request rectification of incorrect or inaccurate personal data, including the right to have incomplete personal data completed, including by means of providing a supplementary statement. Upon receipt of such a request, we will process the request without undue delay.

      Please note that the right of rectification concerns "objective" personal data and not our subjective assessments. If you do not agree with an assessment that we have made, it does not therefore necessarily mean that you can require such an assessment to be rectified, unless the request concerns a fact based error, inaccuracy or similar objective discrepancy in our assessment.
    4. Right to erasure - you have the right to require personal data to be deleted if certain grounds for such deletion are met. Upon receipt of such a request, we will process the request without undue delay and your data will be anonymised so it will no longer constitute personal data. However, we are not able to erase personal data which is mandatory in order for us to provide you Services. If you still wish to have this data deleted, we are not going to be able to provide you our Services. We are also not able to erase your personal data if we have to retain it in order to comply with a legal obligation or in order to exercise or defend legal claims.

      However, the right to erasure does not apply to the extent that our processing of the personal data in question is necessary for compliance with a legal obligation, including, but not limited to, obligations pursuant to applicable anti-money laundering regulations.

      Further, the right to erasure does not apply if the processing is necessary for our exercise or defence of legal claims.
    5. Right to restriction of processing - you have the right to restrict processing of personal data concerning you where the accuracy of the personal data is contested by you but only for the period required for us to verify the accuracy of the personal data in question. However, if you wish to restrict the processing of personal data which is mandatory in order for us to provide you Services, we are not able to fulfil your request without cancelling the provision of our Services to you.
    6. Right to data portability - you have the right to receive the personal data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit such data to another data controller without hindrance from us. Where technically feasible, you have the right to have the personal data transmitted directly from us to another controller. The right to data portability does not apply to the extent that it will adversely affect the rights and freedoms of others.
    7. Right to lodge a complaint - you have a right to lodge a complaint with a supervisory authority of your habitual residence, place of work or place of alleged infringement if you consider that our data processing has infringed your rights.
    8. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. The period may be extended by two months where necessary, taking into account the complexity of the request. If the requests are unfounded or excessive, we may charge a reasonable fee or refuse to act.
    9. Please contact us at, if you wish to make a request.
  7. Minors
    1. People under the age of 18 ("Minors") may only use Ekofolio under the supervision and with the consent of the person holding parental authority over them (parents or guardians). Minors may only register as a user in Ekofolio with consent from their parent(s) or guardian(s).
    2. Only when this consent has been granted shall it be possible to collect the personal data of the Minor who has requested registration to use Ekofolio.
    3. If we discover that any data collected in the our systems relates to a Minor and such data was collected without a valid parental consent, we will delete such data at the earliest opportunity possible.
  8. Anonymized Data

    Service Provider may process anonymized information to further improve Ekofolio. We may also transfer anonymized data to third parties for use of Artificial Intelligence (AI).
  9. Retention
    1. We will retain your personal data for as long it is needed to provide you the Services.
    2. If you delete your account or if you do not use your account with us for a period of three (3) years, we will automatically delete your personal data and your account. Please note that:
      • there might be some latency in deleting such personal data from our servers and back-up storage and
      • Service Provider may retain such personal data if it necessary to comply with our legal obligations, resolve disputes or enforce our agreements.
  10. Third Party Platforms

    Our Website may contain links to other platforms. Service Provider is not responsible for the privacy practices of such other platforms. We encourage you to ensure that when leaving Ekofolio you read the privacy statements of each platform that collects personal data. We accept no liability or commitment from the terms and conditions applied by operators of these other websites.
  11. Cookies
    1. We deploy and administer cookies on the Website.
    2. Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to remember you and your preferences, either for a single visit ("session cookie") or for multiple repeat visits ("persistent cookie"). They ensure a consistent and efficient experience for visitors and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting ("first party cookies") or by third parties, such as those who serve content or provide advertising or analytics services on the website ("third party cookies").

      When visiting Website for the first time, you will automatically receive a cookie. We use cookies to customize and create content and services that match your interests and desires. We also use cookies for demographic and user-related statistics and thus determine who is visiting our website.
    3. We use cookies:
      • for statistics, ie: measuring traffic on Website, including the number of visits, the domains visitors come from, the pages they look at and user’s general geographic area;
      • to enhance the functionality: improve the functionality and optimize your experience on the Website and help you remember your username and password so you do not have to log in again when you return to the website;
      • to integrate with social media, i.e.: allow you to integrate with social media such as Facebook;
      • for quality assurance: to ensure the quality of reviews and preventing fraud and irregularities in connection with writing reviews and registering to use our services;
      • for targeted marketing, i.e.: display specific marketing on Website.

      We provide access for our third party suppliers to inspect the contents of the cookies that are set by us. This information shall be used exclusively on behalf of us and will not be used for the third party’s own purposes.
    4. We use Google Analytics for statistical purposes. You can refuse cookies set by Google Analytics by clicking here:

      We use Google Analytics to analyse how users use our Website. The information generated by the cookie about your use is transmitted to and stored on Google’s servers in the United States. Google uses this information to evaluate your use of Website, compiling reports on the activity of the Website and to provide other services relating to the operation of the Website and internet use. Google may also transfer this information to third parties if required by law or if third parties process the information on Google’s behalf.

      Google Analytics sets two types of cookies: (a) persistent cookie providing information on whether the user is recurrent, where the user is from, what search engine is used, keywords, etc., and (b) session cookies that are used to show when and how long a user uses the Website. Session cookies expire after each session, that is, when you close your tab or browser.
    5. You may see a cookie banner on our website that asks your consent to use cookies. We do not set or allow our partners to set cookies that use your personal information before you click accept. When you consent, we and our partners may set cookies on the site you are visiting and on other of our websites, dashboards and services.
    6. Most browsers allow you to erase cookies from your hard drive, block all cookies or receive a warning before a cookie is stored. You must be aware that in such case services and features cannot be used by you because they require cookies to remember choices you make. We hope that you will allow the cookies to be set, as they help us to improve Ekofolio. You always have the option to delete cookies stored on your computer.
  12. Questions

    If you have questions about this Privacy Notice, please feel free to contact us at the following address:

    Ekofolio OÜ, Rotermanni tn 8, Tallinn, 1011, Estonia


  13. Changes
    1. We may change this Privacy Notice at any given time and you should review it regularly. Such changes come into force immediately. If you do not agree to the modified terms, we ask you to stop using Ekofolio. In the event of a conflict between this Privacy Notice and the modified terms, the modified terms shall apply.
    2. If we are involved in a reorganization, merger, acquisition or sale of our assets, your information may be transferred as part of that deal. We will notify you of any such deal and outline your choices in such event.