Privacy Policy
How we collect, use, and protect your personal data
Last Updated: December 5, 2025
1. Introduction
Welcome to DealCluster.com ("we," "our," or "us"). This Privacy Policy explains how HR Electronics OÜ collects, uses, processes, and protects your personal data when you use our website and services.
Company Name: HR Electronics OÜ
Registry Code: 14412321
Registered Address: Estonia
Email: [email protected]
Business Register: Estonian e-Business Register
We are committed to protecting your privacy and complying with the EU General Data Protection Regulation (GDPR), the Estonian Personal Data Protection Act, and the ePrivacy Directive.
2. Data Controller
HR Electronics OÜ is the data controller responsible for your personal data. For privacy-related inquiries, please contact us at [email protected].
3. What Data We Collect
3.1 Information You Provide Directly
We collect information you voluntarily provide when using our services:
- Contact Information: Email address when you subscribe to newsletters or contact us
- Account Information: If you create an account (username, email, password)
- Communication Data: Messages you send through our contact forms
- Preference Data: Saved searches, favorite products, and personalized settings
3.2 Information Collected Automatically
When you visit DealCluster.com, we automatically collect:
- Technical Data: IP address, browser type and version, device type, operating system
- Usage Data: Pages visited, time spent on pages, click patterns, referral sources
- Cookie Data: Information collected through cookies and similar technologies (see Cookie Policy)
- Location Data: General geographic location based on IP address (country/city level)
3.3 Affiliate and Third-Party Data
As a price comparison and affiliate marketing platform:
- Affiliate Tracking: When you click on product links, we may collect affiliate tracking data to attribute purchases
- Merchant Data: Information about which merchants you visit through our links
- Price Interaction Data: Products you view, compare, or show interest in
3.4 Analytics Data
We use privacy-focused analytics (Umami Analytics) to collect:
- Page views and navigation patterns
- Aggregated user behavior statistics
- Website performance metrics
Note: Our analytics solution does not use personal identifiers and stores data in an anonymized format.
4. Legal Basis for Processing
We process your personal data under the following legal bases (GDPR Article 6):
4.1 Consent (Article 6(1)(a))
- Newsletter subscriptions
- Non-essential cookies and tracking
- Marketing communications
4.2 Contractual Necessity (Article 6(1)(b))
- Providing our price comparison services
- Managing your account
- Processing your requests
4.3 Legitimate Interests (Article 6(1)(f))
- Website security and fraud prevention
- Analytics for service improvement
- Affiliate commission tracking
- Customer support
4.4 Legal Obligations (Article 6(1)(c))
- Compliance with accounting and tax laws
- Responding to legal requests
- Regulatory reporting
8. Data Retention
We retain your personal data only as long as necessary for the purposes outlined in this policy:
| Data Type | Retention Period | Legal Basis |
|---|---|---|
| Account Data | Until account deletion + 30 days | Contractual necessity |
| Analytics Data | 12 months (anonymized) | Legitimate interest |
| Email Communications | Until unsubscribe + 30 days | Consent |
| Affiliate Transaction Data | 36 months | Legal obligation (accounting) |
| Security Logs | 12 months | Legitimate interest |
After retention periods expire, we securely delete or anonymize your data.
9. Your Rights Under GDPR
As a data subject in the EU/EEA, you have the following rights:
9.1 Right of Access (Article 15)
You can request a copy of the personal data we hold about you, including information about processing activities.
9.2 Right to Rectification (Article 16)
You can request correction of inaccurate or incomplete personal data.
9.3 Right to Erasure / "Right to be Forgotten" (Article 17)
You can request deletion of your personal data when:
- It's no longer necessary for the original purpose
- You withdraw consent
- You object to processing
- It was unlawfully processed
- Legal obligations require deletion
9.4 Right to Data Portability (Article 20)
You can receive your personal data in a structured, machine-readable format (JSON, CSV) and transmit it to another controller.
9.5 Right to Object (Article 21)
You can object to processing based on legitimate interests or for direct marketing purposes.
9.9 Right to Lodge a Complaint
You can file a complaint with your national data protection authority:
Estonia: Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)
Website: https://www.aki.ee/en
Email: [email protected]
10. How to Exercise Your Rights
To exercise any of the rights above, please contact us:
Email: [email protected]
Subject Line: "GDPR Data Subject Request - [Your Right]"
Include in your request:
- Your full name and email address
- Specific right you wish to exercise
- Details of your request
- Proof of identity (for security purposes)
We will respond within 30 days of receiving a valid request. Complex requests may take up to 60 days, and we will inform you of any delay.
No Fee: Exercising your rights is free of charge unless requests are manifestly unfounded or excessive.
11. Cookies and Tracking Technologies
We use cookies and similar technologies to provide and improve our services. For detailed information, please see our Cookie Policy.
Summary of Cookie Usage:
- Essential Cookies (No Consent Required): Session management, security features, user preferences
- Analytics Cookies (Consent Required): Umami Analytics (privacy-focused, no personal identifiers)
- Affiliate Cookies (Consent Required): Affiliate link tracking, commission attribution
You can manage cookie preferences through our cookie banner or browser settings.
13. Security Measures
We implement appropriate technical and organizational measures to protect your personal data:
Technical Measures
- Encryption: HTTPS/TLS for data in transit
- Secure Storage: Encrypted databases
- Access Controls: Role-based access
- Authentication: Secure password hashing
- Monitoring: Security logging
Organizational Measures
- Staff Training: Privacy and security training
- Data Minimization: Collecting only necessary data
- Regular Audits: Security assessments
- Incident Response: Breach notification procedures
- Vendor Management: GDPR-compliant contracts
Data Breach Notification: In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the Estonian Data Protection Inspectorate within 72 hours and inform affected individuals without undue delay.
12. Children's Privacy
DealCluster.com is not intended for children under 16 years of age. We do not knowingly collect personal data from children.
If we discover that we have collected data from a child under 16, we will:
- Delete the data immediately
- Terminate any associated account
- Notify the appropriate supervisory authority if required
If you believe we have collected data from a child, please contact us immediately at [email protected].
19. Changes to This Privacy Policy
We may update this Privacy Policy to reflect:
- Changes in our data processing practices
- New features or services
- Legal or regulatory requirements
- Industry best practices
Notification of Changes:
- Material changes will be prominently announced on our website
- You will be notified by email if you have an account
- The "Last Updated" date will be revised
- Continued use constitutes acceptance of the updated policy
20. Contact Information
For privacy-related questions, concerns, or requests:
HR Electronics OÜ
Email: [email protected]
Registry Code: 14412321
Business Register: Estonian e-Business Register
Data Protection Contact: [email protected]
Response Time: We aim to respond to all privacy inquiries within 5 business days, with formal GDPR requests within 30 days.
Your privacy matters to us. If you have questions or concerns about how we handle your personal data, please don't hesitate to contact us at [email protected].
Effective Date: December 5, 2025 | Version: 1.0