1. Controller
Express Buy OÜ, registry code 12907550, Paasiku 4, Tallinn, Estonia is the data controller for LEMIO. Privacy requests may be sent to info@lemio.ee or made by phone at +372 58404003.
2. Data processed
Depending on the features used, LEMIO processes:
- account data: email, display name, password hash, account status and registration date;
- profile data: first and last name, phone, country, city, avatar and visibility choice;
- organization data submitted by authorized users;
- listing data, photographs, location, public description and contact choices;
- private-message content, participants, listing reference, delivery/read state and timestamps;
- moderation, security and support records;
- technical data such as IP address, user agent, request logs and authentication events;
- legal acceptance evidence:
accepted_version,accepted_at,accepted_ipandaccepted_user_agent; - subscription-term acceptance evidence: accepted subscription version and timestamp;
- language and session preferences stored in cookies.
Do not submit special-category data or information about another person unless it is necessary and lawful.
3. Purposes and legal bases
We process data to:
- create and operate accounts, listings, organization profiles and messaging (GDPR Article 6(1)(b));
- secure the service, prevent abuse, maintain evidence, moderate content and defend legal claims (Article 6(1)(f), legitimate interests in a safe and accountable service);
- comply with legal orders and statutory duties (Article 6(1)(c));
- publish profile or listing information at the user’s request (Article 6(1)(b));
- use optional non-essential technologies only where valid consent is obtained (Article 6(1)(a)).
Where legitimate interests apply, we balance those interests against the user’s rights and reasonable expectations.
4. Visibility and recipients
Published listings are visible to visitors. Profile visibility follows the user’s selected setting. Full listing contact details are shown only as described in the service interface. Private messages are available to their participants and are not public.
Data may be handled by authorized Express Buy OÜ personnel and service providers needed for hosting, maintenance, security and email delivery, under appropriate contractual safeguards. Data may be disclosed where required by law or necessary to protect legal rights. LEMIO does not sell personal data.
Payment processing
When a user pays for a paid LEMIO service, the data necessary for the payment may be transferred to the selected licensed payment service provider and to the bank or payment service selected by the user. Available payment methods are shown when the order is placed. The data may include the order reference, payable amount and currency, payment status, customer identification and contact details required for the payment, and information necessary to process a refund. This processing is necessary to perform the contract and arrange the requested payment (GDPR Article 6(1)(b)) and, where applicable, to comply with accounting, refund and other legal obligations (Article 6(1)(c)). Only data needed to initiate and process the payment, identify the order, confirm the payment status, process a refund and meet applicable legal requirements is transferred. Payment recipients do not receive online-banking credentials, card PINs, full authentication credentials, LEMIO passwords, private messages or listing content from LEMIO for payment processing. Payment and order records are retained only for as long as required to administer the transaction and comply with applicable accounting, payment, refund and legal-retention obligations.
5. International transfers
LEMIO should select European Economic Area processing where reasonably available. If a provider processes data outside the EEA, Express Buy OÜ will use a lawful transfer mechanism, such as an adequacy decision or approved contractual safeguards, and provide further information on request.
6. Retention
Account and profile data are retained while the account is active. A participant may remove a conversation only from their own interface; removal by one participant does not remove the other participant’s copy. If both participants remove a conversation, its messages and participant state may be permanently deleted.
Inactive conversations are normally deleted by a background process after three months from the last message or other confirmed conversation activity. A new message starts a new three-month period and may restore visibility for a recipient who previously removed the conversation. Retention may be extended while a report, dispute, moderation or legal investigation is open, while a legal hold applies, or where records are temporarily needed for fraud prevention, safety, legal claims or compliance with law. After physical deletion, the conversation cannot be restored. Backups are overwritten according to technical cycles.
When data is no longer needed, it is deleted or anonymized unless continued retention is legally required. A specific retention explanation may be provided in response to a request because the period depends on the record and any unresolved dispute.
7. Rights
Subject to GDPR conditions, you may request access, correction, deletion, restriction, portability or objection, and may withdraw consent without affecting earlier lawful processing. Requests should be sent to info@lemio.ee. We may need to verify identity. You may complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or another competent supervisory authority.
8. Automated decisions
LEMIO does not currently make decisions producing legal or similarly significant effects solely by automated processing. Technical filters may support security or moderation, but account and content restrictions can be requested for human review.
9. Children
LEMIO accounts are for persons aged 18 or over. If we reasonably learn that an account belongs to a younger person, we may restrict it and delete data unless retention is legally necessary.
10. Security
We use access controls, WordPress security mechanisms, password hashing, validation, nonces and other proportionate safeguards. No internet service can guarantee absolute security. Users should use a unique password and report suspected compromise promptly.
11. Changes
This policy is versioned. Material changes will be presented through the service or another appropriate channel. Acceptance records do not replace any consent required for a separate optional processing activity.