Last updated: 3 August 2026

This Privacy Policy explains how RULL COMMERCE OÜ, operating under the brand name Golden Palma (“Golden Palma”, “we”, “us” or “our”), collects, uses, stores and protects personal data when you visit goldenpalma.com, contact us, book a consultation or purchase our services. The website and its content are owned and operated by the site creator as a private individual (Ingrid J.), and all rights to the website design, structure and materials belong to the owner unless otherwise stated.

1. Data Controller

The controller responsible for the processing of your personal data is:

RULL COMMERCE OÜ
Registration code:14509167
Registered address:Pae tn 68-45, 13620
Estonia
Email: goldenpalma@outlook.com

2. Personal Data We Collect

Depending on how you interact with our website and services, we may collect the following categories of personal data.

Contact and enquiry data

When you contact us, submit a form, send us a message or request a consultation, we may collect:

• your name;

• email address;

• telephone number;

• company or brand name;

• country or market of interest;

• information included in your message or enquiry;

• preferred consultation date and time.

Please do not include sensitive personal information in free-text message fields unless it is strictly necessary for your request.

Consultation and service data

When you book a consultation or purchase a service, we may process:

• consultation and appointment details;

• information required to understand and provide the requested service;

• communication history;

• contract and order information;

• invoice and payment status;

• information reasonably required to fulfil our contractual obligations.

Payment and billing data

When you purchase a service, payments may be processed by a third-party payment provider, bank or payment platform.

We may receive limited transaction information, such as:

• customer or company name;

• billing address;

• transaction reference;

• amount paid;

• payment date;

• payment status.

We do not normally receive or store complete payment card details. Such information is processed directly by the relevant payment provider.

Technical and website usage data

When you visit our website, certain technical information may be collected automatically, including:

• IP address;

• approximate location derived from the IP address;

• browser type and version;

• device type and operating system;

• referring website or advertising campaign;

• pages visited;

• buttons and links clicked;

• date, time and duration of the visit;

• cookie identifiers and similar online identifiers.

Some of this information is collected only where you have provided the required consent through our cookie banner.

3. How We Use Personal Data

We may use personal data to:

• respond to enquiries and requests;

• arrange and conduct consultations;

• prepare offers and service proposals;

• enter into and perform service agreements;

• process orders and payments;

• issue invoices and maintain accounting records;

• provide Amazon account registration, brand registration, consulting, launch, design and related agency services;

• communicate with customers about purchased services;

• maintain the security and functionality of our website;

• understand how visitors use the website;

• measure the performance of our advertising;

• improve our website, services and customer experience;

• prevent fraud, misuse and security incidents;

• comply with legal, accounting and tax obligations;

• establish, exercise or defend legal claims.

We do not sell personal data.

4. Legal Bases for Processing

We process personal data under one or more of the following legal bases.

Steps before entering into a contract and performance of a contract

We process contact, consultation, order and service information where necessary to respond to your request, prepare an offer, provide a consultation or perform an agreement with you.

Consent

We rely on consent when required for:

• analytics cookies;

• advertising and marketing cookies;

• advertising measurement;

• personalised advertising;

• other non-essential tracking technologies.

You may withdraw your consent at any time through the cookie settings available on our website. Withdrawal does not affect processing that took place before consent was withdrawn.

Legitimate interests

We may process limited personal data where necessary for our legitimate interests, including:

• operating and securing the website;

• preventing fraud and misuse;

• responding to business enquiries;

• managing customer relationships;

• protecting our legal rights;

• improving the quality and efficiency of our services.

We consider whether these interests are overridden by your privacy rights before relying on this legal basis.

Legal obligations

We process and retain certain information where required by accounting, taxation, consumer protection or other applicable laws.

5. Cookies and Analytics

Our website may use cookies and similar technologies for:

• essential website functionality;

• remembering privacy preferences;

• website analytics;

• advertising measurement;

• understanding which campaigns lead visitors to the website;

• measuring enquiries, bookings and other conversions.

Non-essential analytics and advertising technologies are activated only in accordance with the consent choices available through our cookie banner.

Further information about the cookies and technologies used on this website is available in our Cookie Policy.

6. Service Providers and Data Recipients

We may share personal data with trusted service providers where necessary to operate our website, communicate with customers and provide our services.

These providers may include:

• Framer, for website hosting and website functionality;

• Google, including Google Analytics, Google Tag Manager and Google Ads;

• Calendly or another scheduling platform, for consultation bookings;

• Zoom, for online consultations and video meetings;

• Microsoft, including Outlook and related business communication services;

• WhatsApp, operated by Meta, for customer communication;

• Telegram, where you choose to contact us through Telegram;

• payment providers, banks and payment platforms used to process payments;

• accounting, legal, compliance and professional advisers;

• IT, hosting, security and technical service providers;

• public authorities where disclosure is required by law.

Service providers may process personal data only for the purposes for which the data is provided and in accordance with their contractual and legal obligations.

7. International Data Transfers

Some service providers may process personal data outside Estonia or outside the European Economic Area.

Where required, international transfers are protected through appropriate safeguards, such as:

• an adequacy decision adopted by the European Commission;

• Standard Contractual Clauses approved by the European Commission;

• other lawful transfer mechanisms recognised under applicable data protection legislation.

8. Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected.

In general:

• enquiries and consultation requests may be retained for up to two years after the last communication;

• customer and service information may be retained for the duration of the contractual relationship and applicable limitation periods;

• accounting, invoice, transaction and tax documentation is normally retained for at least seven years or for another period required by applicable law;

• technical, analytics and advertising data is retained in accordance with our configured retention periods, consent choices and the policies of the relevant service providers;

• information required for a legal dispute may be retained until the dispute or applicable limitation period has ended.

Data may be deleted or anonymised earlier where it is no longer required.

9. Your Data Protection Rights

Subject to the conditions of applicable data protection law, you may have the right to:

• request access to your personal data;

• request correction of inaccurate or incomplete data;

• request deletion of your personal data;

• request restriction of processing;

• object to processing based on legitimate interests;

• withdraw your consent at any time;

• receive certain personal data in a structured, commonly used and machine-readable format;

• request that your data be transferred to another controller where applicable;

• lodge a complaint with a data protection supervisory authority.

Where processing is based on consent, withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise your rights, contact us at goldenpalma@outlook.com. We may need to verify your identity before responding to a request.

You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate — Andmekaitse Inspektsioon, or with the supervisory authority in your country of residence.

10. Data Security

We use reasonable technical and organisational measures designed to protect personal data against:

• unauthorised access;

• accidental loss;

• unlawful use;

• alteration;

• disclosure;

• destruction.

However, no website, communication method or data storage system can be guaranteed to be completely secure.

11. Third-Party Websites and Communication Platforms

Our website may contain links to third-party websites and communication platforms, including WhatsApp, Telegram, Calendly, Zoom and social media services.

When you leave our website or use a third-party platform, that provider may process your data under its own privacy policy. We are not responsible for the privacy practices of independent third-party services.

12. Children’s Privacy

Our website and services are intended for businesses and adults. We do not knowingly collect personal data from children.

If you believe that a child has provided personal data to us, please contact us so that we can review and, where appropriate, delete the information.

13. Changes to This Privacy Policy

We may update this Privacy Policy when our services, website technologies or legal obligations change.

The latest version will be published on this page. The “Last updated” date at the top indicates when the policy was most recently revised.

14. Contact Us

For questions about this Privacy Policy or the processing of your personal data, contact:

RULL COMMERCE OÜ
Operating under the brand name Golden Palma
Registration code: 14509167
Registered address: Pae tn 68-45, 13620
Estonia
Email: goldenpalma@outlook.com