PRIVACY & INTELLECTUAL PROPERTY POLICY

Last updated: August 2026

This Privacy Policy explains how Soulani OÜ (“Soulani”, “we”, “us” or “our”) collects, uses and protects personal data when you visit soulani.com, make a purchase from our Online Store, contact us or otherwise interact with our services.

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable Estonian data protection legislation.

1. Data Controller

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

Soulani OÜ
Registered address: Linavästriku vkt 25, Laulasmaa 76702, Estonia
E-mail: info@soulani.com
Website: soulani.com

Company registration number: 16836574

2. Personal Data We Collect

Order and Contact Information

When you place an order or contact us, we may collect:

• your first and last name;
• e-mail address;
• billing and delivery address;
• information necessary for delivery, such as parcel locker or pickup point details;
• order details and purchase history;
• payment status and transaction-related information;
• communications between you and Soulani.

Technical and Website Usage Information

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

• IP address;
• browser and device information;
• website usage information;
• pages visited and interactions with the website;
• approximate location derived from technical information;
• referring website or source;
• cookie identifiers and similar technology information.

The exact information collected depends on the technologies enabled on the website and, where required, your cookie preferences.

Marketing Information

Where you have consented to marketing or where electronic marketing is otherwise permitted by applicable law, we may process:

• your name, where provided;
• e-mail address;
• marketing preferences;
• information relating to your interaction with our marketing communications;
• information relating to interactions with our advertising campaigns, where applicable.

      3. Why We Process Personal Data

We process personal data for the following purposes and on the following legal bases:

Processing and Fulfilling Orders

We process the information necessary to accept, process, deliver and manage your order.

Legal basis: performance of a contract or taking steps at your request before entering into a contract.

Payments

We process information necessary to administer and confirm payments.

Payments may be processed by third-party payment service providers, including Montonio.

Legal basis: performance of a contract and compliance with applicable legal obligations.

Delivery

We share information necessary for delivery with the relevant logistics and delivery service providers.

Legal basis: performance of a contract.

Customer Service

We process information contained in enquiries, complaints, returns and other communications in order to provide customer service and resolve issues.

Legal basis: performance of a contract and, where applicable, our legitimate interest in providing customer service and managing our business.

Accounting and Legal Obligations

Certain order and transaction information is processed and retained in order to comply with accounting, tax and other legal obligations.

Legal basis: compliance with a legal obligation.

Website Security and Functionality

Certain technical data may be processed where necessary to operate, maintain and protect our website, prevent abuse and ensure the security of our services.

Legal basis: our legitimate interests in maintaining a secure and functional website and, where applicable, compliance with legal obligations.

Analytics and Advertising

With your consent, we may use analytics and advertising technologies to understand how visitors use our website, measure the performance of our marketing campaigns and show more relevant advertising.

Legal basis: consent, where required by applicable law.

You can withdraw or modify your consent at any time through the cookie settings available on our website.

Marketing

We may send newsletters, product news, offers and other electronic marketing communications where you have given the required consent or where another lawful basis for such communication applies.

You may withdraw your consent or unsubscribe from marketing communications at any time.

4. Cookies and Similar Technologies

Soulani.com uses cookies and similar technologies.

Some cookies are necessary for the basic functioning, security and operation of the Online Store. These may be used without separate consent where permitted by law.

Other cookies and similar technologies, including those used for analytics, advertising and marketing, are used only where permitted by applicable law and, where required, after you have provided your consent.

Depending on your choices, cookies and similar technologies may be used to:

• keep the website and Online Store functioning correctly;
• remember your preferences;
• maintain shopping cart and checkout functionality;
• understand how visitors use our website;
• measure website traffic and performance;
• measure the effectiveness of advertising campaigns;
• support advertising and remarketing activities; and
• help prevent spam, fraud and abuse.

You can accept, reject or manage non-essential cookies through the cookie consent settings available on our website.

Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn.

More detailed information about individual cookies, their providers, purposes and retention periods may be provided through the website’s cookie consent management tool or a separate Cookie Policy.

5. Google Analytics

We use Google Analytics to help us understand how visitors use soulani.com.

Subject to your cookie preferences and consent, Google Analytics may process information such as:

• pages visited;
• interactions with the website;
• approximate location;
• browser and device information;
• referral source;
• IP address and related technical information; and
• cookie or similar identifiers.

We use this information to analyse website traffic, understand how our Online Store is used and improve our website and services.

Where consent is required, Google Analytics will be activated only after the relevant consent has been provided.

Google may process information in accordance with its own privacy policies and data protection terms.

6. Meta Pixel and Facebook/Instagram Integration

Soulani may use Meta Pixel and integrations with Facebook and Instagram, services provided by Meta.

Subject to your consent, these technologies may allow us to:

• understand how visitors interact with our website after seeing or clicking Soulani content or advertisements on Facebook or Instagram;
• measure the effectiveness of advertising campaigns;
• create advertising audiences;
• support remarketing and personalised advertising; and
• better understand the performance of our social media marketing.

Depending on your interaction with our website and Meta services, information such as website activity, browser and device information, cookie identifiers and information relating to advertising interactions may be processed.

Where required by applicable law, Meta Pixel and other non-essential Meta tracking technologies will be activated only after you have provided the relevant consent.

Meta may process personal data in accordance with its own privacy policies and data protection terms.

7. Google Ads

We may use Google Ads to advertise Soulani products and measure the effectiveness of our advertising campaigns.

Subject to your consent, Google Ads technologies may be used for:

• advertising conversion measurement;
• understanding whether an advertisement resulted in a visit or purchase;
• measuring advertising campaign performance;
• remarketing; and
• displaying more relevant advertisements.

These technologies may process information about your interactions with our website and advertisements, along with device, browser, cookie and similar identifier information.

Where required by applicable law, Google Ads advertising and tracking technologies will be activated only after you have provided the relevant consent.

Google may process personal data in accordance with its own privacy policies and data protection terms.

8. Google reCAPTCHA

We may use Google reCAPTCHA to protect forms, account functions, checkout processes and other areas of our website against spam, automated abuse and malicious activity.

reCAPTCHA may process technical and usage information necessary to determine whether an interaction is likely to originate from a human user or an automated system.

This may include information such as:

• IP address;
• browser and device information;
• interaction information; and
• other technical information necessary for security and fraud prevention.

The legal basis and consent requirements applicable to reCAPTCHA depend on how the technology is implemented and the information processed.

Where consent is legally required for a particular implementation, reCAPTCHA will be used in accordance with those consent requirements.

Google may process information collected through reCAPTCHA in accordance with its own privacy policies and terms.

9. Payment Processing

Payments made through the Online Store may be processed by Montonio and the payment service providers available through its payment solution.

Soulani does not receive or store the Customer’s full online banking or payment card credentials.

Payment providers process personal data in accordance with their own privacy policies and applicable data protection legislation.

10. Delivery Service Providers

In order to fulfill an order, we may provide the relevant delivery service provider with the information necessary to deliver the parcel, including the Customer’s name, contact details, delivery address or selected pickup location.

Depending on the destination and selected delivery method, delivery may be carried out through Montonio’s logistics solutions or through delivery service providers contracted by Soulani.

Only information necessary for arranging and completing delivery is shared.

11. Other Recipients of Personal Data

We may share personal data with trusted service providers where this is necessary for operating our Online Store and providing our services.

These may include:

• payment service providers;
• logistics and delivery companies;
• website hosting and technical service providers;
• e-commerce platform and website service providers;
• accounting and financial service providers;
• analytics providers, including Google;
• advertising providers, including Google and Meta;
• social media platforms, including Facebook and Instagram;
• security and anti-spam service providers;
• e-mail and newsletter service providers, where applicable;
• professional advisers; and
• public authorities where required by law.

Service providers may process personal data only in accordance with applicable data protection requirements and their respective roles under data protection law.

We do not sell personal data to third parties.

12. International Transfers of Personal Data

Some of our service providers, including international technology providers, may process personal data outside Estonia or the European Economic Area (EEA).

Where personal data is transferred outside the EEA, the transfer will take place using an appropriate legal mechanism as required by the GDPR.

This may include:

• an adequacy decision adopted by the European Commission;
• Standard Contractual Clauses approved by the European Commission;
• or another lawful transfer mechanism permitted under applicable data protection law.

 13. How Long We Keep Personal Data

We retain personal data only for as long as necessary for the purposes for which it was collected or as required by applicable law.

Order, payment and accounting information may be retained for the period required under applicable accounting and tax legislation.

Customer service communications may be retained for as long as reasonably necessary to resolve enquiries, protect our legal interests and manage potential claims.

Marketing information is generally retained until you withdraw your consent, unsubscribe or the information is no longer necessary for the relevant marketing purpose.

Cookie, analytics and advertising information is retained according to the applicable technology, cookie settings and retention periods.

After the relevant retention period expires, personal data will be deleted or anonymised unless continued retention is required or permitted by law.

14. Your Data Protection Rights

Subject to the conditions provided by applicable data protection law, you have the right to:

• request access to your personal data;
• request correction of inaccurate or incomplete personal data;
• request deletion of your personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• receive certain personal data in a structured, commonly used and machine-readable format and request data portability;
• withdraw consent at any time where processing is based on consent; and
• lodge a complaint with a competent data protection supervisory authority.

Withdrawing consent does not affect the lawfulness of processing carried out before the consent was withdrawn.

To exercise your rights, contact us at info@soulani.com.

In Estonia, the competent supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).

15. Security

We take reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.

Access to personal data is limited to persons and service providers who require access for legitimate business purposes.

However, no method of transmitting or storing information electronically can guarantee absolute security.

16. Children’s Personal Data

Our Online Store is not intended to knowingly collect personal data directly from children for marketing purposes.

Where a purchase is made on behalf of a child, the personal data necessary for the transaction should be provided by a parent, guardian or other person legally entitled to make the purchase.

17. Changes to This Privacy Policy

We may update this Privacy Policy where necessary to reflect changes to our services, website, technologies or legal requirements.

The latest version will always be available on soulani.com.

INTELLECTUAL PROPERTY

18. Ownership and Copyright

The Soulani brand and the creative content presented on soulani.com are protected by applicable copyright and intellectual property laws.

Unless otherwise stated, all original content displayed on the website, including but not limited to:

• product designs and artwork;
• illustrations, drawings and graphic elements;
• prints, patterns and visual concepts;
• product photographs and other photography;
• product presentations and creative compositions;
• logos and brand elements;
• website graphics and visual materials;
• written product descriptions and other original texts; and
• other original creative content

is owned by Soulani OÜ or is used by Soulani under appropriate rights, permissions or licences.

Copyright and other intellectual property rights remain with Soulani OÜ and/or the respective rights holder.

Purchasing a Soulani product does not transfer any copyright, design rights or other intellectual property rights relating to the product, artwork or design to the Customer.

19. Prohibited Use

Soulani’s copyrighted and protected content may not be copied, reproduced, modified, adapted, distributed, published, uploaded, transmitted, displayed, sold, licensed or otherwise commercially exploited without prior written permission from Soulani OÜ or the relevant rights holder.

In particular, without prior written permission, it is prohibited to:

• copy or reproduce Soulani product designs or artwork;
• manufacture or sell products using Soulani designs, artwork or substantially copied versions of them;
• copy, download or reuse Soulani product photographs for commercial purposes;
• use Soulani photographs, artwork or other creative materials to advertise or sell other products;
• modify or create commercial derivative works based on Soulani artwork or designs;
• remove copyright notices, watermarks or other rights information;
• present Soulani content, designs or photographs as the work of another person or business.

Nothing on this website grants any licence or right to use Soulani’s intellectual property except as expressly permitted in writing.

This section does not restrict uses that are expressly permitted without the rights holder’s authorisation under applicable copyright law.

20. Soulani Designs and Artwork

Soulani products may feature original artwork and designs created specifically for the Soulani brand.

Such artwork and designs are protected by copyright and, where applicable, other intellectual property rights.

The physical purchase of a product featuring Soulani artwork gives the Customer ownership of that individual physical product only.

Purchasing a Soulani product does not grant the Customer any right to reproduce, copy, modify, manufacture, distribute, license, sell or otherwise commercially exploit the artwork, illustration, print, pattern or design featured on the product.

Unauthorised reproduction or commercial use of Soulani artwork, product designs, photographs or other protected materials may constitute an infringement of intellectual property rights.

Soulani OÜ reserves the right to take appropriate legal action to protect its intellectual property rights.

21. Use of Soulani Images and Content

Images and other content displayed on soulani.com may be viewed and shared for ordinary personal, non-commercial purposes only to the extent permitted by applicable law.

Soulani product photographs, campaign images, artwork, illustrations, graphics and other protected materials may not be used for commercial purposes, copied for use in another online store, marketplace or website, or used to manufacture, advertise or sell other products without prior written permission.

The fact that an image, design or other material is publicly accessible on soulani.com or Soulani’s social media channels does not mean that it is free to use.

22. Permission to Use Soulani Content

If you would like to use Soulani photographs, artwork, designs or other protected content for editorial, commercial, collaboration or other purposes, please contact:

info@soulani.com

Permission must be obtained in writing before the relevant content is used.

23. Contact

For questions regarding this Privacy Policy, personal data or the use of Soulani’s intellectual property, please contact:

Soulani OÜ
E-mail: info@soulani.com
Website: soulani.com