1. Introduction

At Finero Horizon, we are committed to protecting your privacy and enhancing your experience on our website, www.finerohorizon.com (“Website”). This combined Cookie Policy and Privacy Terms document outlines how we use cookies to improve our Website and how we process your personal data in compliance with the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679), the e-Privacy Directive (Directive 2002/58/EC as amended), and Estonian law. By continuing to use our Website or engaging with our services, you consent to the practices described herein.

2. Cookie Policy

2.1 What Are Cookies?

Cookies are small text files stored on your device (e.g., computer, tablet, smartphone) through your browser when you visit our Website. They help us track activity, improve functionality, and gather usage statistics.

2.2 Types of Cookies We Use

We use the following cookies on our Website:

2.2.1 Essential Cookies

These are necessary for the Website to function properly and cannot be disabled. They support core features like navigation and secure access. PHPSESSID Supports user session functionality; essential for Website operation. End of session Unique identifier

2.2.2 Analytical Cookies

These optional cookies collect statistical data (e.g., page views, navigation patterns) to improve our Website. We use Google Analytics for this purpose. escription/Type Expiration Data Used

_ga Used by Google Analytics to evaluate user visits and generate reports on Website activi

2.3 Managing Cookies

You can control cookies by adjusting your browser settings to block, delete, or prompt for permission before accepting them. Visit www.allaboutcookies.org for more details. Disabling essential cookies may impair Website functionality. To opt out of Google Analytics, install the Google Analytics OptOut Browser Add-On at Google Analytics Support.

2.4 Third-Party Data Sharing

Analytical cookies may transfer data to third parties (e.g., Google Analytics in the USA) outside the European Economic Area (EEA). We ensure GDPR compliance through standard contractual clauses, though data protection standards may differ outside the EEA. We assess the conditions for processing and storing such data carefully.

2.5 Cookie Policy Updates

We may update this Cookie Policy periodically. Changes will be posted here and take effect immediately upon publication. We recommend reviewing this section regularly, as we cannot notify users directly of updates.

3. Privacy Terms

3.1 Personal Data We Collect

We do not collect personal data that identifies you or your device unless you choose to contact us (e.g., via email), providing details such as your name or email address. In such cases, we process only the data you provide. Additionally, we may collect:

  • Contact details (e.g., email, phone number) if you request services or subscribe to updates.
  • Business-related data (e.g., company name, role) when engaging with our consultancy services.
  • Website usage data (e.g., IP address, browser type) via cookies, as outlined above.

This data is processed only to the extent necessary for service delivery, client relationship management, marketing, and compliance with legal obligations.

3.2 Legal Basis for Processing

We process your personal data based on:

  • Contractual necessity (e.g., to fulfill consultancy agreements).
  • Your consent (e.g., subscribing to newsletters or contacting us).
  • Legitimate interests (e.g., improving our services, direct marketing to existing clients unless you object).
  • Legal obligations (e.g., Anti-Money Laundering compliance).

3.3 Third-Party Data

We may process data about third parties (e.g., business contacts) provided by you, limited to what is necessary for our services, in compliance with GDPR.

3.4 Direct Marketing

If you are a client and have not objected, we may use your name, email, and phone number for direct marketing (e.g., newsletters, event invitations) based on our legitimate interest. You can unsubscribe at any time by clicking the “Unsubscribe” link in emails or emailing info@finerohorizon.com.

3.5 Data Retention

Your data is retained for the duration of our engagement and as required by law (e.g., accounting purposes for 7 years under Estonian law) or to protect our rights (e.g., defending claims). We may retain data longer if there is a legal dispute, suspicion of illegal activity, or for backup purposes, deleting it within a reasonable time after the retention period ends.

3.6 Data Security and Transfers

We use secure methods to protect your data and may share it with authorized processors (e.g., IT providers, marketing platforms) or our partners within the EEA for service delivery. Data may be transferred outside the EEA (e.g., to Google Analytics in the USA) with appropriate safeguards under GDPR, though protection levels may vary.

3.7 Your Rights

Under GDPR, you have the right to:

  • Access, correct, or delete your personal data.
  • Restrict or object to processing (e.g., marketing).
  • Request data portability for data processed under consent or contract.
  • Withdraw consent at any time (without affecting prior lawful processing).

To exercise these rights, contact us at info@finerohorizon.com. You may also lodge a complaint with the Estonian Data Protection Inspectorate.

3.8 Privacy Terms Updates

We may update this Privacy Terms section as needed. Changes will be posted here and take effect immediately upon publication. Please review this section periodically for updates.

4. Contact Information

For questions about this Cookie Policy or Privacy Terms, please contact us at:

  • Email: info@finerohorizon.com
  • Website: www.finerohorizon.com