Introduction
In our mission to make commerce better for everyone at Golden Door, we collect and use information about you,
This Privacy Policy will help you better understand how we collect, use, and share your personal information. If we change our privacy practices, we may update this privacy policy. If any changes are significant, we will let you know (for example, through the Golden Door admin or by email).

Our values
Trust is the foundation of the Golden Door platform and includes trusting us to do the right thing with your information. Three main values guide us as we develop our products and services. These values should help you better understand how we think about your information and privacy.

Your information belongs to you
We carefully analyze what types of information we need to provide our services, and we try to limit the information we collect to only what we really need. Where possible, we delete or anonymize this information when we no longer need it. When building and improving our products, our engineers work closely with our privacy and security teams to build with privacy in mind. In all of this work our guiding principle is that your information belongs to you, and we aim to only use your information to your benefit.

We protect your information from others
If a third party requests your personal information, we will refuse to share it unless you give us permission or we are legally required. When we are legally required to share your personal information, we will tell you in advance, unless we are legally forbidden.

We help merchants and partners meet their privacy obligations
We provide detailed FAQs, documentation and whitepapers covering the most important privacy topics, and respond to privacy-related questions we receive.

Why we process your information
We generally process your information when we need to do so to fulfill a contractual obligation (for example, to process your subscription payments to use the Golden Door or Odoo platform), or where we or someone we work with needs to use your personal information for a reason related to their business (for example, to provide you with a service). European law calls these reasons “legitimate interests.” These “legitimate interests” include:

- helping merchants find and use apps through our app store
- preventing risk and fraud
- providing reporting and analytics
- providing and improving our products and services
- answering questions or providing other types of support
- testing out features or additional services
- assisting with marketing, advertising, or other communications

We only process personal information for these “legitimate interests” after considering the potential risks to your privacy—for example, by providing clear transparency into our privacy practices, offering you control over your personal information where appropriate, limiting the information we keep, limiting what we do with your information, who we send your information to, how long we keep your information, or the technical measures we use to protect your information.

One of the ways in which we are able to help merchants using Golden Door / Odoo is by using techniques like “machine learning” (European law refers to this as “automated decision-making”) to help us improve our services. When we use machine learning, we either: (1) still have a human being involved in the process (and so are not fully automated); or (2) use machine learning in ways that don’t have significant privacy implications (for example, reordering how apps might appear when you visit the app store).

We may process your personal information where you have provided your consent. In particular, where we cannot rely on an alternative legal basis for processing, where your data is sourced and it already comes with consent or where we are required by law to ask for your consent in the context of some of our sales and marketing activities. At any time, you have a right to withdraw your consent by changing your communication choices, opting out from our communications or by contacting us.

Your rights over your information
We believe you should be able to access and control your personal information no matter where you live. Depending on how you use Golden Door website, you may have the right to request access to, correct, amend, delete, port to another service provider, restrict, or object to certain uses of your personal information (for example, direct marketing). We will not charge you more or provide you with a different level of service if you exercise any of these rights.

If you buy something from a Golden Door Odoo -powered store and wish to exercise these rights over information about your purchase, you need to directly contact the merchant you interacted with. We are only a processor on their behalf, and cannot decide how to process their information. We will of course help our merchants to fulfill these requests by giving them the tools to do so and by answering their questions.

If you are a merchant, partner, Shop user, Golden Door employee, or other individual that Golden Door has a direct relationship with, please submit your data subject request through our online portal. Please note that if you send us a request relating to your personal information, we have to make sure that it is you before we can respond. In order to do so, we may use a third party to collect and verify identification documents.

If you are not happy with our response to a request, you can contact us to resolve the issue. You also have the right to contact your local data protection or privacy authority at any time.

Finally, because there is no common understanding about what a “Do Not Track” signal is supposed to mean, we don’t respond to those signals in any particular way.

Where we send your information
We are a Estonian company, but we work with and process data about individuals across the world. To operate our business, we may send your personal information outside of your state, province, or country. This data may be subject to the laws of the countries where we send it. When we send your information across borders, we take steps to protect your information, and we try to only send your information to countries that have strong data protection laws.

Transfers outside of Europe and Switzerland
If you are in Europe, the UK, or Switzerland, we don´t send your personal information outside of Europe, we do so in accordance with European law.

Finally, while we do what we can to protect your information, we may at times be legally required to disclose your personal information (for example, if we receive a valid court order). For information about how we respond to such orders, please review our Guidelines for Legal Requests.

How we protect your information
Our teams work tirelessly to protect your information, and to ensure the security and integrity of our platform. We also have independent auditors assess the security of our data storage and systems that process financial information. However, we all know that no method of transmission over the Internet, and method of electronic storage, can be 100% secure. This means we cannot guarantee the absolute security of your personal information.

How we use “cookies” and other tracking technologies
We use cookies and similar tracking technologies on our website and when providing our services. For more information about how we use these technologies, including a list of other companies that place cookies on our sites, a list of cookies that we place when we power a merchant’s store, and an explanation of how you can opt out of certain types of cookies, please see our Cookie Policy.

How you can reach us
If you would like to ask about, make a request relating to, or complain about how we process your personal information, please contact Golden Door Support, or mail us at one of the addresses below. If you would like to submit a legally binding request to demand someone else’s personal information (for example, if you have a subpoena or court order), please review our Guidelines for Legal Requests.

Golden Door Estonia OÜ
ATTN: Chief Privacy Officer
Parda 8
Fift floor
10151 Tallinn
Estonia