Privacy & Cookies Policy

Version 2.0  |  Effective date: September 2026  |  Next review: September 2027

1. About this Privacy Policy

The British-Estonian Chamber of Commerce (“BECC”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy & Cookies Policy explains how BECC collects, uses, stores and protects personal data when you:

• become or represent a BECC member;
• attend or register for a BECC event;
• communicate with BECC;
• subscribe to BECC newsletters or other communications;
• use the BECC website;
• interact with BECC through social media;
• participate in BECC activities, surveys or business networking;
• represent a company or organisation that has a relationship with BECC; or
• otherwise provide personal information to BECC.

This Policy explains what information we collect, why we collect it, the legal basis on which we process it, who may receive it, how long we retain it and the rights available to you.

BECC processes personal data in accordance with the EU General Data Protection Regulation (“GDPR”), Estonian data-protection legislation, the UK GDPR and the UK Data Protection Act 2018 (as amended, including by the Data (Use and Access) Act 2025) where they apply, and other applicable privacy laws.

2. Who is responsible for your personal data?

The data controller is:

British-Estonian Chamber of Commerce

Briti Esti Kaubanduskoda MTÜ

Kopli 90-21, Tallinn 10416, Harjumaa

Estonia

Email: legal@becc.ee

Website: https://becc.ee

BECC is responsible for deciding how and why your personal data are processed.

BECC has considered the requirements of Article 37 GDPR and, based on the nature and scale of its activities, does not currently consider that it is required to appoint a formal Data Protection Officer (DPO). If this assessment changes, BECC will update this Policy and publish the appropriate DPO contact details.

Questions concerning the processing of personal data should be sent to legal@becc.ee

Where required under Article 27 UK GDPR, BECC’s representative in the United Kingdom is: [priviness limited, 7 Hungate, Beccles, NR34 9TT, United Kingdom, info@priviness.eu].

3. What personal data do we collect?

The information we collect depends on your relationship with BECC.

3.1 Identity and business information

• name;
• job title or position;
• company or organisation;
• business address;
• business telephone number;
• business email address;
• professional biography or profile information;
• professional interests or areas of business activity.

3.2 Membership information

For members and their representatives we may collect:

• membership category;
• membership start and renewal dates;
• membership correspondence;
• event attendance;
• member preferences;
• information required to administer membership;
• invoicing and payment information; and
• records of communications with BECC.

3.3 Event information

When you register for or attend a BECC event we may collect:

• name;
• company and position;
• contact details;
• registration and attendance information;
• dietary requirements where voluntarily provided;
• payment information where applicable; and
• information relating to your participation in the event.

We will only request special-category information, where there is a specific reason to do so and an appropriate legal basis exists.

3.4 Communications

If you contact BECC by email, telephone, website form, social media or another method, we may retain information contained in that communication and information necessary to respond to you.

3.5 Website information

When you use the BECC website, we may collect technical information such as:

• IP address;
• browser type;
• device type;
• operating system;
• pages visited;
• approximate time and duration of visits;
• referring website;
• information concerning website interactions; and
• cookie identifiers and similar technical information.

The collection of this information depends on the cookies and other technologies active on the website and, where required, your consent.

If you sign in to a BECC user area using a third-party sign-in service such as Google Sign-In or Facebook Login, we receive basic information from that provider (such as your name and email address) to create or access your account.

4. Where do we obtain personal data?

We may obtain personal data:

1. directly from you;
2. from your employer or organisation;
3. when you register for a BECC event;
4. when you apply for or renew BECC membership;
5. when you subscribe to BECC communications;
6. when you contact BECC;
7. through the BECC website;
8. from publicly available professional or business sources;
9. from business networking platforms such as LinkedIn;
10. from organisations or individuals who introduce or refer you to BECC; and
11. from other BECC members or event participants where appropriate.

Where we obtain personal data from publicly available or third-party sources, we will use that information only for legitimate and relevant BECC activities and in accordance with applicable data-protection law.

Where required by GDPR, we will provide the information required under Article 14 concerning the source and use of such personal data.

5. Why do we process personal data?

5.1 Membership administration

We use personal data to:

• process membership applications;
• administer membership;
• communicate with members;
• maintain membership records;
• issue invoices;
• manage membership renewals;
• provide member services and benefits;
• communicate information relevant to members; and
• administer BECC governance and meetings.

5.2 Events

We use personal data to:

• administer event registrations;
• communicate event information;
• manage attendance;
• arrange catering and other event requirements;
• process event payments;
• facilitate networking;
• maintain records of BECC activities; and
• communicate information about future BECC events.

5.3 Business networking

As a chamber of commerce, BECC facilitates business relationships between members, companies, government representatives, diplomatic organisations and other stakeholders. We may process professional contact information to:

• introduce businesses and individuals;
• facilitate networking;
• communicate business opportunities;
• support UK–Estonia commercial relationships;
• provide relevant business information; and
• maintain appropriate business-contact records.

5.4 Communications and newsletters

We may send members and subscribers newsletters, event invitations, business updates, information about BECC activities, information about the products, services and offers of BECC members, relevant UK–Estonia business developments and other communications relevant to the relationship with BECC. Marketing communications will include an appropriate method for unsubscribing.

5.5 Governance and administration

We may process personal data to administer the BECC Board, organise General Meetings and other governance activities, maintain statutory and organisational records, manage complaints, administer contracts, maintain financial records and comply with legal and regulatory requirements.

5.6 Website administration

We process technical information to operate and secure the BECC website, resolve technical problems, understand website usage, improve the website and maintain appropriate website records.

6. What are our legal bases for processing?

Under GDPR, BECC must have a lawful basis for processing personal data. Depending on the circumstances, BECC may rely on one or more of the following:

Contract

Processing may be necessary to enter into or perform a membership or other agreement with you, for example administering membership, processing event registrations, providing membership benefits and administering payments.

Legal obligation

Processing may be necessary for BECC to comply with a legal obligation, for example accounting and tax records, statutory reporting or responding to lawful requests from competent authorities.

Legitimate interests

BECC may process personal data where necessary for its legitimate interests, provided those interests are not overridden by your rights and freedoms. These interests may include operating and administering the Chamber, managing member relationships, communicating with members and stakeholders, organising business events, facilitating professional networking, promoting UK–Estonia commercial relations, developing the membership network, maintaining business records, protecting systems and property, promoting BECC activities, securing the BECC website and remembering users’ choices, referring enquiries to relevant members, and sending direct marketing about BECC and its members’ events, products and services.

Where BECC relies on legitimate interests, we will consider whether the processing is proportionate and whether your interests or fundamental rights override those interests.

Consent

BECC will rely on your consent where consent is required by law. This may apply to certain marketing communications, non-essential cookies, photographs or other specific processing activities. Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

6A. Do you have to provide personal data?

Some personal data is needed to enter into or perform an agreement with you, for example to apply for membership, register for an event or process a payment, or to deal with an enquiry about a member’s products or services. If you do not provide it, BECC (or the relevant member) may not be able to process your application, registration or request. Where providing information is optional, such as dietary requirements or a professional biography, we will make this clear when we collect it.

7. Marketing communications

BECC distinguishes between communications necessary to administer an existing relationship and marketing communications.

Member and administrative communications

BECC may contact members concerning membership, invoices, renewals, AGM notices, governance, event registrations, important changes to BECC services and other communications necessary to administer the relationship. These are not marketing and cannot necessarily be stopped while you remain a member or participant.

Marketing communications

Marketing may include newsletters, invitations to future events, information about BECC activities, information about the products, services and offers of BECC members, relevant business opportunities and other promotional information. Where consent is required, BECC will obtain it before sending such communications. Where consent is not required, BECC relies on its legitimate interests, for example when sending marketing to business contacts, or to members, event participants and enquirers about events and services similar to those they have already shown an interest in. In those cases you will be given a simple, free opportunity to opt out when your details are collected. Every marketing email will contain an appropriate unsubscribe facility, so you can opt out free of charge with each message. You may contact BECC at any time to change your marketing preferences.

8. Photographs and video at BECC events

BECC may photograph or record events organised or supported by BECC. Images and recordings may be used to document activities, report on events, promote future events, and communicate through newsletters, the website, social media, presentations and publications, or maintain historical records.

Where appropriate, BECC will provide notice at events that photography or filming is taking place. BECC will take reasonable steps to avoid using photographs in a misleading, inappropriate or offensive context. If you have a concern about an image or recording in which you are identifiable, contact BECC using the details in this Policy. Where consent is the appropriate legal basis for a particular use, BECC will obtain consent.

9. Publication of member information

BECC may publish certain information about members to promote the Chamber and its membership network. This may include company name, company description, company website, business sector, company logo and other business information supplied for publication.

BECC will not normally publish an individual’s private contact details without an appropriate legal basis. Where an individual’s name, position, photograph or professional biography is published, BECC will consider the applicable legal basis and context. Members should ensure that information supplied for publication is accurate and appropriate.

10. Sharing personal data

BECC may share personal data where necessary and lawful. Recipients may include BECC Board members and authorised volunteers; relevant BECC members, where your enquiry concerns their products or services or you ask to be introduced; event venues and suppliers; catering providers; IT and website service providers; email and newsletter providers; providers of website analytics, security and advertising technologies, such as Google (Google Analytics, reCAPTCHA) and Meta (Meta Pixel), where you have consented to the relevant cookies or they are strictly necessary; event-registration providers; accounting and financial service providers; professional advisers; insurers; government or regulatory authorities where legally required; diplomatic or business organisations where necessary for a particular activity; and other service providers acting on BECC’s instructions.

BECC will provide only information reasonably necessary for the relevant purpose. Where a third party processes personal data on behalf of BECC, appropriate contractual and data-protection safeguards will be required where GDPR requires them.

BECC does not sell personal data. BECC does not provide its membership database to third parties for their independent marketing purposes unless there is a lawful basis and individuals have been appropriately informed.

11. International transfers

Some BECC service providers may store or process personal data outside Estonia or the European Economic Area (EEA). Where personal data are transferred outside the EEA, BECC will ensure that an appropriate GDPR transfer mechanism is in place where required. This may include an European Commission adequacy decision, Standard Contractual Clauses, appropriate additional safeguards or another lawful transfer mechanism permitted under GDPR. Some of these providers, including Google and Meta, are based in the United States; transfers to them may rely on the EU–US Data Privacy Framework (for certified organisations) or Standard Contractual Clauses. Transfers to the United Kingdom rely on the European Commission’s adequacy decision for the UK. The same requirements apply where BECC shares an enquiry with a member located outside the EEA. You may contact legal@becc.ee to request details of the safeguards used and how to obtain a copy.

BECC will not rely on blanket consent to justify international transfers where another appropriate GDPR transfer mechanism is required.

12. Data security

BECC takes appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, unlawful destruction, unauthorised disclosure, alteration and other unlawful or unauthorised processing.

Access to personal data will be restricted to people with a legitimate organisational need. No electronic storage or transmission system can be guaranteed to be completely secure.

Where BECC becomes aware of a personal-data breach, it will assess the incident and take actions required by GDPR, including notification to the Estonian supervisory authority and/or affected individuals where legally required.

13. How long do we keep personal data?

BECC retains personal data only for as long as reasonably necessary for the purpose for which it was collected, unless a longer period is required or permitted by law.

Type of information	Retention approach
Current member information	For the duration of membership and a 3 period afterwards
Former member information	Deleted or archived when no longer required, subject to legal and legitimate business requirements
Event registration information	As long as reasonably necessary to administer the event and maintain appropriate records
Financial and accounting records	For the period required by applicable Estonian law
Marketing subscriptions	to 3 years from your last interaction with BECC, or until you unsubscribe or withdraw consent if sooner. A minimal suppression record is kept so that we do not contact you again
Enquiries and correspondence	As long as reasonably necessary to deal with the enquiry and any related matter
Consent records	As long as reasonably necessary to demonstrate consent and comply with legal requirements
Website technical information	In accordance with cookie/analytics settings and provider retention periods (see the cookie table in clause 17)
Photographs and event records	Where reasonably necessary for historical, reporting or promotional purposes, subject to applicable rights and objections

BECC will periodically review retained information and delete or anonymise information that is no longer required.

14. Your rights under GDPR

Depending on the circumstances, you have the right to:

• **Access:** request a copy of personal data BECC holds about you.
• **Rectification:** request correction of inaccurate or incomplete personal data.
• **Erasure:** request deletion in certain circumstances.
• **Restriction:** request restriction of processing in certain circumstances.
• **Object:** object to processing based on legitimate interests. You have an absolute right to object to direct marketing.
• **Data portability:** where applicable, request data you provided in a structured, commonly used and machine-readable format.
• **Withdraw consent:** where processing is based on consent, withdraw it at any time.
• **Automated decisions:** exercise applicable rights concerning solely automated decisions producing legal or similarly significant effects.

15. How to exercise your rights

To exercise a GDPR right, contact legal@becc.ee  Please provide sufficient information to enable BECC to identify you and understand your request. BECC may need to verify your identity before disclosing or changing personal data.

BECC will normally respond within one month, subject to the circumstances and extensions permitted by GDPR. BECC will not normally charge a fee, although GDPR permits reasonable charges in certain circumstances, including manifestly unfounded or excessive requests.

16. Complaints

If you have concerns about how BECC processes your personal data, we encourage you to contact BECC first so that we can investigate and attempt to resolve the matter.

You also have the right to complain to the Estonian supervisory authority:

Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate)

Website: https://www.aki.ee

You may also have the right to complain to another competent supervisory authority within the EEA where applicable.

If you are in the United Kingdom, you may also complain to the Information Commissioner’s Office (ICO): https://ico.org.uk.

17. Cookies

Cookies are small text files placed on your device when you visit a website. BECC uses cookies and similar technologies to operate, secure and improve the website.

Necessary cookies are required for the website to function properly, such as for security, consent preferences and basic operation. They do not normally require consent where strictly necessary for a service requested by the user.

Preference or functionality cookies allow the website to remember choices or settings. Where consent is required, they will only be activated after consent.

Analytics cookies help BECC understand website use, such as pages visited, approximate visitor numbers and navigation. Where consent is legally required, analytics cookies will not be activated until consent is obtained.

Marketing or third-party cookies may support embedded content, social media or other functionality and may collect information about website use. Where consent is required, they will only be activated after consent.

The non-essential cookies currently used on the BECC website are:

Cookies are small text files placed on your device when you visit a website. They are widely used to make websites work, or work more efficiently, and to provide information to the site owner. Below is a list of the cookies we have detected, what they are for, and how long they last, generated automatically from a scan of this website and kept up to date whenever the site owner re-scans it.

You can change your cookie preferences at any time using the cookie icon shown in the corner of the screen, or via the consent banner shown on your first visit.

BECC also uses strictly necessary cookies, which do not require consent: _GRECAPTCHA (Google reCAPTCHA, about 6 months), which protects website forms from spam and abuse, and cookielawinfo-checkbox-necessary / cookielawinfo-checkbox-non-necessary, which record your cookie choices.

Google and Meta may also use information collected through their cookies for their own purposes, including advertising. Please see their privacy notices at https://policies.google.com/privacy and https://www.facebook.com/privacy/policy.

18. Cookie consent

When you first visit the BECC website, a cookie banner lets you “Accept all”, “Reject all” or choose which categories of non-essential cookie (analytics, preferences/functional, marketing) to allow. These options are presented with equal prominence. Non-essential cookies are not set until you have given consent. You can change or withdraw your choices at any time, as easily as you gave them, using the Cookie Icon in the bottom left of your screen.

The cookie banner and this Policy should be aligned with the actual cookies and third-party technologies operating on the BECC website. BECC will periodically review its cookie configuration. BECC periodically reviews the cookies and similar technologies operating on its website and will update the cookie table in clause 17 when they change.

19. Third-party websites and social media

The BECC website may contain links to member, sponsor, event-partner, government, diplomatic, social-media and other websites. BECC is not responsible for the privacy practices or content of those third-party websites. Review the relevant privacy policy before providing personal data to a third party.

If you communicate with BECC through a social-media platform, that communication may also be processed by the platform under its own privacy policy.

20. Children

BECC’s activities are directed primarily towards businesses, professionals and adults. BECC does not knowingly seek to collect personal data from children for its ordinary membership or business activities. If BECC becomes aware that it has inadvertently collected such data where collection was inappropriate, it will take reasonable steps to delete it where required.

21. Automated decision-making and profiling

BECC does not currently make decisions about individuals using solely automated processing that produces legal or similarly significant effects. BECC does not currently undertake automated profiling for such purposes. If this changes, BECC will update this Policy and provide information required by GDPR. However, if you consent to marketing cookies, Google and Meta may use information collected through those cookies to build profiles and show you tailored advertising on their platforms and partner sites. This is carried out by those companies under their own privacy notices, not by BECC.

22. Changes to this Privacy Policy

BECC may update this Policy to reflect changes to its activities, technology, services, applicable law, regulatory guidance or privacy practices. The latest version will be published on the BECC website.

Last reviewed and updated: September 2026.

23. Contact

British-Estonian Chamber of Commerce

Email: legal@becc.ee

Address: Briti Esti Kaubanduskoda MTÜ , Kopli 90-21, Tallinn 10416, Harjumaa

Website: https://becc.ee