UPD: Effective Date: 24.05.2018


1.1. Hotwire Systems company respects the privacy of all our users, and we fully committed to protect customers/visitors personal data and use it in accordance with legal obligations. This privacy policy describes the personal information that we can collect from You, or that You provide on the and how that information may be used or disclosed by us. 

1.2. The terms: «eShop», «HWS», «we», «us», «our», «Hotwire Systems» as used herein refers to Hotwire Systems OÜ, an Estonian company with business register code #12444328.

1.3. Please read the following privacy policy carefully to understand our policies and practices regarding Your personal information and how we will treat it. By accessing or using this eShop, You signify Your approval of the terms and policies posted on our eShop. If You do not agree to this privacy policy, You must immediately leave and discontinue all use of our Services (including services provided on other web pages of Hotwire Systems company).

1.4. The controller of the personal data of the online shop is Hotwire Systems OÜ


2. INFORMATION WE COLLECT (What personal data are processed)

2.1. We collect and process some or all of the following types of information from You:

  • Information that You provide by filling in forms on the We may also ask You for information when You report a problem with the eShop.
  • If You contact Us by e-mail, we may keep a record of that correspondence.
  • We may also ask You to complete surveys that We use for research purposes, although You do not have to respond to them.
  • Details of all actions that You carry out through the eShop. Some details may be collected automatically of Your visits to the eShop including, but not limited to, traffic data, location data, the site that referred You to our site and the resources that You access.
  • Information You submit at the time of placing Your order:
    • First name and surname
    • Personal ID code
    • Address
    • Phone number
    • E-mail address
    • Delivery address (which may be different from the main address)
    • Bank account number
    • Cost of goods and services and payment details (purchase history)
    • Customer support details
  • Information based on Your social media preferences which You share with us, for example Facebook or YouTube. Please note, however, that each of our eShop pages and applications which are hosted or available through social media sites may contain its own separate terms of use and privacy policy. Your use of that company page or application, including but not limited to your submission of any content, materials or personal information to or via the applicable company page or application, is at all times subject to any posted terms of use and privacy policy.
  • Information we receive from third parties, for example, our business partners and customers, including without limitation, information related to referrals to our website from third parties.

2.2. IP Addresses and cookies

2.2.1. We may collect information about Your visits to our eShop and also collect some information about Your computer, including where available Your IP address, operating system and browser type, for system administration, customer support and to collect aggregate information for internal reporting purposes. This is statistical data about users’ browsing actions and patterns, and does not identify any individual.

2.2.2. Cookies. A Cookie is a small files of letters and numbers that allow the devices used to browse the Web (e.g. computer, smartphone, tabs) to store specific information regarding the device used. The information recorded in cookies is used e.g. for advertising and statistical purposes and to adapt our eShop to Your individual needs.

2.2.3. You can change cookie settings in Your web browser. If the settings remain unchanged, cookies will be saved on the device.

2.2.4. You should be aware that, if You disable cookies, this may limit Your ability to enjoy the full functionality of the eShop.

2.2.5. To find out more about cookies, visit


3.1. Any information You submit on the Site may be used for a variety of purposes, including, for example, to:

  • Manage the customer’s orders and deliver goods.
  • Respond to Your questions and requests.
  • Verify Your identity.
  • Communicate with You.
  • Request feedback or contact You about Your use of the eShop.
  • Send You newsletters, promotional or updates provide You with information about HWS250! such as news about discounts, out of stock products, new prices.

3.2. Purchase history details (date of purchase, goods, quantity, customer’s details) are used for preparing summaries of goods and services purchased and for analysing customer preferences.

3.3. The bank account number is used to reimburse payments to the customer.

3.4. Personal data such as email, phone number and the customer’s name are processed to handle any issues relating to the provision of goods and services (customer support).

3.5. The IP address or other web identifiers of a user of the eShop are processed for the provision of the eShop as an information society service and for web use statistics.

3.6. Hotwire Systems OÜ will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect Your computer equipment, computer programs, data or other proprietary material due to Your use of the eShop.

3.7. Where personal data are processed on the basis of the customer’s consent, the customer may withdraw their consent by notifying customer support by email

3.8. Direct marketing messages

3.8.1. Email address, address and phone number are used for sending direct marketing messages if the customer has given their consent to receiving such messages. If the customer does not want to receive direct marketing messages, the customer should select the relevant link at the footer of the email or contact customer service.


4.1. The eShop may contain links to other sites, maintained by third parties.

4.2. Hotwire Systems OÜ has no control over, and is not responsible for any content, services or products offered by or found on third party sites, or their privacy policies. Please check all terms & conditions and privacy policies before You submit any of Personal Data to these websites.


5.1. No one under age 18 may provide any personal information to our eShop or otherwise to Hotwire Systems OÜ. We do not knowingly collect personal information from children under 18. If You are under 18, please do not make any purchases through our eShop or send any information about Yourself to us, incl. Your name, address, telephone number or email address. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information. If You believe that we might have any information from or about a child under 18, please contact us immediately.


6.1. Under the General Data Protection Regulation You have a number of important rights free of charge. In summary, those include rights to:

  • Access to Your personal data and to certain other supplementary information that this privacy policy is already designed to address.
  • Require Us to correct any mistakes in Your information or the erasure of personal data concerning You in certain situations.
  • Receive the personal data concerning You which You have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • Object at any time to processing of personal data concerning You for direct marketing
  • Object to decisions being taken by automated means which produce legal effects concerning You or similarly significantly affect You
  • Object in certain other situations to our continued processing of Your personal data
  • Otherwise restrict our processing of Your personal data in certain circumstances
  • Claim compensation for damages caused by our breach of any data protection laws.


7.1. Personal data are processed for the purpose of performing a contract with the customer.

7.2. Personal data are processed for performing legal obligations (such as accounting and the settlement of consumer complaints).

7.3. Data are processed with the customer’s consent for the following purposes: sending of marketing messages.


8.1. Personal data are stored in the servers of (Elkdata OÜ, register code: 10510593, legal address: Tondi tn 51-10 Kristiine linnaosa, Tallinn Harju maakond 11316) which are located on the territory of a member state of the European Union or states of the European Economic Area. Data may be transferred to the countries whose data protection levels have been assessed as adequate by the European Commission and to the companies in the USA who have joined the Privacy Shield framework.

8.1.1. Your personal data can be accessed by the staff of the eShop in order to settle technical issues related to the use of the online shop and to provide customer support.

8.1.2. The eShop takes appropriate physical, organisational and IT security measures to protect personal data against accidental or unlawful destruction, loss, alteration or unauthorised access and disclosure. Personal data are transmitted to the data processors of the online shop (such as the providers of transport and data hosting services) and processed under contracts concluded between the online shop and the processors. The processors must ensure appropriate safeguards when processing personal data.

8.1.3. Unfortunately, the transmission of information via the internet is not completely secure. We use certain reasonable security measures to help protect Your Personal Data. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note, that we cannot ensure or warrant the security of any information You transmit to us at 100%, and You use the eShop and provide us with Your information at Your own risk.

8.2. Access to Information (Deletion, modification)

8.2.1. The Act gives You the right to access and rectification or erasure of personal data or restriction of processing information held about You. Your right of access can be exercised in accordance with the Act.

8.2.2. You can check/download/delete Personal data which we are holding on You by typing Your e-mail address, You have used on our eShop, to the form at the end of this page.

8.2.3. Personal data can be also deleted by contacting customer support by email ( Deletion requests are responded to within one month and the period of deletion shall be specified.

8.2.4. In case if You believe that any information we are holding on You is incorrect or incomplete, please write to or e-mail us as soon as possible. We will promptly correct/modify information found to be incorrect.

8.2.5. Transfer requests made by e-mail are responded to within one month. Customer support shall identify the person and inform them of the personal data to be transferred.

8.2.6. In addition, You should be aware that it is not always possible to completely remove or delete all of Your information from our databases without some residual data because of backups or other technology-related reasons.

8.3. How long will we keep Your personal data?

8.3.1. As long as You are a customer of eShop!

8.3.2. Until You remove/delete You personal data or send us e-mail message with the request to remove/delete or stop using Your personal data if there is no reason to keep it.

8.3.3. In the event of disputes concerning payments and consumer disputes, the personal data are stored until the meeting of the claim or until the end of the limitation period (three years).


9.1. Disputes concerning the processing of personal data are settled through customer support (e-mail: or phone # +372 658 5566).

9.2. The General Data Protection Regulation also gives You right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where You work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Estonia is the Estonian Data Protection Inspectorate (


10.1. This privacy policy may be updated from time to time, for example in cases when we introduce new services, products or new features. Therefore, we encourage You to check this page from time to time, because the amendments to this privacy policy enter into force and are applied from the moment changes have been uploaded to this page (please follow for the Effective Date at the beginning of this page). Your use of the Service following any such notice will signify and constitute Your assent to and acceptance of such revised privacy policy.


11.1. If You have any questions or comments about Your personal data or this privacy policy, please feel free to contact Hotwire Systems directly:

  • by e-mail: shop @
  • by phone: +372 658 5566
  • by mail at Hotwire Systems OÜ, Treiali tee 2, 75312 Peetri alevik, Rae vald, Harjumaa, Estonia.

Hotwire Systems OÜ legal requisites

  • Reg #: 12444328 | VAT #: EE10164923
  • Legal address: Treiali tee 2, 75312 Peetri alevik, Rae vald Harjumaa, Estonia
  • Phone: +372 658 5566
  • E-mail: shop @

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