Privacy Policy

1. Introduction

This Privacy Policy explains how Lubera OÜ, a private limited company established in the Republic of Estonia ("Lubera", "we", "us"), processes personal data in connection with the Tervita platform and the websites tervita.ee, tervita.lv and tervita.app (the "Platform").

We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and the Estonian Personal Data Protection Act. This policy describes what data we process, why, on what legal basis, with whom we share it and what rights you have.

2. Our Role: Controller and Processor

We act in two different roles depending on the data:

  • Controller. For personal data of account holders, Authorised Users and website visitors — such as registration details, billing information and usage data — Lubera is the data controller.
  • Processor. When a business customer (a clinic, salon or other service business) uses the Platform to manage its own clients, that business is the controller of its clients' ("End Clients'") personal data, and Lubera acts as its processor. We process such data only on the documented instructions of the business customer in order to provide the Platform. If you are an End Client, please direct privacy requests to the business you booked with; we will assist that business as its processor.

3. Personal Data We Process

Depending on how the Platform is used, we may process:

  • Account data: name, email address, phone number, organisation, role and login credentials of account holders and Authorised Users.
  • Booking data entered by business customers about their End Clients: name, contact details, appointment date and time, selected services and any notes the business chooses to record.
  • Billing data: subscription plan, invoicing details and payment status (card details are handled by our payment providers, not stored by us).
  • Communications: messages you send us, support requests and booking notifications.
  • Conversations with our AI support assistant (Ficus): what you type in the support chat, the assistant's answers, any ratings you give them and, in the dashboard, which of your settings it checked. We keep them to continue the conversation and to review the quality of the answers.
  • Support tickets: when you open a support ticket, we store your account, the text of your request and our replies, the technical context of the page you wrote from (such as the route, app version, language and screen size — no personal data), and a delivery log of the notification emails this generates. We process this to answer your request.
  • Technical and usage data: IP address, device and browser information, log data and cookie identifiers (see our Cookie Policy).
  • How you found us: the campaign tags in the link you arrived by (UTM parameters), the first page of our website you landed on and the domain of the website that referred you. We store this with your salon's account when it is created, without cookies or any storage on your device. Legal basis: our legitimate interest in understanding which advertising works. When you arrive from one of our ads, the visit is also added to anonymous daily totals: per day, page language, campaign and ad, we count how many visits opened our page and how many reached the sign-up page. For all visitors we likewise count, per day and language, how often the cookie banner was shown, accepted or declined. These totals contain only numbers, with no IP address, cookie, device storage or other identifier, and cannot be linked to you.
  • Business contact data: the name of a company, its general business email address and its website, taken from public sources such as the company's own website or the Estonian Business Register, when we offer the Platform to businesses.

The Platform does not require special-category (e.g. health) data to function. Any such data that a business customer chooses to record about its End Clients is entered under that business's own responsibility as controller.

4. Purposes and Legal Bases

As controller, we process personal data for the following purposes and legal bases:

  • To provide, operate and maintain the Platform and your account — performance of a contract.
  • To secure the Platform, prevent fraud and abuse, and keep records — our legitimate interests and, where applicable, legal obligations.
  • To communicate with you about your account, service changes and support — performance of a contract and legitimate interests.
  • To comply with legal, accounting and tax obligations — compliance with a legal obligation.
  • To improve and develop the Platform — our legitimate interests, using data in an aggregated or minimised form where possible.
  • To send optional product updates or marketing to account holders — consent or legitimate interests, and you can opt out at any time.
  • To operate and support your account with service messages by e-mail, SMS or in-product notification — sign-in and security, billing, legal notices, setup guidance, changes to the Platform, activity summaries and tips on features you use — performance of a contract and our legitimate interest in helping you use the Platform. Non-essential service messages can be turned off at any time via the link in the message or your dashboard settings.
  • To measure whether a Google Ads click led to a completed sign-up (conversion counting only, no ad personalisation or remarketing); legal basis: your consent, given in Cookie settings and withdrawable at any time.
  • To send a business a short offer of the Platform at its published business email address, at most one letter and one reminder - our legitimate interest in offering our services to businesses (Article 6(1)(f) GDPR). Each letter says how to opt out; a one-word reply is enough, and we will not write again.

Where we act as processor for a business customer's End Client data, we process that data only to provide the Platform and on the business customer's documented instructions.

5. Cookies

We use strictly necessary cookies to keep you signed in, secure the Platform and remember preferences such as language. Optional analytics is denied by default and can be controlled through Cookie settings. After consent, selected pseudonymous events are processed in our first-party ledger, Google Analytics 4 and Amplitude EU, without cross-site tracking. If you then create a salon account, we also save with it which broad channel first brought you to us. Advertising measurement is a separate optional category, also denied by default: only if you allow it do we use Google Ads to count sign-ups that come from our ads, and the ad click identifier is then saved with the account you create (see section 6). Ad personalisation stays switched off. For details, see our Cookie Policy.

6. Sharing and Sub-Processors

We do not sell personal data. We share personal data only with service providers who process it on our behalf under a contract, and where required by law.

Our sub-processors, by name, as of 12 October 2026:

  • Supabase - database, authentication, file storage and server functions (EU region);
  • Cloudflare - application hosting, content delivery and security (global edge network);
  • Hetzner - encrypted off-site backups of the database (Germany). Backups are encrypted before they leave our systems and the decryption key is held offline by us, so Hetzner cannot read their contents;
  • Resend - transactional email delivery (booking confirmations, reminders, account notifications);
  • Twilio - SMS delivery, including verification codes;
  • Messente - SMS delivery, used as a fallback route for Baltic and Finnish numbers;
  • Stripe - subscription billing and, where a business customer enables it, client payments;
  • Anthropic - the AI assistant in our support chat, where that feature is switched on. It receives the text of the support conversation and our public help articles. It does not receive client or patient records;
  • Google Ads (Google Ireland Limited) - optional advertising measurement, only after separate Advertising consent: it receives the ad click identifier and the completed sign-up conversion; the same click identifier is saved with the account you create so that the sign-up can be matched to the ad;
  • Google Analytics 4 and Amplitude EU - optional analytics, only after consent and only for minimised pseudonymous events.

We will inform business customers before a new sub-processor starts processing personal data on our behalf, so that there is an opportunity to object. Write to us at the address in section 1 to be notified of changes to this list.

We may also disclose personal data where necessary to comply with the law, enforce our agreements, or protect the rights, safety and security of Lubera, our customers or others.

7. International Data Transfers

We aim to process personal data within the European Union / European Economic Area. Where a sub-processor processes data outside the EEA, we ensure appropriate safeguards are in place, such as an adequacy decision of the European Commission or the EU Standard Contractual Clauses.

8. Data Retention

We keep account and related personal data for as long as your account is active and as needed to provide the Platform. After an account is closed, we delete or anonymise personal data within a reasonable period, except where we must retain certain data to comply with legal obligations (for example, accounting records, which Estonian law generally requires to be kept for seven years).

End Client data entered by a business customer is retained in accordance with that customer's instructions and settings, and deleted or anonymised when no longer needed or on the customer's request.

Conversations with the AI support assistant are deleted 12 months after the last message. Authorised Tervita staff may read a conversation to answer a support request or to improve the assistant's answers; each such access is logged and, for conversations from a business account, also shown in that account's audit log.

Support tickets are deleted 24 months after they are closed. A ticket from a website visitor with no account — and so no clinic attached — is deleted 12 months after its last activity, whatever its status.

If you came to us through an ad and allowed Advertising, the ad click identifier (gclid, gbraid or wbraid) saved with your account is kept until the account is deleted.

If a business has not replied to an offer, we review its contact data 90 days after the last letter and delete what we no longer need. If a business asks us not to write, we keep only its email address on a do-not-contact list, so that we never write to it again.

9. Security

We use appropriate technical and organisational measures to protect personal data, including encryption in transit (TLS), encryption of data at rest, role- and row-level access controls, least-privilege access and monitoring. No system is completely secure; if a personal-data breach affects your data, we will act and notify affected parties and authorities as required by law.

10. Your Rights

Subject to applicable law, you have the right to:

  • access the personal data we hold about you;
  • have inaccurate data corrected;
  • have your data erased in certain circumstances;
  • restrict or object to certain processing;
  • receive your data in a portable format;
  • withdraw consent at any time, where processing is based on consent.

To exercise these rights in relation to data for which we are the controller, contact us at privacy@tervita.ee. If your data was entered into the Platform by a business customer (as its End Client), please contact that business, which is the controller; we will support it as processor. You also have the right to lodge a complaint with a supervisory authority — in Estonia, the Data Protection Inspectorate (Andmekaitse Inspektsioon, aki.ee).

11. Children

The Platform is intended for use by businesses and is not directed to children. Where a business customer records data about a minor End Client, that business is responsible for obtaining any consent required from a parent or guardian under applicable law.

12. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide reasonable notice, for example by posting the updated policy on the Platform and updating the "last updated" date below.

13. Contact

For questions about this Privacy Policy or about how we handle personal data, contact the controller:

  • Lubera OÜ (Republic of Estonia)
  • Email: privacy@tervita.ee

Last updated: 28 October 2026