Privacy and transparency
Privacy Policy
We explain transparently how Brokerly collects, uses and protects personal data.
Contents16 sections
1. General
This Privacy Policy explains how Brokerly OÜ processes personal data when you use www.brokerly.ee, submit a contact form, contact us by e-mail or telephone, or use another contact channel offered by Brokerly.
The Policy applies to the Estonian, English and Russian versions of the website. If there is a substantive inconsistency between language versions, the Estonian version prevails unless applicable law requires otherwise.
2. Controller
Brokerly OÜ
- Registry code:
- 16428131
- Address:
- Valukoja tn 8/1, Lasnamäe District, 11415 Tallinn, Harju County, Estonia
- Website:
- www.brokerly.ee
- E-mail:
- info@brokerly.ee
- Telephone:
- +372 5555 5009
For privacy questions and data-subject requests, contact info@brokerly.ee.
3. Personal data we process
3.1 Enquiries and contact forms
Depending on the form or contact method, we may process the following data:
- name;
- telephone number, e-mail address or another contact detail chosen by you;
- the contents of your enquiry or message;
- property address, area, type or other property-related information;
- the service you are interested in, such as valuation, sale, quick sale, rental or property management;
- the date, time and history of communications.
3.2 Technical website data
For normal website operation, security and troubleshooting, Brokerly’s hosting server and service providers may process technical log data. Depending on the log-file type, this may include an IP address, date and time, HTTP request method, requested URL or path, response status and size, referrer, User-Agent, error category and technical process information. The exact log content depends on the hosting configuration and the particular log file.
3.3 Analytics data
With your consent, Google Analytics 4 may process website-use data such as page views, session and event data, approximate location, device and browser category and technical identifiers. Brokerly does not send form contents, names, e-mail addresses, telephone numbers, property addresses or other directly identifying data to Google Analytics.
4. Purposes and legal bases
| Purpose | Data | Legal basis |
|---|---|---|
| Responding to an enquiry, arranging a meeting or consultation and taking pre-contractual steps | Name, contact details, message, property and service information | Steps at your request before entering into a contract and, where relevant, legitimate interests |
| Providing brokerage, sales, rental, valuation or property-management services | Client, property, communication and contract data | Performance of a contract and legal obligations |
| Website and form security, spam and abuse prevention | Technical request data, security fields and server logs | Brokerly’s legitimate interest in protecting the website, data and communication channels |
| Measuring website use and improving services | Google Analytics data | Your consent |
| Accounting, compliance and legal-claim management | Contract, invoice, payment and communication data | Legal obligation, contract and legitimate interests |
Brokerly does not make automated decisions based on website data that produce legal or similarly significant effects.
5. Contact forms
Brokerly’s custom forms transmit the information you enter through a secured server-side form handler to info@brokerly.ee. Security controls include a nonce, timestamp, signature, minimum completion time and honeypot field to reduce automated spam and unauthorised submissions.
Once conversion measurement is activated following a separate technical check, a successful server-confirmed form submission will send only the event generate_lead and a general service category lead_type to Google Analytics. Form contents, contact details, property address, free text and the one-time technical token are not sent to Google Analytics.
Submitting a form does not automatically guarantee a service or create a contract. Brokerly may request additional information to respond or take pre-contractual steps.
Information marked as mandatory on a contact form is required to respond to the enquiry and, where applicable, to take pre-contractual steps. If the user does not provide sufficient contact or enquiry information, Brokerly may be unable to respond or carry out the requested action.
6. E-mail, telephone and external communication channels
If you contact Brokerly by e-mail or telephone, we process the data you provide to answer your enquiry, organise communications and, where applicable, take pre-contractual steps or perform a contract.
The website may link to WhatsApp, Viber, Telegram, Facebook Messenger, TikTok, Instagram or another external service. If you choose such a channel, the service provider processes data under its own terms and privacy policy. You may use e-mail or telephone if you prefer not to use an external messaging platform.
7. Cookies, localStorage and consent
7.1 Remembering your choice
The website stores your cookie preference in browser localStorage under brokerly_consent_v1. It contains only a version number, the choice “allow” or “deny”, and saved-at and expiry timestamps. It does not contain your name, e-mail, telephone number, IP address or form contents.
The preference is kept for 180 days so that the website remembers your decision. You can change it through the “Cookie settings” control on the website.
7.2 Google Analytics 4
Brokerly uses Google Analytics 4 through Google Site Kit. The Measurement ID is G-PVV8EXNL8Q.
By default, analytics_storage, ad_storage, ad_user_data and ad_personalization are denied. Analytics cookies are enabled only after you select “Allow statistics”. Brokerly does not use advertising cookies, AdSense or personalised advertising, and advertising-related consent categories remain denied.
Brokerly uses a consent solution based on Basic Consent Mode. Google Analytics loads and analytics cookies are set only after the user selects “Allow statistics”. If the user has not made a choice or selects “Decline”, Google Analytics remains blocked and analytics cookies are not set. The user can change the choice later through “Cookie settings”. If the user changes the choice from allow to deny, further analytics stops and Brokerly’s GA4 cookies are removed.
| Name | Type and purpose | Duration |
|---|---|---|
| brokerly_consent_v1 | Necessary localStorage entry that remembers your consent preference; stores version, choice and timestamp | 180 days |
| _ga | Google Analytics; distinguishes users after analytics consent | Default up to 2 years; browser limits may shorten this |
| _ga_PVV8EXNL8Q | Google Analytics; property-specific GA4 session-state cookie pattern after analytics consent | Default up to 2 years; browser limits may shorten this |
GA4 user- and event-level data retention is set to 14 months. Under the current GA4 configuration, the user-data retention period resets on new user activity. Google Signals data collection is disabled.
8. Google Analytics privacy information
Google provides Google Analytics. Google processes Analytics customer data under its service and data-processing terms. According to information published by Google, Google Analytics does not log or store individual IP addresses from users in the European Union. An IP address may be used to derive approximate geographic information before it is discarded.
Directly identifying data must not be sent to Google Analytics. Brokerly’s implementation is designed so that names, contact details, messages, property addresses and other personal form content are not included in GA4 events or URL parameters.
Google may process data outside the European Economic Area using safeguards described in its terms. Further information is available in Google’s privacy and data-processing terms.
9. Recipients and processors
Only the following recipients may access personal data, and only to the extent necessary and within the scope of their role or function:
- Brokerly OÜ personnel and cooperation partners who need the data to handle an enquiry or service;
- website hosting provider Elkdata OÜ, registry code 10510593, Telliskivi 60/2, 10412 Tallinn, Estonia; Google Workspace and e-mail provider Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland;
- Google Analytics provider;
- IT, security, accounting or legal service providers where necessary for service operation or compliance with legal obligations;
- public authorities and other lawful recipients where required by law.
Brokerly does not sell personal data.
10. Retention
| Data category | Retention period |
|---|---|
| Enquiry that does not lead to a service relationship | Up to 12 months after the last substantive contact where the enquiry does not lead to a client or contractual relationship; longer only for a legal claim or another documented need |
| Client and contract records | For the contract term and afterwards for as long as necessary for legal obligations, claims or rights of defence |
| Accounting and payment records | For the period required by applicable law |
| E-mail and messaging communications | E-mail and messaging enquiries that do not lead to a client or contractual relationship are retained for up to 12 months after the last substantive contact. Data may be retained longer only where necessary for an active client relationship, a legal obligation, evidence of an agreement, or the establishment, exercise or defence of a legal claim. |
| Server and security logs | The retention period for hosting logs is not fixed. It depends on the provider’s technical configuration, log-file volume and website activity; higher log volume may result in a shorter retention period. |
| Consent localStorage | 180 days |
| GA4 user- and event-level data | 14 months; the user-data retention period resets on new user activity |
Where data is needed for the establishment, exercise or defence of a legal claim, it may be retained until the relevant proceedings or claim limitation period ends.
11. Security
Brokerly uses reasonable technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, disclosure or unauthorised access. Measures include access restrictions, WordPress and server security controls, form nonce and timing checks, a honeypot, software updates, backups and need-to-know access.
No method of transmission over the internet or electronic storage is completely risk-free. If a security incident occurs, Brokerly acts in accordance with applicable law and a risk assessment.
12. Your rights
Subject to applicable conditions, you have the right to:
- receive information about the processing of your personal data;
- request access to your data;
- require inaccurate data to be rectified;
- require erasure of data;
- require restriction of processing;
- object to processing based on legitimate interests;
- receive data you provided in a machine-readable format where the right to data portability applies;
- withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal;
- lodge a complaint with a supervisory authority.
Send requests to info@brokerly.ee. Brokerly may ask for reasonable information to verify your identity and the scope of the request.
13. Complaints
If you believe that your personal data has been processed unlawfully, please first contact Brokerly at info@brokerly.ee. You also have the right to complain to the Estonian Data Protection Inspectorate, Tatari 39, 10134 Tallinn, Estonia, e-mail info@aki.ee, website www.aki.ee.
14. External links and public content
The website may link to third-party websites and services, including Google reviews, social media and messaging platforms. Brokerly is not responsible for third-party privacy practices. Before using an external service, we recommend reviewing its privacy terms.
Public Google reviews displayed on the website may include a reviewer’s public name, rating and comment. Brokerly displays such public content based on its legitimate interest in demonstrating trust and service quality.
15. Children
Brokerly’s services are not directed at children. If we learn that a minor’s data has been collected without an appropriate basis, we will take reasonable steps to delete or restrict it.
16. Changes
Brokerly may update this Policy when services, technical arrangements or legal requirements change. The current version will be published on the website with the update date.