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Privacy Policy

As a trustworthy partner, Naiya Holding OÜ (hereinafter Naiya), has committed to treating the company’s customers’ personal data, respecting all their rights. Based on this, the company has developed the main principles of privacy policy regarding the collection, use, disclosure, transfer and storage of customer data.


1.1. A data subject is a natural person about whom Naiya has information, or the information that can be used to identify a natural person. Data subjects are, for example, customers, collaborators, and employees as natural persons whose personal data Naiya has received.

1.2. Privacy policy is this text, which sets out the principles for the processing of personal data at Naiya.

1.3. Personal data is any information related to an identified or identifiable natural person.

1.4. The processing of personal data covers any act performed with a data subject's personal data, including collection, recording, organisation, storage, alteration, disclosure, providing access to them, conducting queries and retrievals, usage, transferring, cross-usage, merging, closure, deleting, or destroying personal data, or several of the above mentioned operations, regardless of the manner in which the operations are performed and the means used.

1.5. A customer is any natural or legal person who uses or has expressed an interest in using Naiya's services.

1.6. A contract is an agreement concluded between Naiya and a customer to provide services, or some other agreement

1.7. Website - is Naiya’s website.

1.8. A visitor is a person who uses Naiya’s website.

1.9. Services – all kinds of services and products provided by Naiya.

1.10. Cookies are data files that are sometimes saved on the device of a website visitor.

1.11. Naiya’s data protection specialist is a person who follows the implementation of the principles for the processing of personal data, and with whom any data subject can contact in case of complaint.

1.12. Sales channels are Naiya’s ways to communicate with data subjects, tools created for selling goods and services, incl e-mail, telephone, public and social media, various chat lines, individualised and interactive adverts, and other similar tools on websites and in other places.

1.13. Product portfolio includes Naiya’s various products and services, the list of which is available on the company’s website

In the privacy policy, the contract, the general terms and in communication between the parties, these notions are used in the sense indicated above.


2.1. Naiya is a legal person Naiya Holding OÜ, with the registry code 14171314 and legal address Suurekivi põik 16c Peetri alevik, Rae vald Harju maakond 75312.

2.2. At Naiya, personal data can be processed:

2.2.1. by a responsible processor, when the purposes and means of processing have been specified;

2.2.2. by an authorized processor according to the instructions of the person responsible;

2.2.3. by a receiver to whom personal data are transferred.

2.3. The privacy policy applies to the data subjects; the rights and obligations specified in the privacy policy are in force for all Naiya’s employees and partners to whom the personal data collected by Naiya are available.

2.3.1. The privacy policy may be supplemented by privacy notices published on the website or on the devices, and they may amend or supplement the privacy policy.


3.1. Naiya always favours the interests, rights and freedoms of data subjects when processing their personal data.

3.2. Naiya's goal is to provide responsible processing of personal data, which is based on best practice, bearing in mind that the company is always ready to demonstrate the compliance of the processing of personal data with the purposes set.

3.3. Naiya's processes, instructions, operations and activities related to processing personal data are based on the following principles:

3.3.1. Legality. In case of processing personal data, there is a legal basis for this, for example a consent.

3.3.2. Fairness. The processing of personal data is fair, requiring, first of all, that the data subject has sufficient information on how their personal data are processed.

3.3.3. Transparency. The processing of personal data is transparent to the data subject.

3.3.4. Purposefulness. Personal data is collected for precisely and clearly defined and legitimate purposes and will not be processed later in a way that does not conform to these purposes.

3.3.5. Correctness. The personal data are correct and, if necessary, updated, and all reasonable steps will be taken to delete or correct the personal data that are incorrect from the point of view of the purpose for processing personal data.

3.3.6. Principle of restricted storage – personal data shall be stored in a form that allows data subjects to be identified only for as long as it is necessary to fulfill the purpose for which the personal data is processed. This means that, if Naiya wishes to keep personal data longer than it is necessary for the purpose, the company will anonymize the data so that the data subject is no longer identifiable. As for the data received by Naiya through customer relationships or similar relations, the company will keep them in accordance with best practices and will retain the data processed on the basis of consent until the consent is withdrawn.

3.3.7. Reliability and confidentiality. Processing of personal data is carried out in a manner that ensures adequate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, by using reasonable technical or organizational measures. Naiya has both internal instructions and rules for employees and separate contracts with each authorized data processor, providing best practices, ongoing risk assessment and relevant technical and organizational measures for processing personal data.


4.1. Naiya shall collect, inter alia, the following types of personal data:

4.1.1. personal data given to Naiya by the data subject (name, e-mail address, postal address, phone number);

4.1.2. personal data resulting from normal communication between the data subject and Naiya;

4.1.3. personal data made clearly public by the data subject (e.g. in social media);

4.1.4. personal data generated when using services (e.g. when buying in Naiya’s online shop);

4.1.5. personal data resulting from the visit and use of the website (e.g. the time spent on the website);

4.1.6. personal data received from third persons;

4.1.7. personal data created and combined by Naiya (correspondence or the list of the order history in the context of customer relationships).



5.1. Naiya processes personal data only by consent of the data subject or by law.

5.2. By consent, Naiya processes personal data exactly within the limits, scope and purposes specified by the data subject. As regards consents, Naiya’s acts are based on the principle that each consent must be clearly distinguishable from other questions, in an understandable and easily accessible form, in a plain and simple language. The consent may be given in writing, electronically or orally. The data subject gives consent voluntarily, specifically, deliberately and unequivocally, for example by ticking the box on the website.

5.3. A legitimate interest is Naiya's interest in managing and running its own business, to offer the best possible services on the market. Under law, Naiya will process personal data only after careful evaluation, to determine that the company has a legitimate interest, the processing of personal data is necessary and in accordance with the interests and rights of the data subject. In particular, the processing of personal data on the basis of legitimate interest may take place for the following purposes:

5.3.1. to ensure trustworthy customer relationships, for example the processing of personal data, which is strictly necessary to identify actual beneficiaries or prevent fraud;

5.3.2. to manage and analyse the customer base to improve the availability, range and quality of the services and products, and to provide the best and most personalized offerings with the customer’s consent;

5.3.3. to collect identifiers and personal data when using webpages, mobile applications and other services. Naiya uses the data collected to conduct web analysis, analysis of mobile phone services and information society services, to ensure and improve activities, do statistics, analyse visitor behaviour and user experience, and to provide better and more personalised services;

5.3.4. to do customer and visitor satisfaction surveys and measure the effectiveness of marketing activities;

5.3.5. to analyse customer and visitor behaviour on different sales channels and webpages;

5.3.6. to monitor services – Naiya can save notices and orders made both in its premises or by means of telecommunication (e-mail, telephone, etc.), as well as information and other activities performed by Naiya, and, if necessary, use them to prove orders or other operations;

5.3.7. when considering network, information and cyber-security, for example to fight against piracy, to secure the websites, to make and maintain backup copies;

5.3.8. to compile, submit or defend legal claims.

5.4. To fulfil obligations arising from law, Naiya shall process personal data for the purpose of fulfilling obligations provided by law or applying the ways of usage permitted by law. For example, the law imposes obligations to process payments or follow the money laundering rules.

5.5. If the processing of personal data is for a purpose other than that for which the personal data was originally collected or is not based on the consent of the data subject, Naiya will carefully evaluate the admissibility of such new processing.



6.1. Naiya cooperates with persons to whom the company may transfer data relating to data subjects, including personal data, in the framework and for the purpose of cooperation.

6.2. These third persons may be, for example: persons mediating or providing postal services, IT partners, service providers for debt collection, payment failure registries, institutions and organizations, provided that:

6.2.1. their purpose and the processing are legal;

6.2.2. personal data processing is carried out in accordance with Naiya's instructions and under a valid contract.

6.3 Naiya Lingerie OÜ transfers the personal data necessary for making payments to the authorized processor Maksekeskus AS.


7.1. Naiya shall store personal data only for the strict minimum necessary time. Personal data, the expiry date of which has passed, will be destroyed, using best practices and in accordance with the procedures established by Naiya.

7.2. Naiya has established instructions and procedures on how to ensure the security of personal data through using both organisational and technical measures.

7.3. In the event of any incident involving personal data, Naiya will take all necessary measures to mitigate the consequences and avoid all relevant risks in the future. Among other things, Naiya shall register all incidents and inform the Data Protection Inspectorate and the data subject directly.



8.1. Rights related to the consent:

8.1.1. The consent to allow the processing of personal data may be withdrawn by the data subject at any time.

8.1.2. The consent to receive Naiya’s newsletter can be withdrawn through the link below the newsletter.

8.2. As regards the processing of personal data, the data subject also has the following rights:

8.2.1. The right to receive information, or the right of the data subject to obtain information about personal data collected on them.

8.2.2. The right to access data that inter alia includes the data subject's right to a copy of their personal data processed.

8.2.3. The right to demand the correction of inaccurate data.

8.2.4. The right to delete data, that is, in a certain case, the data subject has the right to require that personal data be deleted, for example, if processing is done only on the basis of their consent. In this case, the opportunity to participate in Naiya’s loyalty program will also end, as the client is no longer identifiable.

8.2.5. The right to demand limitation of processing personal data. This right arises, inter alia, if the processing is not authorized by law or if the data subject disputes the accuracy of their personal data. The data subject has the right to demand that the processing of personal data be restricted for a period that allows the responsible person to check the accuracy of personal data, or when the processing of personal data is unlawful, but the data subject does not request the deletion of their personal data.

8.2.6. The right to a supervisory authority's assessment of whether the processing of personal data of the data subject is lawful.



9.1. Exercising rights:

9.1.1. The data subject has the right to contact Naiya by e-mail in the event of a question, application or complaint concerning the processing of personal data.

9.2. Submitting complaints:

9.2.1. The data subject has the right to appeal to Naiya, the Data Protection Inspectorate or a court when the data subject thinks that their rights have been violated during the processing of their personal data.

9.2.2. The contacts of the Data Protection Inspectorate are available on its website.


10.1. Naiya may collect data about the visitors of the webpages and other information society services by using cookies (i.e. small pieces of information that are stored by the visitor's browser on the hard disk of their computer or other device) or other similar technologies (such as IP address, device information, location information), and process these data.

10.2. Naiya uses the data collected to: enable the provision of the service in accordance with the visitor or customer's habits; ensure the best service quality; make website experience more convenient for the customers; inform the visitor and the customer about the content and make recommendations; make ads more relevant and improve marketing efforts, analyse customer behaviour and thereby improve online experience, facilitate logging in and data protection. The collected data is also used to count visitors and identify their user habits.

10.3. We use the cookies of our online store environment to identify users as unique but anonymous persons.

10.4. Naiya uses session, permanent and advertising cookies. Session cookies will be deleted automatically after each visit; permanent cookies are extant when the website is visited frequently; advertising cookies are used to present materials suitable for the visitor or limit the number of times the same ad is seen on the website. Cookies of third parties are used by websites of Naiya’s partners. Naiya does not control the appearance of these cookies, so you can get information about these cookies from third parties.

10.5. As regards cookies, the visitors agree to use them on the website, in the settings of information society services, or the web browser. If the visitor does not want to allow the use of cookies on the website, they may block them in their web browser settings, use the option of private browsing, or delete them completely using the instructions given by the service provider of the web browser.

10.6. Most web browsers allow default cookies. Without the full permission of cookies, the features of the website are not fully available to the visitor, and unforeseen problems with functionality and user experience may occur. Allowing, blocking, or deleting cookies and other similar technologies is controlled by the visitor through the browser settings, information society service settings, and privacy enhancement platforms.



11.1. The following documents, procedures and instructions are used to implement Naiya’s privacy policy:

11.1.1. The Processing Operations Register, which lists all purposes, ways, processes, types and categories of personal data and the corresponding basics for the processing;

11.1.2. A person’s account in the online shop through which all personal information of the data subject is available to them at Naiya; it is possible to correct and alter them and exercise other rights given under law and this privacy policy;

Terms of Service


In addition to these conditions, the legal relationships arising from the distribution of products via the e-store are regulated by the laws of the Republic of Estonia.
By placing an order you are offering to purchase a product on and subject to the following terms and conditions.
Naiya Holding OÜ and the customer enter into a contract after the payment for the goods has been transferred to the account of Naiya Holding OÜ. Goods will not be reserved or dispatched before payment.


The prices of the products sold in Naiya Lingerie e-store are indicated on the product pages. All product prices are given in euros. Sale prices are listed on the product page, both the original and the discount price.


Whilst we try and ensure that all details, descriptions and prices which appear on this website are accurate, errors may occur. If we discover an error in the price/availability of any goods which you have ordered, we will inform you of this as soon as possible and give you the option of reconfirming your order at the correct terms or canceling it.


To order products, add the desired items to the shopping cart. To complete the order, fill in the required fields and choose the appropriate delivery method. Then, the screen will display the amount to be paid, which can be securely processed through the following payment methods:
  • Visa/Mastercard Card Payments
  • Estonian Bank Payments : Swedbank, SEB, Luminor, LHV, Coop Pank, Citadele, Pocopay
  • Finnish Bank Payments: Aktia, Ålandsbanken, Danske, Handelsbanken, Nordea, Oma Säästopankki, Pohjola, POP Pankki, S-Pankki, Säästopankki
  • Latvian Bank Payments: Swedbank, SEB, Citadele, Citadele and Lumino
  • Lithuanian Bank Payments: Swedbank, SEB, Citadele, Šiauliu and Luminor

    Please note! When making a payment via online banking, be sure to click on the "Return to Merchant" button on the bank's page.

    Payments are processed by Maksekeskus AS. Payment takes place outside of the Web Store in a secure environment – when paying via online banking, it occurs in the secure environment of the respective bank, and when paying by credit card, it takes place in the secure environment of Maksekeskus AS. The seller does not have access to the customer's bank or credit card details. The contract becomes effective once the amount due is received in the Web Store's bank account.

    Naiya Holding OÜ is the responsible data processor, and Naiya Holding OÜ provides the necessary personal data to the authorized processor Maksekeskus AS for the execution of payments.

    The owner of the Web Store is the responsible data processor and provides the necessary personal data to the authorized processor Maksekeskus AS for the execution of payments.

    If the ordered goods cannot be delivered due to their unavailability or for any other reason, the buyer will be informed as soon as possible, and the payment made (including the cost of delivering the goods) will be refunded promptly, but no later than within 14 days from the date of sending the notice.


    We are happy to offer worldwide delivery. Naiya Holding OÜ uses the trusted international logistics company DPD to deliver your goods to you safely.

    Delivery options and costs vary depending on your location and the selected shipping method. You can choose between three delivery options: Parcel Terminal, Pickup Point, and Courier. The exact shipping cost will be calculated at checkout.

    Delivery time: Depending on your location and selected shipping method the delivery time varies between 2-7 working days.


    Products purchased from can be returned within 14 days of the date of delivery notification. To return products send us a return request at In your request provide us with the following information: order number, and items you wish to return.

    Please note refunds are made based on the value of the products returned and do not include shipping costs. If you have any questions, feel free to contact us via

    Condition of the product returned:
  • The product can’t be damaged. If the returned product is damaged and the damage is not caused by non-targeted use or by circumstances that are caused by Naiya Holding OÜ, Naiya Holding OÜ has the right to offset the decrease in the value of the product that you have paid for and you will be refunded the difference. Naiya Holding OÜ will send you a statement.

  • The product doesn’t have signs of use. If the product has been used, we are guided by the principle of reasonable use – if the unsuitability is determined by trying the goods out, the goods are considered unused. Naiya Holding OÜ has the right to offset the decrease in the value of the product that you have paid for and you will be refunded the difference.

  • The product must have tags attached.


    Complaints and issues associated with Naiya Holding OÜ should be addressed to
    According to the Consumer Protection Act, Naiya Holding OÜ is under obligation to accept your complaint and issue a written response within 15 days.
    If the customer and Naiya Holding OÜ can’t resolve the case on their own, the customer can file a complaint with the Consumer Disputes Committee.


    We warrant to you that on delivery any product purchased from us through our site is of satisfactory quality and reasonably fit for all the purposes for which products of the kind are commonly supplied.

    Naiya Holding OÜ isn’t responsible for inconveniences to the client or for delays in delivery in case: the damage or delay in delivery was caused by a factor that wasn’t influenceable by Naiya Holding OÜ and that wasn’t and couldn’t be foreseen by Naiya Holding OÜ (force majeure).

    Naiya Holding OÜ isn’t responsible for the loss or damage of the item after it has been handed over to the courier.

    Naiya Holding OÜ takes responsibility only to the extent of the selling price. Naiya Holding OÜ isn’t responsible for the losses caused by the defective products such as damage to property/information, loss of turnover or profit.


    By using Naiya Lingerie e-store you give clear and voluntary consent to processing your personal data under the conditions provided for in this agreement.

    The personal data is stored in a customer database and is strictly used for sales purposes only. Naiya Holding OÜ sends newsletters and special offers to loyal customers who have signed up for the newsletter on the website

    The customer always has the opportunity to unsubscribe from receiving these letters by sending a corresponding e-mail or by following the instructions in the newsletter.

    The personal information necessary for the delivery of goods has only been forwarded to the extent strictly necessary. The data about the client and their order that is stored in the orders’ environment of the e-store are treated as confidential information. We will not disclose the information to third parties.

    You can be sure that we have a safe shopping environment and we’ll not pass your information to third parties.

    Naiya Lingerie e-store offers secure online purchases.

    When paying for goods at Naiya Lingerie online store you will be directed to the selected Internet Bank once you have entered your bank card details. There you will be asked to identify yourself to confirm payment. For this, enter your Internet Bank username, select a method of authentication and enter your password. In the event of a successful authentication, you will be re-directed to the merchant and the purchase transaction will continue as per usual. Should authentication fail, an alternative method of payment must be selected (an alternative card, bank link or PayPal).

    Naiya Holding OÜ is the responsible processor of personal data, Naiya Holding OÜ transfers the personal data necessary for making payments to the authorized processor Maksekeskus AS. Payments are also mediated by Maksekeskus AS.


    We have the right to revise and amend these terms and conditions from time to time to reflect any following changes that affect our business: changes in market conditions, changes in technology, changes in payment methods, changes in relevant laws and regulatory requirements, and changes in our system’s capabilities.

    You will be subject to the policies and terms and conditions in force at the time that you order products from us, unless any change to those policies or these terms and conditions is required to be made by law or governmental authority, or if we notify you of the change to those policies or these terms and conditions before we send you the order confirmation (in which case we have the right to assume that you have accepted the change to the terms and conditions unless you notify us of the contrary within 14 working days of receipt).