GENERAL TERMS OF POSTIMEES GRUPP AS

Definitions

• Postimees Grupp – company AS Postimees Grupp, registry code 10184643, location Tartu mnt 80, Tallinn, Estonia 10112. Customer support phone: 666 2525 (Mon–Fri 9–17) and levi@postimees.ee.
• Subscriber – a natural or legal person who has subscribed to the Publications of Postimees Grupp and/or to a newsletter.
• Subscription – a purchase–sale agreement concluded between Postimees Grupp and the Subscriber, the subject of which is the ordering of a print and/or digital product.
• User – a user of the Postimees Grupp web environment and/or a Subscriber of a Publication.
• User account – a user account for all Postimees Grupp media portals.
• Publication – a print or digital product published by Postimees Grupp.
• Print product – a Publication whose content is available on paper together with Summaries (daily, weekly or other Summaries) made available on a regular basis.
• Digital product – a Publication whose content is available digitally together with Summaries (daily, weekly or other Summaries) made available on a regular basis.
• Package – a subscription solution defined by Postimees Grupp for Digital and/or Print Products or a combination thereof, the content and scope of which may vary.
• Advertisement – an advertisement published in a Postimees Grupp print newspaper or in an online environment.
• Additional Services – supplementary services offered free of charge to Users of the Postimees Grupp web environment and/or Subscribers of Digital Products, provided through separate Portals.
• Portals – independent service environments within the Postimees Grupp web environment through which Additional Services are offered, including various service functions and solutions (e.g. price comparison portals and other similar solutions).
• Summaries – a component of a Digital Product or Print Product through which Postimees Grupp prepares summaries of its media content for Subscribers to ensure fast and relevant access to news and other content. Summaries may be delivered to the postal or e-mail address provided by the Subscriber. The Subscriber may request Summaries on various thematic or regional topics at any time. If the Subscriber does not wish to receive Summaries, they must contact Postimees Grupp.
• General Terms and Conditions – these terms and conditions for using the website and subscribing to Publications.

Compliance with and Amendments to the General Terms and Conditions

2.1 The General Terms and Conditions apply to all Users.

2.2 The General Terms and Conditions have been drawn up in Estonian and English. In the event of interpretation discrepancies, contradictions or translation errors between the different language versions, the Estonian version shall prevail and shall be considered authoritative.

2.3 Postimees Grupp has the right to amend the General Terms and Conditions. Amendments to the General Terms and Conditions take effect from the date the updated terms are published in the Postimees Grupp web environment at www.mmgrupp.ee/legal/postimehe-kasutustingimused.

2.4 Postimees Grupp has the right to change the Subscription price with reasonable advance notice. Subscribers will be informed of price changes through various channels: in the print newspaper, by e-mail, and by SMS. Subscription price changes take effect at the beginning of the next subscription period after the date of the price change.

2.5 Postimees Grupp has the right to suspend or discontinue the partial or full publishing of a Publication. If Postimees Grupp decides to suspend or discontinue publishing a Publication, the prepayment made by the Subscriber will be refunded.

2.6 Postimees Grupp does not guarantee fulfilment of the Subscription and may suspend or terminate the Subscription if:

• the data provided by the Subscriber is false and/or inaccurate;
• the Subscriber's mailbox does not meet the requirements set out in clause 3.5;
• the Subscriber fails to pay the agreed amount for the Subscription by the due date;
• the Subscriber violates other requirements of the General Terms and Conditions.

Subscriptions

3.1 To place a paid subscription order for a Publication, the person must be at least 18 years of age.

3.2 Access to paid content of Digital Products is granted through the user account immediately after payment for the Subscription and/or from the start date specified for the Subscription. For more information on creating and using a User Account, see clause 4.

3.3 A Digital Product subscription is personal unless otherwise stated in the Package terms. In the case of a Subscriber that is a legal entity, use of the Subscription within the organisation through a personal User Account is permitted.

3.4 Programmes/series may be subject to geographic screening rights restrictions, meaning that the producer of the programme/series has granted the right to show it only within the territory of Estonia. Geographic restrictions also apply to Subscribers.

3.5 For delivery of a Print Product Subscription, the Subscriber must ensure:

• a secure, accessible mailbox that corresponds to the dimensions of the publication and can be identified as the Subscriber's mailbox, with a minimum opening size of 230 x 20 mm (length, width);
• clear, unobstructed access to the mailbox, free of snow and ice in winter.

3.6 A Print Product Subscription may be redirected within the Republic of Estonia. The relevant request must be submitted to Postimees Grupp customer support. Redirection takes effect no later than 10 business days after receipt of the notification.

3.7 A standing order Subscription renews automatically at the end of each subscription period, unless the Subscriber cancels the Subscription before the end of the current subscription period. The length of the new subscription period and payment terms depend on the selected Package and Subscription price description, unless the subscription is a promotional offer with separately specified price and validity.

3.8 Upon expiry of the Subscription term, Postimees Grupp will send the Subscriber a new invoice/sales offer to allow the Subscriber to conveniently continue their Subscription. If the Subscriber has expressed a wish not to receive offers, no new offer will be sent.

3.9 A standing order Subscription may be cancelled from the user account under "My Subscriptions" or through customer support. Upon cancellation, the Subscription remains valid until the end of the prepaid period and the prepayment will not be refunded.

3.10 In the case of an e-invoice standing order agreement, the first payment on e-invoices issued to the Subscriber may cover up to three subscription periods:

• The first period payment is calculated based on the Subscription price received by the time of invoice issuance for the past period;
• The second period payment is the Subscription price for the current period;
• The third period payment is an advance payment for the following period.

3.11 An e-invoice standing order Subscription may be cancelled through customer support, at a bank branch, or via online banking.

3.12 The consumer's 14-day right of withdrawal does not apply to agreements whose subject matter is:

• the supply of digital content not delivered on a physical medium;
• the delivery of newspapers, magazines or other periodically published publications (except for ongoing subscription agreements concluded for such publications).

User Account

4.1 To register as a user of the Postimees Grupp web environment, a person must be at least 13 years of age. Upon registration, a username (e-mail address) and password must be chosen.

4.2 The e-mail address used as the username must be in active use so that important notifications can be delivered.

4.3 The username and password are confidential information and must not be disclosed to third parties.

4.4 The User has the right to use Digital Products and Additional Services offered by Postimees Grupp only with their personal username and password.

4.5 Postimees Grupp has the right to require a change of the User Account password upon detection of a breach of the General Terms and Conditions, to restrict access to Digital Products and/or Additional Services, and/or to terminate the Subscription.

4.6 Postimees Grupp may close a User Account if the account has been inactive for 2 (two) consecutive years.

Availability of Digital Products and Applications

5.1 Postimees Grupp endeavours to ensure good and consistent availability of its Digital Product applications, but does not in any way guarantee their availability at all times and does not exclude the possibility of disruptions.

5.2 Postimees Grupp reserves the right to suspend the availability of its Digital Product applications at any time for technical or other reasons without prior notice to Users. Consequently, Postimees Grupp is not in any way liable for inconveniences or damages caused by such disruptions. Such disruptions do not give grounds for a refund of the subscription fee, price reductions or other financial compensation, except in cases where such disruptions are the result of intentional and deliberate action by Postimees Grupp.

5.3 Postimees Grupp is not liable for temporary or permanent damage or malfunctions that may arise from the use of Postimees Grupp Digital Product applications, including damage caused by viruses or malware, provided that their introduction into the Digital Products or applications and their spread is not the result of intentional or grossly negligent conduct by Postimees Grupp and is not within Postimees Grupp's control.

5.4 Postimees Grupp has the right to analyse the activities of Users of the web environment and Portals for the purpose of improving services, taking into account primarily the Users' previous service consumption history.

Advertisements

6.1 When publishing advertisements, we comply with advertising and other legislation, and the advertiser is obliged to comply with all requirements arising from the law (including the rights of other persons) and to act in accordance with the General Terms and Conditions. The advertiser is responsible for any claims, costs and damages arising from the advertisement that occur to Postimees Grupp or other persons.

6.2 The editorial team reserves the right to make linguistic and formatting corrections to advertisements, including obituary notices, without distorting the content. The editorial team does not undertake to verify or edit all informational content published in advertisements.

6.3 Advertisements ordered and paid for in read-aloud format on Radio Elmar (kuulutus.elmar.ee) are non-refundable due to the nature of the service. To cancel an advertisement, a written request must be submitted to elmar@elmar.ee stating the name of the subscriber indicated in the order and the publication date of the advertisement, at least 24 hours before the planned broadcast.

6.4 The Subscriber bears full responsibility for the informational content published in the Mälestusraamat.ee online obituary environment. Mälestusraamat.ee has the right to review content only to the extent necessary to assess its compliance with the General Terms and Conditions, applicable legislation and the principle of protection of the honour and dignity of persons, and the right to refuse to publish or to remove content if there is reasonable suspicion of a breach of these requirements.

6.5 By uploading any copyright-protected works (including images, photos, etc.) to the Mälestusraamat.ee online obituary environment, the Subscriber grants PMG a free non-exclusive licence to use the economic rights of such works, including to receive, store, use and delete the work in the online environment and to grant sub-licences. Also to permit and prohibit the reproduction, distribution, translation, adaptation of the work and to include the work in compilations or databases and to communicate it to the public. By uploading works to the online obituary environment, the Subscriber confirms that all rights related to the relevant content, including copyrights, belong to them and that they have all necessary rights to publish the materials in the online obituary environment.

6.6 Advertisements in the Mälestusraamat.ee online obituary environment are published immediately after payment is received. Advertisements remain in the obituary environment for the period selected by the Subscriber.

6.7 Postimees Grupp does not refund the fee for an advertisement published in the Mälestusraamat.ee online obituary environment. Upon the Subscriber's request, we will remove the advertisement from the obituary environment.

6.8 The Subscriber may change the content of a published advertisement before the end of the publication period by sending an e-mail with the change information to levi@postimees.ee. Changes will be made within one business day.

Newsletters

7.1 A newsletter is an e-mail sent to the Subscriber daily, once a week, once a month or less frequently, containing news from postimees.ee and its subdomains.

7.2 Subscribing to Postimees Grupp newsletters is free of charge. To subscribe to a newsletter, the User must enter their e-mail address on the website.

7.3 Postimees Grupp, as the data controller, may forward the newsletter subscriber's e-mail address to a third-party company as the data processor authorised by the Subscriber, who sends newsletters to subscribers on behalf of and for Postimees Grupp.

7.4 By subscribing to newsletters, the Subscriber gives Postimees Grupp a revocable consent to use their electronic contact details for the purpose of delivering newsletters.

7.5 You may unsubscribe from an ordered newsletter at any time via the "UNSUBSCRIBE" link at the bottom of the newsletter. Upon unsubscribing, the e-mail address will be removed from the list and the newsletter will no longer be sent.

7.6 For questions related to the delivery of newsletters, please contact levi@postimees.ee.

8.1 In providing the opportunity to comment, Postimees Grupp follows the good practice of commenting established by the Estonian Newspapers Association (EALL), the rules established by Postimees Grupp, and applicable legislation, as follows:

• comments containing obscenities; inciting hatred or war between peoples and races; spreading terrorist content; calling for the use of drugs or weapons, the overthrow or betrayal of the state, or physical violence against specific individuals; spreading false information or unjustifiably defaming other persons will be deleted from the commenting environment;
• it is prohibited to add advertisements and general links, to publish advertising and classified content, and to burden the comment section with empty, repetitive or off-topic comments;
• the User bears full responsibility for the content of their published comments. Publication of comments does not imply the approval or endorsement of Postimees Grupp;
• Postimees Grupp moderates comments with the aim of ensuring the civility, legality and quality of discussion. Moderation may take the form of both pre- and post-publication review and may include automated and human-intervention decisions;
• Postimees Grupp does not guarantee the publication of comments and may remove an inappropriate comment, restrict its visibility or apply other measures against the writing of inappropriate comments (application of word filters, blocking Users who have violated the rules, notifying law enforcement authorities);
• the application of comment moderation measures does not affect the validity of a digital subscription and does not give grounds for reducing the subscription price or withdrawing from the agreement, unless otherwise provided by law;
• upon the request of a court or other procedural body, all information saved in connection with a non-compliant comment must be disclosed.

8.2 By submitting only their own opinions, notices and other information through the Postimees Grupp web environment, the author simultaneously transfers the publication rights (author's economic rights) to the print publications of Postimees Grupp.

8.3 All works sent to Postimees Grupp via a web address are not subject to remuneration, unless the parties agree otherwise.

8.4 Only users who are at least 18 years of age and have authenticated themselves using an ID card, Mobile-ID or Smart-ID may comment in Postimees Grupp web environments. In order to increase the sense of responsibility among commenters and improve the quality of discussion, the commenter's first and last name will be published alongside the comment.

8.5 By publishing a comment, the commenter has given permission to process personal data contained in the comment that reveals racial or ethnic origin, political views, religious or philosophical beliefs or trade union membership, genetic data, biometric data used for the unique identification of a natural person, health data or data concerning a natural person's sex life and sexual orientation.

8.6 Postimees Grupp ensures the confidentiality of commenters' personal data (including contact address), except for the commenter's first and last name and data disclosed in the comment.

8.7 Postimees Grupp may transmit personal data to third parties if such transmission is required to fulfil a legal obligation arising from law, including to a court or other procedural body. Also in cases where the commenter has given Postimees Grupp consent to transmit their personal data.

Complaints

9.1 The User has the right to submit complaints to Postimees Grupp regarding:

• a Publication or its delivery – within 1 month of discovering the deficiency;
• an Advertisement – within 7 days of the date of publication of the advertisement;
• commenting and the blocking of a User – within 7 days of the relevant decision being communicated or becoming known, whichever occurs first;
• Additional Services – within 7 days.

9.2 Complaints must be submitted to levi@postimees.ee.

9.3 Complaints submitted to Postimees Grupp will be reviewed and responded to as soon as possible, but no later than within the period specified in clause 9.1 from the date of receipt of the notification.

9.4 Postimees Grupp undertakes to resolve the User's complaint if the reasons for the complaint are independent of the User.

9.5 The General Terms and Conditions do not limit the User's statutory right to refer a dispute to a court under applicable law. Consumers have the right to submit a complaint to the Consumer Disputes Committee.

Submitting Tips

10.1 Users may submit tips to Postimees Grupp about events and topics of interest or concern. When submitting tips, please note:

• by submitting a tip, you grant the right to publish the material;
• when submitting images and videos, the tipster confirms that the photo/video material was created by them;
• by submitting a tip through the Postimees Grupp web environment or by e-mail, the author simultaneously transfers the publication rights (author's economic rights) to the print publications of AS Postimees Grupp;
• by submitting a tip, the tipster consents to the processing of their IP address by AS Postimees Grupp.

10.2 When submitting a tip, the tipster has the option to add their contact details (name, contact phone number, e-mail address); by adding their data, the tipster consents to the processing of their personal data by Postimees Grupp.

10.3 By publishing a tip, the tipster has given permission to process personal data that reveals racial or ethnic origin, political views, religious or philosophical beliefs or trade union membership, genetic data, biometric data used for the unique identification of a natural person, health data or data concerning a natural person's sex life and sexual orientation.

10.4 All works sent to Postimees Grupp via a web address are not subject to remuneration, unless the parties agree otherwise.

10.5 Postimees Grupp ensures the confidentiality of tipsters' personal data, except where the disclosure of personal data to a third party (including upon the request of a court or other procedural body) is necessary to fulfil Postimees Grupp's legal obligation, and where the tipster has given Postimees Grupp consent to transmit their personal data (for the delivery of possible prizes, subscriptions, etc. to their address).

Additional Services

11.1 The User has the right to use the services of the Portals, including accessing content available therein, comparing products, setting up categories of interest and using other Portal functionalities in accordance with their availability and the General Terms and Conditions.

11.2 Through the Portals, the User may:

• compare prices and terms of products and/or services offered in the Portals, save them for later use and receive e-mail notifications about price changes for saved products and/or services. Sending notifications is an integral part of the Additional Services;
• navigate to the website or sales channel (e-shop) of the product and/or service provider;
• read and/or publish reviews and ratings (where this function is enabled);
• use other functions that Postimees Grupp may add or change over time.

11.3 Additional Services are informational in nature. The content of Additional Services (e.g. prices, service and product information) is sourced from public sources or from product and/or service providers and may differ from reality.

11.4 Postimees Grupp is not a party to purchase agreements for products and/or services displayed through the Portals and is not responsible for the content, characteristics, quality, availability, price or contractual terms of the products and/or services.

11.5 Postimees Grupp is not liable for:

• the content, security or privacy policy of third-party websites, nor for damages arising from the use of third-party products and/or services;
• errors, inaccuracies, changes or non-compliance with legislation arising from data on products and/or services displayed in the Portal, nor for the accuracy, clarity and compliance with applicable legislation of information presented to consumers.

11.6 Postimees Grupp has the right to change the content and availability of Additional Services, including changing the selection of Portal services, content, parameters, restrictions, procedures, menu structures of service delivery, usage logic, etc.

11.7 The availability, content and possible deficiencies of Additional Services are not connected to a Publication Subscription, do not affect its fulfilment, and do not give grounds for submitting complaints related to the Subscription.

Use of Materials

12.1 When using Postimees Grupp materials, the copyright of Postimees Grupp and its journalists in articles and other materials must be respected. This applies regardless of whether the material was obtained through news agencies, websites or other media.

12.2 Text, graphics, images, web design, sound and any other content of the Postimees Grupp website or Portals is protected by copyright. AS Postimees Grupp reserves all rights to the content, including the right to use the content for text and data mining purposes (with reference to § 19² of the Estonian Copyright Act and Article 4 of the DSM Directive). For further clarification, without prior written consent it is not permitted to use, facilitate or allow the use of this website and/or any content for any other purpose. This prohibition includes, but is not limited to:

• scraping of content,
• reproduction, modification, creation of compilations or excerpts of content,
• aggregation, analysis or mining of text and data,
• use of content for training artificial intelligence (AI) or machine learning models,
• any automated or robot-driven data collection,
• any use for commercial purposes.

The prohibition also applies through machine-readable means, including via metadata and website terms, in accordance with the Estonian Copyright Act and the DSM Directive.

12.3 The legal rules and principles of free use of works apply to the use of materials. In particular, referencing of articles is permitted on the grounds, in the manner and to the extent prescribed by legislation. Each time an article is referenced, the place of publication and the author of the referenced article must be disclosed. When referencing in an online environment, a link to the referenced material must also be added prior to the reference, in addition to the above. An article may generally be referenced to the extent of the title and one sentence. However, that sentence should not be longer than the introductory sentence of the original text. After the referenced material, an exact reference to the original Postimees Grupp material must be added online, reading: "Read the full text of the referenced article on the website of AS Postimees Grupp", which is clickable and links directly to the Postimees Grupp material that was used. The above requirements apply unless otherwise agreed.

12.4 For the avoidance of doubt, without the written or reproducible written consent of Postimees Grupp, it is not permitted to copy, publish or otherwise make available to third parties the materials in their entirety or in a volume exceeding that permitted by legislation, on any physical or electronic medium, including but not limited to social media. This rule also applies to videos on Postimees Grupp social media accounts. Including but not limited to, the automatic or non-automatic downloading or otherwise saving or processing of material, as well as forwarding the material to any third party, including for downloading purposes, is prohibited.

12.5 Use of materials beyond the scope of free use (including in their entirety), including the use of materials for any commercial purpose, is possible with the written or reproducible written consent of Postimees Grupp, provided that a licence agreement has been concluded with Postimees Grupp. For more information on the terms of the licence agreement and the licence fee, please contact the Postimees editorial team.

12.6 In the event of a breach of the conditions for the use and referencing of materials set out in this section, Postimees Grupp has the right to charge a fee according to the following price list:

• Single unlawful use of materials – €200 (VAT will be added)
• Repeated (two or more) unlawful use of materials – €320 per instance (VAT will be added)

Measures to Combat the Dissemination of Terrorist Content

13.1 When using Postimees Grupp services, it is not permitted to publish or disseminate, in accordance with Regulation (EU) 2021/784, terrorist content (text, image, audio recording, video, etc.), content promoting terrorism or inciting the commission of a terrorist act, or recruitment into terrorist organisations. It is also not permitted to publish content that provides instructions for the manufacture or use of explosives, firearms or other weapons or harmful or dangerous substances, including chemical, biological, radiological and nuclear materials (CBRN materials), in order to commit or create a threat of committing or contributing to a terrorist act referred to in points (a) to (i) of Article 3(1) of Directive (EU) 2017/541.

13.2 Postimees Grupp removes or blocks terrorist content without delay. Upon receipt of a removal order from the competent authority (the Estonian Internal Security Service), Postimees Grupp removes or blocks the terrorist content without delay, but no later than within one (1) hour of receipt of the removal order. In reviewing and removing content, Postimees Grupp follows the principles of diligence, proportionality and non-discrimination. The main measures for reviewing and moderating content are: technical filters and algorithms or other automated tools, reviewed by a moderator; the possibility to report inappropriate content by e-mail to intsident@postimeesgrupp.ee.

13.3 Postimees Grupp notifies the website user of the removal or blocking of content. At the User's request, Postimees Grupp will inform the user of the reasons for the removal or blocking of access to the content and their rights to challenge the removal order, or will provide the user with a copy of the removal order issued. The foregoing does not apply if the competent authority has prohibited this for reasons of public security.

13.4 Postimees Grupp retains removed content and related data securely for six (6) months. At the request of the competent authority or a court, terrorist content will be retained for an additional specified period. Postimees Grupp ensures that appropriate technical and organisational safeguards are applied to the retained terrorist content and related data, including personal data.

13.5 The User has the right to submit a complaint about the removal or blocking of content by e-mail to intsident@postimeesgrupp.ee, including information about the removed content and the reason why the decision to remove or block it should be reversed. Postimees Grupp will review the complaint within 2 (two) weeks of receipt and issue a decision on whether to uphold or reject the complaint. If the complaint is upheld, Postimees Grupp will restore the content without delay. If the complaint is rejected, the complainant has the right to apply to a court for the protection of their rights in accordance with the legislation of the Republic of Estonia. A complaint regarding a removal order or the non-disclosure of its content may be submitted to the competent authority within 48 hours of receiving information about the removal or restriction of access.