Privacy notice

Who is the owner, manager and developer of the voter application?

The voter application allows you to vote electronically on a smart device. Electronic voting is one of the types of voting prescribed by the electoral laws in force in Estonia. The voter application belongs to the Republic of Estonia. The controller and administrator of the voter application is the State Electoral Office, which is part of the Chancellery of the Riigikogu and operates independently based on the Election Acts. The voter application has been technically developed by Cybernetica AS based on a contract. You can contact the State Electoral Office by e-mail: [email protected]. You can contact Cybernetica AS by e-mail: [email protected].

This Privacy Notice describes what type of information is collected when you use the voter application and how that information is used.

You will also learn how and with whom to contact.

This privacy policy is available in the voter application and on the website of valid.ee.

What personal data is processed?

The voter application is intended for internet voting in elections taking place in Estonia. The voter application enables voters to make a choice using the voter application, encrypt it, digitally sign it and send an electronic vote to the electronic ballot box (collector component), which is managed by the authorised processor Estonian Information System Authority ([email protected]).

The voter application processes personal data necessary for electronic voting. The data is processed to comply with the legal obligation under Article 6(1)(c) of GDPR and the legal obligation under Article 9 arises from Article 15(1)(1) of the Riigikogu Election Act. Without the processing of personal data, it is impossible to organize internet voting and elections.

The list of voters and amendments there shall be forwarded to the voter application by the electoral information system. The electoral information system receives the list of voters and amendments there from the Ministry of the Interior through the data exchange layer of information systems. If you find an error in the list of voters and make changes, please contact the Estonian population register at [email protected].

When you use the voter application, the following data is processed:

Categories of data	Legal basis for processing	Purpose of data processing
User's personal identification code	§ 48⁵ (2) and 48⁶ (5) 1) of the Riigikogu Election Act.	Necessary for identification. User input and transferred to the backend for authentication.
User's phone number (using mobile ID)	Section 48(4)(2) of the Riigikogu Election Act.	Necessary for identification. User input and transferred to the backend for authentication.
Name corresponding to the personal identification number	Section 48(4)(2) of the Riigikogu Election Act.	Necessary for identification. From the back interface procured because of authentication.
Answer to the question of whether a user is a voter or not	Section 48(4)(2) of the Riigikogu Election Act.	Necessary for identification. From the back interface it procured because of authentication.
IP address of the voter's device	Section 48⁶(5)(1) of the Riigikogu Election Act.	Necessary for backend and user interaction. Detecting attacks or fraud. The IP is logged in the technical logs.
Country of location corresponding to the Internet Protocol address	Section 48⁶(5)(1) of the Riigikogu Election Act.	The country is logged in the technical logs. Detecting attacks or fraud.
Date and time of the start of voting	Section 48⁶(5)(1) of the Riigikogu Election Act.	Detecting attacks or fraud. The date and time are logged in the technical logs.
Electoral constituency	Section 48⁶(5)(1) of the Riigikogu Election Act.	To show the electorate the candidates of his constituency.
Validation and recording of electronic votes: the date and time of the closing of the vote, the issuer of the certificates and information on the validity of the certificates.	Section 48⁶(5)(2) of the Riigikogu Election Act.	Detecting attacks or fraud. Log in to technical logs.
List of candidates (selection list): the candidate’s registration number; the candidate’s first name and surname; the name of the political party or election coalition; electoral district and local government council elections for rural municipality or city name; answer options (by referendum).	Section 48⁵(4) of the Riigikogu Election Act.	To display the candidates and the selection.
Choice of the voter's plain text from the list of candidates (choices) - Choice chosen by the voter and encrypted/digitally signed by the application	Section 48(5)(5) of the Riigikogu Election Act.	Voters to make a choice
Encrypted and digitally signed electronic vote – created in the application and transmitted to the electronic ballot box (collector component) during the voting process.	Section 48(5)(5) of the Riigikogu Election Act.	For the formation and transmission of electronic votes

The voter application shall classify the vote of the voter in such a manner that upon forwarding the vote it is not possible to see whom the voter voted. Although the voter application has access to the voter's personal identification number and selection, this information is not transmitted outside the user's device. The voter's choice is transmitted to the electronic ballot box (collector's component) as an encrypted and digitally signed electronic vote, which is processed while preserving the voter's privacy. The voter receives confirmation of the acceptance of the vote in the voter application. The confirmation also displays a QR code, which allows the voter to check their choice on another smart device with a separate application called the EH Kontrollrakendus application.

The principle of secrecy of votes shall be guaranteed to every voter, including minors, with special attention at every stage of voting, including after the cancellation of an electronic vote. The electronic voting system shall ensure that, before counting electronic votes, the personal data of a voter shall be separated from the internet vote in such a manner that the voter's declaration of intent cannot be ascertained.

After the internet voting is completed, the logs will be anonymised.

Internet voting and counting of votes are organised in such a way that it is not possible to establish a link between the voter and the open vote.

How is the data stored and published?

The voter application respects the privacy of the voter. For this reason, the voter application processes and stores only personal data that is necessary for the organisation of elections. The electronic vote shall be recorded and stored encrypted in the electronic ballot box (and collector component) until the electronic votes are destroyed. Electronic votes and unanonymised logs shall be destroyed one month after election day and until all electoral complaints have been resolved. Anonymised logs shall be stored by the State Electoral Office for an unspecified term. Anonymised logs may be used for scientific purposes.

The collected personal data, but no choices, are only given to law enforcement authorities for the conduct of proceedings in justified cases. The technical solution of the voter application allows data to be protected against unauthorised access, alteration, disclosure, removal and tampering.

The data in the voter application is not transferred to third countries or cloud services are used. All processing operations remain within the European Economic Area.

How is the data secured?

All data shall be treated as confidential.
Only encrypted connection TLS is used.
Use of cryptographic electronic voting protocols to ensure the confidentiality of the vote.
restricting access to personal data to people who need the information to process the data and who are subject to contractual confidentiality obligations.
Personal data shall be protected by appropriate IT technical and organisational protection measures.

Alternatives to the voter application

The voter application allows you to vote electronically on a smart device. Voters can also participate in electronic voting in the voter application created for desktop and laptop computers, which can be found on the valmised.ee website. Voters also can vote at polling stations and cast their votes on paper.

What are your rights?

As a subject of data, you have the following rights:

Right of access - pursuant to law, a voter has the right to access his or her data in the list of voters. To do this, you must contact the State Electoral Office with a written application at [email protected];
Right to rectification - You have the right to have your personal data rectified and/or completed if the personal data processed concerning you is incorrect or incomplete. To correct and amend the data, please contact the Estonian population register at [email protected].
Right to erasure – by law, all voters who have the right to vote have the right to vote and the law does not provide for the right of voters to erase their personal data.
Right to restriction of processing - pursuant to law, the voter does not have the right to request restriction of processing of personal data.
Right to data portability – by law, the voter has no right to data portability.
Right to object to automated decision-making – the voter application does not take automated decisions or profiling, so there is no right to contest the automated decision concerning you.

Submitting questions and complaints

If you have any questions or objections regarding the processing of personal data, please contact the State Electoral Office (Lossi plats 1a, 15165, Tallinn, phone +372 631 6633, e-mail [email protected]).

If you believe that the processing of your personal data violates your rights, you can lodge a complaint with the Data Protection Inspectorate (Tatari tn 39, 10134 Tallinn, telephone +372 627 4135, e-mail [email protected]) or file a claim with an administrative court.

06.05.2025

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