Summary

Recently, a collision between the freedom of speech and the right of privacy has become a topical issue in Estonia.
This article provides an overview of the concept of privacy, its development and the scope of its present legal meaning in the Continental European legal system based on Roman law traditions and in common law countries. In this context, the author compares the legal systems of the USA and Germany. Further, the author also briefly analyses Article 8 of the European Convention on Human Rights and the Estonian Acts pertaining to the corresponding area.