Privacy policy

Who processes your data

We have not appointed a data protection officer, as none of the cases in art. 37 GDPR applies to us. For any question about your data, write to us at [email protected].

What data we collect

We only process the data you give us and the data your visit generates:

We do not ask for special categories of data (health, beliefs, ethnic origin…) and we would ask you not to include them in the form message.

Why we use it and on what legal basis

Who else has access to your data

We do not sell or trade your data. It is only shared with the providers we need in order to operate, which act as processors and strictly on our instructions:

We may also disclose data to public authorities or courts where the law requires it.

International transfers

Some of these providers are US companies and may process data outside the European Economic Area. When that happens, the transfer relies on the adequacy decision of the EU-US Data Privacy Framework or on standard contractual clauses approved by the European Commission, together with the additional safeguards each provider documents.

Your rights

You can exercise the following rights at any time, free of charge:

Write to [email protected] telling us which right you want to exercise. We will reply within one month at the latest. If you believe we have not handled your request properly, you can lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), which is the lead supervisory authority because the company is established in Estonia. Art. 77 GDPR also lets you complain to the data protection authority of your own country of residence.

Profiling and automated decisions

If you have written to us or subscribed, HubSpot links your visits to the site with your contact record. That lets us know which topics interest you before a commercial conversation, and it is profiling within the meaning of art. 4(4) GDPR.

We make no automated decisions that produce legal effects concerning you or similarly significantly affect you (art. 22 GDPR). You can object to this tracking at any time: reject the “Marketing & contact” category in the cookie notice, or write to us.

Children

This site is aimed at professionals and companies, not at children. We do not knowingly collect data from children under 13, the threshold set by § 8 of the Estonian Personal Data Protection Act (isikuandmete kaitse seadus) under art. 8 GDPR, and also the age COPPA requires in the United States. In other EU countries that threshold goes up to 16; if that is your case, we will apply the one that corresponds to you. If you are a parent or guardian and believe a child has given us their data, write to us and we will delete it.

Security

The whole site is served over HTTPS, the forms are protected with reCAPTCHA, and access to the data is limited to the team members who need it. We apply reasonable technical and organisational measures to prevent loss or unauthorised access, although no system is infallible.

If you live in the United States

This section answers California’s CalOPPA and the state privacy laws that may apply to you. It operates alongside the rest of this policy, not instead of it.

What we collect and where it comes from

We use it to reply to you, send the newsletter if you asked for it, understand how the site is used and keep it secure. Only the providers listed above receive it, acting on our behalf.

Selling, sharing and advertising

We do not sell personal information and we do not share it for cross-context behavioural advertising, as the CCPA/CPRA and the other state laws define those terms. We also use no third-party advertising pixels.

We do use cookies from HubSpot, our CRM, to link visits to contact records for our own commercial follow-up. That is neither a sale nor sharing under those laws, but you can switch it off by rejecting the “Marketing & contact” category in the cookie notice.

Your rights and how to exercise them

Depending on your state, you may have the right to: know what data we hold and get a copy, correct it, delete it, take it with you in a portable format, opt out of its sale or sharing and of targeted advertising, limit the use of sensitive personal information (we process none), and appeal if we turn your request down. We will not treat you differently for exercising any of them.

There are two ways to ask: by email at [email protected], or by post to our registered address, shown at the top of this page. We reply within the deadlines your state sets, and if we refuse a request we tell you why and how to appeal.

To verify your identity we will ask you to write from the address already in our records, or to give us enough detail to find your record. If you act as someone’s authorised agent, we need their written authorisation and may confirm it with them directly.

Do Not Track and Global Privacy Control

We do not respond to the browser’s Do Not Track signal, because there is no common standard for interpreting it. We do honour Global Privacy Control: if your browser sends it, no non-essential cookies are set.

Changes to this policy

We may update this policy if the services we use or the applicable rules change. The date of the latest review is shown at the top of the page.