Privacy Policy

Last Updated: October 23, 2025

1. Introduction

UpSmart OÜ (“we,” “us,” or “our”) is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, and protect your information when you visit our website upsmart.ee (the “Website”).

We operate in accordance with the General Data Protection Regulation (GDPR) and Estonian data protection laws.

2. Data Controller

UpSmart OÜ
Registry Code: 16200741
Address: Heldri tee 15, Haabneeme alevik, 74001 Viimsi vald, Harju maakond, Estonia
Email: upsmart@upsmart.ee

For any privacy-related inquiries, please contact us at the email address above.

3. What Information We Collect

We collect minimal personal information through our Website:

3.1 Information You Provide

When you submit our contact form, we collect:

Your name
Your email address

3.2 Information Collected Automatically

We use Google Analytics to collect anonymized data about how visitors use our Website, including:

Pages visited
Time spent on pages
Browser type and version
Device information
Geographic location (country/city level)
Referral sources (how you found our Website)

We do not collect any sensitive personal data such as financial information, health data, or information about minors.

4. How We Use Your Information

We use your personal information for the following purposes:

Contact Form Submissions: To respond to your inquiries and communicate with you about your questions or requests
Website Analytics: To understand how visitors find and use our Website, and to improve our services and user experience

We do not use your information for marketing purposes, and we do not send newsletters or promotional emails.

5. Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

Consent: When you submit the contact form, you provide consent for us to process your name and email address to respond to your inquiry
Legitimate Interest: We have a legitimate interest in analyzing website traffic to improve our services and understand our audience

6. Data Sharing and Third Parties

We share your information only with the following third-party service provider:

Google Analytics: We use Google Analytics to analyze website traffic and usage patterns. Google Analytics collects anonymized data and is subject to Google’s privacy policy. You can learn more about how Google uses data at https://policies.google.com/technologies/partner-sites

We do not sell, rent, or trade your personal information to third parties. We do not transfer your data outside the European Economic Area (EEA).

7. Cookies and Tracking Technologies

Our Website uses cookies through Google Analytics to collect anonymized usage data. Cookies are small text files stored on your device that help us understand how you use our Website.

You can control and manage cookies through your browser settings. Please note that disabling cookies may affect the functionality of our Website. For more information about managing cookies, visit www.allaboutcookies.org.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy:

Contact Form Data: We retain your name and email address for as long as necessary to respond to your inquiry and maintain a record of our communication. This data is deleted in accordance with GDPR requirements
Analytics Data: Google Analytics data is retained according to Google’s data retention policies and our configured settings

9. Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

Right of Access: You can request access to the personal data we hold about you
Right to Rectification: You can request that we correct any inaccurate or incomplete data
Right to Erasure: You can request that we delete your personal data
Right to Restrict Processing: You can request that we limit how we use your data
Right to Data Portability: You can request a copy of your data in a machine-readable format
Right to Object: You can object to our processing of your personal data
Right to Withdraw Consent: You can withdraw your consent at any time

To exercise any of these rights, please contact us at upsmart@upsmart.ee. We will respond to your request within one month.

10. Data Security

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no internet transmission is completely secure, and we cannot guarantee absolute security.

11. Children’s Privacy

Our Website is not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If you believe we have collected data from a child under 16, please contact us immediately, and we will delete such information.

12. WordPress and WPForms

We use WordPress as our content management system and WPForms plugin to manage our contact form. These tools are configured to comply with GDPR requirements. We do not allow user comments or account creation on our Website.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post any changes on this page with an updated “Last Updated” date. We encourage you to review this Privacy Policy periodically.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

UpSmart OÜ
Email: upsmart@upsmart.ee
Address: Heldri tee 15, Haabneeme alevik, 74001 Viimsi vald, Harju maakond, Estonia

15. Supervisory Authority

If you believe that we have not handled your personal data in accordance with GDPR, you have the right to lodge a complaint with the Estonian Data Protection Inspectorate:

Andmekaitse Inspektsioon
Address: Tatari 39, 10134 Tallinn, Estonia
Phone: +372 627 4135
Email: info@aki.ee
Website: www.aki.ee

This Privacy Policy is governed by Estonian law and GDPR regulations.