This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us. We take data protection seriously and are committed to complying with the General Data Protection Regulation (GDPR) of the European Union and other relevant data and privacy protection laws and regulations in your jurisdiction.

1. Data Controller

The data controller responsible for your personal information for GDPR compliance is Thorough Solutions OÜ, with its registered office at Ahtri 12, 15551 Tallinn, Estonia. You can contact us via the contact form on our website or directly via e-mail at info@thorough-solutions.com.

2. Types of Personal Data We Collect

We collect several types of personal data from and about users of our website and services, including:

• Identifying information: Your name and email address when you contact us.
• Transactional information: Details about the translations you request and data included in the texts you submit to us.
• Technical and usage data: Information such as your IP address, browser type, time zone settings, and how you navigate through the website, including pages visited and time spent on the site.

For more details on cookies and how you can manage them, please refer to our Cookie Policy.

3. Legal Basis for Processing Personal Data

We collect and process personal data based on the following legal foundations under the GDPR:

• Contractual Necessity: Processing is necessary for the performance of a contract with you, such as delivering purchased services or processing payments.
• Legitimate Interests: Processing is necessary for our legitimate interests, including:
  • Fraud prevention and maintaining security;
  • Improving the functionality of our website and services;
  • Analyzing and understanding how users interact with our website to improve user experience;
  • Ensuring business continuity and compliance with legal obligations.
• Consent: Where required, we obtain your explicit consent for specific processing activities, such as for marketing communications and other activities not covered by other legal bases.
• Legal Obligation: Processing is necessary for compliance with our legal obligations, such as tax reporting or responding to legal requests.

4. Purposes of Collecting Personal Data

We use the personal data we collect for the following purposes:

• Providing Services: To deliver the services you purchase, process payments, and communicate with you regarding your transactions.
• Communication: To respond to your inquiries, provide customer support, and keep you informed about our services.
• Enhancing User Experience: To improve the content and functionality of our website, ensuring it meets your needs and preferences.
• Legal Compliance: To fulfill our legal obligations, such as preventing fraud or responding to legal processes.

5. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements. Specific retention periods are as follows:

• Transactional Data: Retained for a minimum of six years for tax and accounting purposes.
• Correspondence Data: Retained for up to two years after the last communication with you.
• Technical and Usage Data: Retained for as long as necessary to ensure website functionality and security, in compliance with cookie expiration policies.

Upon the end of the necessity of processing your personal data, we will delete it or store it in a way that it can no longer be associated with you.

6. Data Collected by Third-Party Services

Our website uses third-party services such as Google Analytics and Google Search Console to analyze user behavior. Google Analytics anonymizes IP addresses before they are processed, and the data is aggregated to ensure that individual users are not identified. These services collect data independently of us.

For more information on these third parties’ practices, please refer to their respective data protection policies. If your personal data is transferred outside the European Economic Area (EEA), we ensure that appropriate safeguards, such as Standard Contractual Clauses (SCCs), are in place to protect your data.

7. Data Processing Agreements (DPAs)

We work with third-party processors who provide services such as payment processing, hosting, and email communication. We ensure that all third-party processors have signed Data Processing Agreements (DPAs) with us, in accordance with Article 28 of the GDPR. These agreements ensure that your personal data is processed only for the specified purposes and with the same level of protection that we provide.

8. Use of Your Personal Data

We use the personal data collected for the following purposes:

• Processing Payments: To process transactions and deliver your purchased services.
• Service Delivery: To manage interactions through our contact forms and provide the information or services you request.
• Security: To filter out spam, protect against fraud, and maintain the security of our website.
• Marketing: With your consent, to send you updates, offers, and news about our services.

9. Disclosure of Personal Data

We will never disclose or share personal data without your explicit permission unless required by law or in the strict context of the necessary processing outlined in this Privacy Policy. We do not sell personal data to third parties.

We may share your personal data with third-party processors who perform services on our behalf, such as payment processing, email communication, and data analysis. All third-party processors are required to comply with GDPR, have signed Data Processing Agreements (DPAs), and provide appropriate safeguards for your personal data.

10. Security Measures

We implement robust security measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption: Data is encrypted both in transit and at rest.
• Access Controls: Only authorized personnel have access to your personal data.
• Security Audits: We perform regular security audits and vulnerability assessments to ensure the integrity and confidentiality of your data.

11. Personal Data from Children

We do not knowingly collect personal data from children under the age of 16. If you believe your child has provided this kind of information on our website, we strongly encourage you to contact us immediately so that we can promptly remove it from our records.

12. Your Rights According to the GDPR

As a user of our website, you have the following rights concerning your personal data:

• Right to Access: You can access the personal data we hold about you.
• Right to Rectification: You can request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have the right to request that we delete your personal data, provided there are no legal grounds for us to continue processing it.
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest its accuracy.
• Right to Data Portability: You can receive a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data for specific purposes, such as direct marketing, profiling, or scientific research.
• Right to Withdraw Consent: If we rely on your consent as the legal basis for processing your personal data, you can withdraw your consent at any time.

To exercise these rights, please contact us using our contact form or send us an email at info@thorough-solutions.com. We may need to verify your identity before fulfilling your request. We will respond within one month unless the request is complex or numerous, in which case we may extend the response period by up to two additional months.

Please note that exercising your rights may be subject to certain limitations or exemptions, depending on the specific circumstances and the applicable laws. If you are dissatisfied with our response, you have the right to lodge a complaint with the relevant Data Protection Authority (DPA) in your jurisdiction. For users in the European Union, you can find your local DPA’s contact details here.

13. Automated Decision-Making and Profiling

We do not engage in automated decision-making, including profiling, that produces legal effects or similarly significant impacts on you. Should we introduce any form of automated decision-making in the future, we will notify you in advance, provide the necessary legal basis (such as explicit consent), and update this Privacy Policy accordingly.

14. Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will notify the relevant authorities within 72 hours and inform you by email as soon as possible.

15. Contact

If you have any questions about this Privacy Policy or want to exercise any of your rights under the GDPR, please contact us via our contact form or send us an email at info@thorough-solutions.com.

16. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. All changes will be posted on this page, and the updated effective date will be reflected in the Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. It is your responsibility to stay updated on any changes by checking this policy periodically.

17. Cookie Policy

Please also review our Cookie Policy more information on how we use cookies and similar technologies.

This Privacy Policy was last updated on September 14, 2024.