Privacy Policy
1. Data Controller
This website is operated by:
2Matter OÜRegistry code: [PLACEHOLDER: Insert Estonian registry number]
Registered address: [PLACEHOLDER: Insert registered address]
Email: [email protected]
2Matter OÜ is the data controller responsible for processing personal data collected through this website in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR").
2. Personal Data We Process
We process minimal personal data through this website:
Server logs
When you visit this website, our hosting provider automatically collects technical data including IP address, browser type, operating system, referring URL, and access timestamps. This data is collected for security monitoring and website functionality.
Email correspondence
If you contact us via email, we process the personal data you provide (name, email address, message content) to respond to your inquiry.
3. Legal Basis for Processing
| Processing activity | Legal basis (GDPR Article 6) |
|---|---|
| Server logs | Legitimate interest in website security and functionality (Art. 6(1)(f)) |
| Email correspondence | Your consent, implied by voluntary initiation of contact (Art. 6(1)(a)) |
4. Data Sharing
We share personal data only with the following service providers, necessary for website operation and communication:
| Provider | Purpose | Location/Adequacy |
|---|---|---|
| DigitalOcean, LLC | Website hosting, server logs | EU data center (Frankfurt); Standard Contractual Clauses for US entity |
| Microsoft Corporation | Email processing (Microsoft 365) | EU Data Boundary; Standard Contractual Clauses |
We do not sell personal data. We do not share personal data with third parties for marketing purposes.
5. Data Retention
Server logs: Retained according to our hosting provider's standard retention period for security and operational purposes.
Email correspondence: Retained for the duration of business relevance, plus any legally mandated retention periods under Estonian or EU law.
6. Your Rights
Given our minimal data processing, the following rights are practically applicable:
If you have contacted us by email:
- Access — Request confirmation that we hold correspondence from you and obtain a copy
- Erasure — Request deletion of your email correspondence from our systems
Regarding server logs:
- Objection — Object to the processing of your IP address and technical data under our legitimate interest basis
Server logs are managed by our hosting provider according to their retention schedule; we cannot retrieve or delete individual log entries but can forward objection requests.
To exercise any right, contact us using the details provided in Section 1. We will respond within one month of receipt.
Complaint: You may lodge a complaint with the Estonian Data Protection Inspectorate or your local supervisory authority if you believe your rights have been violated.
7. Cookies and Tracking
This website does not use cookies, analytics tools, or tracking technologies.
8. Changes to This Policy
We may update this Privacy Policy to reflect changes in our practices or legal requirements. The effective date at the top of this document indicates the latest revision.