Privacy Policy
This policy explains what personal data Silvermind OÜ collects, why we collect it, and what you can do about it. We keep data collection to the minimum we need to run our business.
01Who we are
Silvermind OÜ is a software development company registered in Estonia. For the purposes of the EU General Data Protection Regulation (GDPR), we are the data controller for the processing described in this policy.
02What this policy covers
- Our website at silvermind.cc.
- Email and other correspondence with us.
- Mobile and web applications published by Silvermind OÜ under our own name.
Applications we build for clients are governed by that client's own privacy policy. In those projects the client is the data controller and we act as a processor under a written agreement.
03Data we collect
Information you send us
When you email us, we receive your email address, your name if you provide it, and whatever you choose to write. We use it only to answer you and to keep a record of the enquiry.
Server logs
Our hosting provider records standard technical information when a page is requested: IP address, date and time, requested URL, referring page, and browser user agent. These logs exist for security and reliability, and are not used to build profiles of visitors.
Cookies and analytics
This website does not set advertising or tracking cookies, and does not use third-party analytics or advertising networks. Web fonts are loaded from Google Fonts, which means your IP address is visible to Google when the font files are requested.
Applications
Where one of our own applications collects personal data, the specific categories, purposes and retention periods are described in the privacy notice shown in that application and on its store listing. We do not sell personal data, and we do not use it for advertising.
04Why we process data, and on what legal basis
- To respond to enquiries and manage client relationships — legitimate interest, or performance of a contract where an agreement is in place.
- To keep our systems secure and available — legitimate interest in preventing abuse and diagnosing faults.
- To meet accounting, tax and other statutory duties — compliance with a legal obligation under Estonian and EU law.
05Who we share data with
We share personal data only with service providers who help us operate, and only to the extent they need it. These currently include our website hosting provider, our email provider, and our accounting service. Each of them acts under a contract that requires appropriate confidentiality and security measures.
We may also disclose data where we are required to do so by law, or to establish or defend legal claims.
06International transfers
We prefer providers located in the European Economic Area. Where a provider processes data outside the EEA, the transfer is made under safeguards recognised by EU law, such as the European Commission's Standard Contractual Clauses or an adequacy decision.
07How long we keep data
- Email correspondence: up to 3 years after our last exchange, unless a contract requires longer.
- Server logs: typically up to 90 days.
- Accounting records: 7 years, as required by Estonian law.
08Your rights
Under the GDPR you may request access to the personal data we hold about you, ask us to correct or erase it, ask us to restrict or object to processing, and request a copy in a portable format. Where processing is based on consent, you may withdraw that consent at any time.
Write to contact@silvermind.cc and we will respond within one month. If you believe we have handled your data improperly, you may lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, aki.ee) or with the supervisory authority in your country of residence.
09Children
Our website and our services are directed at businesses and are not intended for children. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will delete it.
10Security
We use encrypted connections, restricted access to production systems, and multi-factor authentication on the accounts that hold personal data. No method of transmission or storage is completely secure, but we work to keep the risk proportionate to the data involved.
11Changes to this policy
When this policy changes, we update the date at the top of the page. Material changes will be highlighted on this page before they take effect.
12Contact
Questions about this policy or about how we handle personal data go to contact@silvermind.cc, or by post to Silvermind OÜ, Lootsa tn 5, Tallinn, Harjumaa 11415, Estonia.