Privacy Policy and Personal Data Protection

Smiddle International OÜ
Last updated: February 27, 2026

This Privacy Policy defines the procedure by which Smiddle International OÜ (hereinafter referred to as the Company, "we") collects, processes, and protects the personal data of users of the web resource www.smiddle.com (hereinafter referred to as the Website), which we automatically receive when you, the subject of personal data, use our web resources or which may be directly provided to us by you through the Website.

Terminology

In this Policy, the terms are used in the following meanings:
User (Personal Data Subject) — a natural person (in particular, a representative of a legal entity or an individual entrepreneur) who visits the Website and/or provides their data through registration forms to receive services or information.
The owner (Controller) of personal data is Smiddle International OÜ (registration number: 12827845), which independently determines the purpose, composition, and procedures for data processing.
Personal data — any information that allows direct or indirect identification of the User, including name, phone number, email address, and the name of the company they represent.
Processing of personal data — any action (collection, storage, use, transfer, etc.) performed by the Company with the User's data to ensure the operation of the Site's services.
Website — a web resource located at www.smiddle.com, which is informational and marketing in nature.
Cookies — text files stored on the User's device that help ensure the stable operation of the Website, analyze traffic, and customize relevant advertising.
Consent — the User's voluntary permission to process their data, provided by filling out forms on the Website or through the Cookie Banner settings.

1. General

The Website is informational and marketing in nature. When the User uses the Website's services, the User's data is processed, namely:
• data provided by the user both when filling out registration forms and in the process of using the services;
• cookie files;
• IP addresses;
• Internet browser parameters and settings (User-agent).

We limit ourselves to collecting only the minimum amount of information necessary to fulfill the personal data subject's request. Through the Website, the Company may process the following personal data:
• first and last name;
• phone number;
• email address;
• company name;
• other information that the user voluntarily provides in the request form.

We do not collect or process special categories of personal data (sensitive data) as defined in Article 9 of the GDPR, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, or data concerning a person's sex life or sexual orientation.

We may collect statistics on visits to the Website. The information may include information about the connection, traffic, user's browser, as well as the date, time, duration of Internet use, and location on the Website.

2. Personal data controller

The owner and controller of the personal data of the Site users is Smiddle International OÜ.
Registration number: 12827845
Address: Harju maakond, Tallinn, Kesklinna linnaosa, Viru väljak 2, 10111, Estonia.
Contact phone number: +372 54773581

The Company acts as the Data Controller and processes personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable Estonian data protection laws.
For any inquiries regarding your personal data or to exercise your rights (access, rectification, erasure, restriction of processing, or data portability), please contact us at: This email address is being protected from spambots. You need JavaScript enabled to view it..

3. Processing of personal data

3.1 The processing and storage of personal data provided is carried out in data centers where equipment ensuring the functioning of the Website's services is located. The personal data provided is processed and may be stored in the Database (Personal Data Database or a separate table of the Website Database).
3.2. Personal data is processed solely for better providing the necessary services and information, as well as to:
• respond to questions and requests;
• process orders;
• analyze user behavior on the site.
3.3. The Company may use personal data in the course of direct marketing.
3.4. We process your personal data based on GDPR for the following purposes:
• providing website services, software access, and information exchange;
• marketing, communications, and handling support requests;
• ensuring IT security (preventing cyberattacks) and system stability.

4. Principles of personal data processing

The User's personal data:
4.1. is processed in a lawful, fair, and transparent manner in relation to the data subject (User);
4.2. collected for specified, explicit, and legitimate purposes and will not be further processed in a manner that is incompatible with those purposes;
4.3. processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing.

5. Analytics and cookies

The website may use statistical data collection services such as Google Analytics and others. Analytical cookies are used only with the user's consent. The company may use marketing cookies to set up targeted advertising and remarketing.
5.1. Use of cookies
Cookies are text files containing a small amount of information that are sent to a web browser and stored on the user's device. Such devices include a computer, mobile phone, or other device used by the user to visit the Website.
Cookies can be permanent (called persistent cookies) and stored on the computer until the user deletes them, or temporary (called session cookies), which are stored only until the browser is closed. In addition, cookies are divided into first-party cookies (set directly by the visited Website) and third-party cookies (set by other websites).
Important:
• when the user revisits the Site, the cookie data is updated;
• In most cases, the web browser allows cookies to be stored on the user's device by default;
• Disabling cookies may result in restricted access to published materials and/or incomplete functioning of the Site's services.
Visiting and using the Site's web resources is completely anonymous; only technical information about sessions, statistics on popular queries, database searches, information about errors, and other non-personalized data is collected for the purpose of further improving the service.
The main purpose of using cookies on this site is to ensure functionality, provide higher-quality personalized services, and store information when working with our websites.
According to EU Directive 2009/136/EC, a website may store cookies on your device if they are essential for its operation, but consent must be obtained for the storage of cookies.
Cookies help us ensure the stable operation of the Website, remember your settings, and analyze traffic.

Categories of cookies we use:
• Technical (necessary): ensure the basic functioning of the Website and its security. They are activated automatically and do not require your consent, as without them, the Website will not be able to function properly.
• Analytical and statistical: help us understand how users interact with the Website (for example, which pages are the most popular). This includes cookies from third-party services and analytics services such as Google Analytics, Gemius, and others. This data is collected in aggregate form and does not identify you directly.
• Marketing: used to track visitors on various websites to display relevant advertising (remarketing), in particular to promote the software products Smiddle. This includes cookies from third-party services such as Facebook, LinkedIn, Instagram, and others.
User information obtained through cookies is not sold or distributed in the public domain and is the property of the organization that owns the resource. Data obtained from third-party services is not stored or processed.
Please note that the Website cannot control the use of third-party services. All necessary information about their use is available in the relevant resource.

5.2. Consent management
We use analytical and marketing cookies only with your prior consent, provided through the Cookie Banner on the Website.
• You can change your settings or withdraw your consent at any time by clearing the cookies in your browser or contacting us.
• You can independently restrict or block the use of cookies by changing the appropriate settings in your web browser. Please note that disabling certain cookies may affect the availability of certain features of the Website.
• If, for any reason, a user does not want third-party services (such as Facebook, LinkedIn, Instagram, and others) to access their personal data, users can log out of their account or profile at any time and clear their cookies (via their browser).
5.3. Marketing communications
If consent is given, the user may receive informational and marketing messages from the Company. The user has the right to opt out of receiving such messages at any time by:
• using the unsubscribe link (in the case of email newsletters);
• contacting the Company at This email address is being protected from spambots. You need JavaScript enabled to view it..
Consent to receive marketing communications is voluntary and is provided separately from consent to the processing of other personal data.

6. Restrictions under the Privacy Policy

The Website user must comply with the following rules:
6.1. Not to use the website inappropriately, not to attempt to influence or interfere with its operation, or to access information other than through the standard interface.
6.2. To use the Website exclusively in compliance with the laws of the Republic of Estonia and all applicable international and EU legal standards.

7. Rights of personal data subjects (users).

The user has the right to:
7.1. know the location of their data, the conditions for providing access to it to third parties, and receive confirmation of the fact of its processing.
7.2. make a reasoned request to change or destroy their data if it is being processed illegally.
7.3. Protection against unlawful processing, as well as legal protection in case of violation of the law.
7.4. Withdraw consent to processing at any time by contacting the Owner (except where processing is required by law).
7.5. to file complaints with state human rights bodies or in court.
7.6. The legal representative of a User with limited civil capacity or recognized as incapacitated shall exercise the rights regarding their personal data.

8. Transfer of personal data to third parties

8.1. The Company does not transfer personal data to third parties, except in cases where such transfer is required by law, at the request of the personal data subject, when it is necessary to fulfill a user request, or when contractors acting on behalf of the Company and based on confidentiality agreements are involved.
8.2. Except as provided in this privacy policy, the Company will not disclose any personal information unless the Company is required to do so by law or if such action is necessary to protect or prevent our rights, property, or personal safety, as well as that of our users/customers and other individuals.
8.3. The Site may contain links to other websites (for informational purposes only). When you follow a link to other websites, this Policy will not apply to such sites. Therefore, we recommend that you review the privacy and personal data policies of each website before submitting any personal data that could identify you.
In compliance with personal data protection laws, including the GDPR, the Company ensures the security of your personal data by implementing appropriate technical and organizational measures.

9. Personal data retention periods

Marketing data is stored until consent is withdrawn, and data relating to requests is stored for 3 years after the last contact.

10. Protection of personal data

The company uses organizational and technical security measures to protect personal data from unauthorized access, loss, or disclosure.

11. Changes to the Policy

We may make changes to this Privacy Policy, including in response to changes in legal requirements. Please review this Policy from time to time.

12. Contact Information

For all questions related to the protection of your personal data, please contact us at: This email address is being protected from spambots. You need JavaScript enabled to view it..