This Privacy Policy explains how Anchor Global OÜ processes personal data in connection with its website, business activities and professional relationships.

Anchor Global OÜ
Private limited company incorporated under the laws of the Republic of Estonia

Registry code: 17553594

Registered office: Narva mnt 5., 10117, Tallinn, Estonia

Registered with: Estonian Commercial Register

Website: https://mail.anchorglobal.eu

Email: info@anchorglobal.eu

Anchor Global OÜ acts as the data controller and processes personal data in accordance with the EU General Data Protection Regulation (GDPR), the Estonian Personal Data Protection Act and other applicable laws.

2.1 Depending on how you interact with us, we may process:

• your name, company, job title and contact details;
• business correspondence, enquiries and professional information;
• contractual, invoicing and transaction information;
• information submitted through our website or by email; and
• technical information generated when you access our website, such as your IP address, date and time of access, browser type, device-related information and server access or error logs.

We may receive personal data directly from you or your organisation. Where we obtain personal data indirectly, the information may originate from your employer or organisation, professional contacts, business partners, publicly accessible corporate or professional registers, professional networking platforms, company websites or other legitimate business sources.

2.2 Where personal data are obtained from a source other than the individual concerned, we process such information only where we have an applicable legal basis under the GDPR and other applicable law.

3.1 We process personal data for specific business and legal purposes. The applicable legal basis depends on the particular processing activity:

• Enquiries and business correspondence: our legitimate interest in responding to business enquiries and maintaining professional communications, and, where applicable, taking steps at the request of the data subject prior to entering into a contract;
• Preparing proposals and entering into contracts: taking steps at the request of the data subject prior to entering into a contract and, where applicable, performance of a contract, pursuant to Article 6(1)(b) GDPR;
• Providing advisory, consulting, representation, brokerage and related services: performance of a contract, or taking steps prior to entering into a contract, where applicable;
• Managing client, partner and supplier relationships: performance of a contract where applicable, or our legitimate interest in managing and maintaining business relationships;
• Payments, invoicing and accounting: compliance with legal obligations applicable to us, including accounting, tax and financial-record keeping requirements;
• Compliance with legal and regulatory obligations: compliance with a legal obligation to which Anchor Global OÜ is subject;
• Protecting legal and commercial interests: our legitimate interest in establishing, exercising or defending legal claims and protecting our lawful business interests;
• Website and IT security: our legitimate interest in operating, maintaining and securing our website, systems and infrastructure, including preventing misuse, unauthorised access and security incidents; and
• Direct marketing: consent where prior consent is required by applicable law, or another applicable legal basis where permitted, subject to the specific requirements applicable to electronic direct marketing in Estonia.

Where we rely on legitimate interests, our legitimate interests include responding to and maintaining business communications, developing and maintaining professional relationships, protecting our business, systems and legal position, preventing misuse and ensuring the secure and effective operation of our activities. We balance these interests against the rights and freedoms of the individuals concerned.

3.2 Where personal data are required for entering into or performing a contract, or are required by law, failure to provide the necessary information may prevent us from entering into or performing the relevant business relationship or complying with the applicable legal obligation.

3.3 For direct marketing, we comply with the applicable Estonian electronic communications rules. Where prior consent is required, marketing communications will only be sent after valid consent has been obtained. Where applicable law permits marketing to existing customers in relation to similar products or services without prior consent, the recipient will be provided with a clear and easy opportunity to object or opt out.

4.1 Our website currently uses only strictly necessary technical cookies and similar technologies that are required for the operation, security and basic functionality of the website.

4.2 These technologies may be used without consent where permitted by applicable law because they are necessary to provide the website or a service explicitly requested by the user.

4.3 We currently do not use Google Analytics, Meta Pixel or other third-party analytics, advertising or behavioural tracking technologies.

4.4 We do not currently use cookies or similar technologies for behavioural advertising, user profiling or advertising purposes.

4.5 We do not currently use non-essential analytics or marketing cookies on the website.

4.6 If we introduce non-essential cookies or similar technologies in the future, we will update this Privacy Policy and, where required by applicable law, obtain the user's consent before activating such technologies.

5.1 When you access or use our website, certain technical information may be automatically processed by the website server and hosting infrastructure. This may include your IP address, date and time of access, browser type, device-related information and server access or error logs.

5.2 The processing of this technical information is necessary for the secure and proper operation of the website and IT infrastructure, including maintaining server security, detecting and preventing technical problems, misuse, unauthorised access and other security incidents.

5.3 The legal basis for this processing is our legitimate interest in operating, maintaining and securing our website and IT infrastructure, pursuant to Article 6(1)(f) of the GDPR.

5.4 IP addresses and technical server information are not used by us for user profiling, behavioural advertising or marketing purposes, and are not used by us to carry out visitor analytics.

5.5 Hosting provider: Servergarden Korlátolt Felelősségű Társaság (Servergarden Kft.)
Company registration number: 01-09-350297
Registered office: 1027 Budapest, Ganz street 12-14. Hungary
Email: info@servergarden.hu
Telephone: +36 1 432 3133
Website: www.servergarden.hu

5.6 Servergarden Kft. provides hosting and IT infrastructure services for our website. In connection with these services, Servergarden Kft. may process technical information and server log data as necessary to provide, operate, maintain and secure the hosting infrastructure.

5.7 Where Servergarden Kft. processes personal data on our behalf, it acts as a processor and such processing is carried out under the applicable data-protection requirements and appropriate contractual arrangements.

5.8 Access to technical data and server logs is limited to persons or service providers who require such access for legitimate technical, operational, security or legal purposes.

6.1 We do not sell personal data.

6.2 Where necessary for the purposes described in this Privacy Policy, personal data may be shared with:

• IT, hosting, cloud and communications providers;
• accountants, lawyers, auditors and other professional advisers;
• banks and payment providers;
• contractors and business partners involved in providing our services; and
• courts, regulators or public authorities where required or permitted by law.

Hosting provider: Servergarden Korlátolt Felelősségű Társaság (Servergarden Kft.), company registration number 01-09-350297, registered office at 1139 Budapest, Váci út 99-105., Balance Building, 3rd floor, Hungary. Servergarden Kft. operates the hosting and IT infrastructure used for our website and may process technical information and server log data on our behalf.

6.3 The relevant data centre is located at 1101 Budapest, Expo tér 5-7., Hungary.

6.4 Where Servergarden Kft. or another service provider processes personal data on our behalf, we use appropriate contractual and data-protection arrangements as required by applicable law.

7.1 As Anchor Global OÜ operates internationally, personal data may in certain circumstances be processed or transferred outside the European Economic Area (EEA).

7.2 Where personal data are transferred outside the EEA, we ensure that an appropriate legal transfer mechanism is in place where required by the GDPR, such as:

• an applicable European Commission adequacy decision;
• Standard Contractual Clauses;
• another legally recognised transfer mechanism; or
• another applicable safeguard permitted under the GDPR.

The hosting of this website is provided by Servergarden Kft. in Hungary. The use of this hosting service does not in itself constitute a transfer of personal data outside the EEA.

7.3 Where applicable, further information about the safeguards used for international transfers, including a copy of relevant safeguards where legally available, may be requested by contacting info@anchorglobal.eu.

8.1 We retain personal data only for as long as necessary for the purposes for which they were collected and for as long as required or permitted by applicable legal, contractual, accounting, tax or reporting obligations.

8.2 Different categories of personal data may therefore be retained for different periods:

• Business enquiries and correspondence: generally for as long as reasonably necessary to respond to the enquiry, manage the relevant relationship and document the communication, and thereafter only where a continuing business, legal or legitimate-interest purpose exists;
• Unsuccessful proposals and prospective business relationships: generally for a reasonable period after the relevant business opportunity has ended, unless a longer period is necessary to establish, exercise or defend legal claims or for another lawful purpose;
• Client, supplier and contractual records: for the duration of the relevant relationship and thereafter for as long as reasonably necessary to comply with legal obligations, resolve disputes, establish or defend legal claims or protect legitimate business interests;
• Accounting, invoicing and transaction records: generally for seven years where required under applicable Estonian accounting or tax legislation. Certain documents may be subject to a different statutory period where specifically required by law;
• Consent records: for as long as necessary to demonstrate the existence and scope of consent and to comply with applicable legal obligations;
• Technical information, including IP addresses and server logs: for the period necessary for website operation, security, troubleshooting and the detection or investigation of security incidents, subject to the actual retention practices of our hosting and IT service providers.

Business correspondence and other information may also be retained where reasonably necessary to establish, exercise or defend legal claims or to protect our legitimate business interests.

8.3 When personal data are no longer required for the relevant purpose or legal obligation, they will be securely deleted or, where appropriate, anonymised.

9.1 Subject to applicable law, you may have the right to:

• access your personal data;
• request correction of inaccurate or incomplete information;
• request deletion of your personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• receive certain personal data in a portable format;
• withdraw consent at any time where processing is based on consent; and
• object to direct marketing at any time.

To exercise your rights, please contact us at info@anchorglobal.eu.

9.2 We may request information reasonably necessary to verify your identity before processing your request.

9.3 Where applicable, you also have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects, subject to the conditions and exceptions provided by the GDPR.

9.4 Automated decision-making and profiling: Anchor Global OÜ does not currently use personal data for automated decision-making producing legal or similarly significant effects within the meaning of Article 22 GDPR. We also do not currently use personal data for behavioural advertising or advertising profiles.

10.1 We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, disclosure or unlawful processing.

10.2 Access is limited to persons who require the information for legitimate business, technical, operational, security or legal purposes.

10.3 The specific security measures applied may vary depending on the nature and risk of the processing and may include access controls, authentication measures, secure communications, system maintenance, backups, monitoring and other appropriate organisational and technical safeguards.

11.1 If you believe that your personal data have been processed unlawfully or that your rights under applicable data-protection law have not been respected, you may lodge a complaint with the competent data-protection supervisory authority.

11.2 For Anchor Global OÜ, the competent Estonian supervisory authority is:

11.3 Estonian Data Protection Inspectorate
(Andmekaitse Inspektsioon)
Tatari 39, 10134 Tallinn, Estonia
Email: info@aki.ee
Website: www.aki.ee

11.4 You may also contact the supervisory authority in the EU/EEA country where you have your habitual residence, place of work or where the alleged infringement occurred, where permitted by applicable law.

12.1 Our website may contain links to third-party websites or platforms. Anchor Global OÜ is not responsible for the privacy practices, security or content of third-party websites.

12.2 We recommend reviewing the privacy policies of third-party websites and services before providing them with personal data.

13.1 We may update this Privacy Policy from time to time to reflect changes to our activities, services, technologies or applicable legal requirements.

13.2 The current version of this Privacy Policy will be published on our website at https://mail.anchorglobal.eu.

13.3 The date of the latest update will be indicated on the published version of this Privacy Policy.

Anchor Global OÜ

Registry code: 17553594

Registered office: Narva mnt 5., 10117, Tallinn, Estonia

Registered with: Estonian Commercial Register

Website: https://mail.anchorglobal.eu

Email: info@anchorglobal.eu