Privacy Policy

How we collect, use, and protect your information

Last updated: November 17, 2025

1. Introduction

22nd Century Dev OÜ ("we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and share your personal information when you visit our website or use our technology consulting services.

2. Information We Collect

2.1 Information You Provide

We collect information you voluntarily provide to us, including:

  • Name and contact details (email, phone number)
  • Company information and job title
  • Project requirements and consultation requests
  • Communication preferences
  • Any other information you choose to provide

2.2 Automatically Collected Information

When you visit our website, we may automatically collect:

  • IP address and location data
  • Browser type and version
  • Pages visited and time spent on our site
  • Referring website information
  • Device and operating system information

3. How We Use Your Information

We use your personal information for the following purposes:

  • Providing technology consulting services
  • Responding to your inquiries and consultation requests
  • Communicating about our services and projects
  • Improving our website and services
  • Complying with legal obligations
  • Protecting our business interests and rights

4. Legal Basis for Processing

Under GDPR, we process your personal data based on:

  • Consent: When you explicitly agree to data processing
  • Contract: To fulfill our consulting services
  • Legitimate interests: For business operations and improvements
  • Legal obligation: To comply with applicable laws

5. Data Sharing and Disclosure

We do not sell your personal information. We may share your data with:

  • Trusted service providers who assist in our operations
  • Legal authorities when required by law
  • Business partners for joint consulting projects (with your consent)
  • Professional advisors (lawyers, accountants, auditors)

6. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of sensitive data
  • Regular security assessments
  • Access controls and authentication
  • Employee training on data protection

7. Data Retention

We retain your personal information only as long as necessary for the purposes outlined in this policy or as required by law. Typical retention periods include:

  • Client data: Duration of engagement plus 7 years
  • Marketing communications: Until you unsubscribe
  • Website analytics: 26 months
  • Legal compliance: As required by applicable laws

8. Your Rights

Under GDPR and applicable data protection laws, you have the right to:

  • Access: Request information about your personal data
  • Rectification: Correct inaccurate personal data
  • Erasure: Request deletion of your personal data
  • Restriction: Limit processing of your data
  • Portability: Receive your data in a structured format
  • Objection: Object to processing based on legitimate interests
  • Withdraw consent: Revoke previously given consent

9. Cookies and Tracking

Our website uses cookies and similar technologies. For detailed information about our cookie practices, please refer to our Cookie Policy.

10. International Data Transfers

As we serve clients across CIS countries, your data may be transferred to and processed in countries outside the European Economic Area. We ensure appropriate safeguards are in place for such transfers.

11. Children's Privacy

Our services are not intended for individuals under 16 years of age. We do not knowingly collect personal information from children under 16.

12. Changes to This Policy

We may update this Privacy Policy periodically. Any changes will be posted on this page with an updated revision date. Significant changes will be communicated via email or website notice.

13. Contact Information

For questions about this Privacy Policy or to exercise your rights, please contact us:

22nd Century Dev OÜ
Email: [email protected]
Address: Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-201, 10152
Registration Number: 16627865

14. Data Protection Officer

For data protection inquiries, you can contact our designated data protection contact at [email protected].

15. Supervisory Authority

You have the right to lodge a complaint with the Estonian Data Protection Inspectorate or your local supervisory authority if you believe your data protection rights have been violated.