Privacy Notice
This notice explains what personal data Kwintex OÜ collects when you contact us through kwintex.ee or browse the site, why we collect it, and what rights you have under the EU General Data Protection Regulation (GDPR) and the Estonian Personal Data Protection Act. We measure how the site is used with Google Analytics, which sets cookies only if you accept them, and with Jetpack Stats. We do not run advertising on this site. The website and our services are intended for business customers and are not directed at children.
Who we are
The data controller is Osaühing Kwintex (short form: Kwintex OÜ), Estonian registry code 11190699, registered at Tartu mnt 21c, 41538 Jõhvi linn, Jõhvi vald, Ida-Viru maakond, Estonia. For any privacy question, write to info@kwintex.ee or call +372 529 1678.
We have not appointed a Data Protection Officer because our processing does not meet the threshold for mandatory appointment under GDPR Article 37 — we are a small manufacturer, we do not engage in large-scale monitoring, and we do not process special categories of personal data.
What personal data we collect
When you send a quote request or write to us directly, we collect what you give us. That typically includes:
- Your name and (optionally) your company name
- Your email address
- Your phone number, if you provide one
- The contents of your message and any files you attach (technical drawings, specifications, reference images)
When you browse the site, Google Analytics and Jetpack Stats also record how the site is used, such as which pages are viewed. Google Analytics places cookies only after you accept them. For details, see Analytics and statistics and Cookies. We do not use this data for profiling or advertising, and we do not run behavioural advertising on this site. Standard server access logs may be retained by our hosting provider for security and troubleshooting (see Who has access).
Why we use it (purposes)
- To reply to your enquiry and prepare a quote
- To take pre-contractual steps at your request — drafting specifications, sample work, scheduling production
- To fulfil any contract that follows from your enquiry
- To comply with our own legal obligations (accounting, tax, statutory record-keeping)
- To keep our quote form free of spam and abuse
- To understand how visitors use the site, in aggregate, so we can improve it
Legal basis for processing
Under GDPR Article 6, we rely on the following legal bases:
- Article 6(1)(a) — your consent, for Google Analytics cookies and the analytics data linked to them. You can withdraw it at any time; see Cookies.
- Article 6(1)(b) — performance of a contract or pre-contractual measures taken at your request, for quote and order handling.
- Article 6(1)(c) — compliance with legal obligations, where Estonian law requires us to retain certain records.
- Article 6(1)(f) — our legitimate interests. We have a legitimate interest in responding to business enquiries and in operating a basic contact channel. We also have a legitimate interest in keeping that channel free of spam and abuse. Finally, we have a legitimate interest in aggregate statistics about how the site is used. These statistics come from Jetpack Stats and from the cookieless Google Analytics measurements described in Analytics and statistics.
Who has access to your data
Within Kwintex OÜ, only staff who need to handle your enquiry can see its contents. We do not sell or rent your personal data, and we do not share it with marketing partners. The service providers below receive data so they can provide their services to us. Where a provider also uses data for a purpose of its own, we say so below.
Our current third-party service providers are:
- Wavecom AS (Tallinn, Estonia) — provides web hosting and the email service for info@kwintex.ee. Your message is stored on Wavecom infrastructure as long as it remains in the inbox.
- Google Ireland Limited (Dublin, Ireland) — provides Google Analytics, which the Site Kit by Google plugin adds to the site, and receives the usage data described in Analytics and statistics. Google LLC (United States) can receive this data too. This notice calls the two companies "Google". Google also uses the information it receives from sites that use its services for purposes of its own, such as maintaining and improving its services, developing new ones, and protecting against fraud and abuse. For details, see How Google uses information from sites or apps that use our services.
- Aut O'Mattic A8C Ireland Ltd. (Dublin, Ireland) — provides Jetpack and Jetpack Stats, and receives the usage data described in Analytics and statistics. Automattic Inc. (United States) processes some of this data too. This notice calls the two companies "Automattic". Automattic also uses page-load performance data, in aggregate across all Jetpack sites, to check that Jetpack does not slow sites down.
We may also disclose data when required by Estonian or EU law — for example, on a lawful request from a public authority or court order.
Where your data is stored
Your enquiries, the files you attach, and our email are stored on servers located in Estonia, operated by Wavecom AS.
Usage statistics can leave the European Economic Area (EEA). Google states that it collects Google Analytics data from devices in the EU through servers in the EU. It performs IP address lookups there before it forwards the data for processing. Google also states that it relies on the EU-U.S. Data Privacy Framework to transfer EEA personal data to the United States for its advertising and analytics products. Google LLC has certified that it adheres to that framework. Automattic Inc. is based in the United States, so Jetpack Stats data can be processed there. Automattic states that it protects transfers out of the EEA with standard contractual clauses approved by the European Commission. To get a copy of these safeguards, email us at info@kwintex.ee.
These are the transfers outside the EEA that we know of, and each relies on the GDPR Chapter V safeguard named above. If we add a service provider that transfers personal data outside the EEA, we will update this notice and name the safeguard it relies on.
How long we keep your data
We periodically review enquiry communications and aim not to retain them longer than reasonably necessary for business purposes. If your enquiry becomes a customer relationship, the underlying data is kept for the duration of that relationship plus the statutory accounting period required under Estonian law (currently seven years, per the Accounting Act). We delete the files you attach to a quote request after 12 months, unless we start working together.
After the retention period, we delete or anonymise the data unless we have an active legal obligation to keep it longer.
Automattic keeps Jetpack Stats logs, which include visitor IP addresses, for 28 days. Google keeps Google Analytics data for the data retention period set in our Google Analytics account. Cookie lifetimes are listed under Cookies.
Analytics and statistics
We use two services to see, in aggregate, how visitors use kwintex.ee, so we can improve the site. We do not use either one for advertising.
Google Analytics
The Site Kit by Google plugin adds Google Analytics 4 to the site. It runs in Google's consent mode: analytics storage stays "denied" until you accept in the cookie banner.
- Before you choose, and if you reject: Google Analytics does not read or write cookies in your browser. It still sends measurements without cookies. According to Google, these measurements can include functional information, such as a timestamp, your user agent, and the referring page. They can also include your consent state and a random number generated on each page load. On this site, they also contain the address and title of the page you view, your screen size, and your browser language. They include details of your browser and device, such as its platform, version, and model. They record events, such as page views and scrolling. Your IP address reaches Google with each request.
- If you accept: Google Analytics also sets the _ga and _ga_<container-id> cookies, which let it recognise a returning browser and group page views into visits.
- Whatever you choose: the site runs no advertising, so the advertising consent types (ad storage, ad user data, and ad personalisation) stay denied.
Google states that Google Analytics does not log or store the IP addresses of visitors in the EU. It uses them only to derive an approximate location, and then discards them.
Jetpack Stats
Jetpack Stats, a service of Automattic, counts page views and related activity. According to Automattic, it uses your IP address, your user agent, the page you visit, the referring page, the time of the visit, your browser language, and your country code. If you are logged in to WordPress.com, it also uses your WordPress.com user ID and username. It records page views, clicks on links that lead to other sites, referring sites and search terms, and your country. Jetpack also measures the performance of each page load, only in aggregate across Jetpack sites.
Automattic keeps the Stats logs for 28 days. We see only aggregate statistics: Jetpack does not show us data that identifies you, such as your IP address. Jetpack Stats does not set cookies in your browser, so your cookie choice does not affect it. You can object to this processing; see Your rights.
Cookies
Cookies are small text files that a website stores in your browser. kwintex.ee sets analytics cookies only after you accept them in the cookie banner. The site uses the following cookies:
- kwintex_consent — set by kwintex.ee when you accept or reject analytics cookies. It stores your choice for up to 180 days, so the banner does not ask again on every page. Some browsers, such as Safari, keep it for a shorter time, and the banner then asks again. Strictly necessary.
- pll_language — set by the Polylang plugin, which serves the site's language versions. It remembers the language of the pages you view, holds only a language code, and lasts 1 year. Strictly necessary.
- _ga — Google Analytics, set only after you accept. It distinguishes one browser from another. Google documents a lifetime of 2 years.
- _ga_<container-id> (on this site, _ga_5SDRMM1Y9Q) — Google Analytics, set only after you accept. It keeps the state of your current visit. Google documents a lifetime of 2 years.
Your browser can delete cookies before they expire. The site may also use strictly necessary technical cookies required for security, load balancing, or form functionality. Strictly necessary cookies do not require consent under applicable Estonian and EU law, and they do not identify you personally.
To change or withdraw your consent at any time, select Cookie settings in the footer of any page, and then select Accept or Reject. When you reject, the site deletes the Google Analytics cookies from your browser and tells Google Analytics to stop using cookies, also on other kwintex.ee pages you have open. Measurements that Google Analytics recorded before you rejected can still reach Google a few seconds later. Withdrawing consent does not affect the lawfulness of processing before the withdrawal.
Automated decision-making
We do not use automated decision-making or profiling within the meaning of GDPR Article 22.
Your rights
Under the GDPR, you have the right to:
- Request access to the personal data we hold about you
- Ask us to correct inaccurate or incomplete data
- Ask us to erase your data ("right to be forgotten")
- Ask us to restrict processing in certain circumstances
- Object to processing based on our legitimate interests
- Receive your data in a structured, machine-readable format (data portability)
- Withdraw any consent you previously gave, without affecting the lawfulness of processing before withdrawal
To withdraw your consent to analytics cookies, use Cookie settings in the footer of any page (see Cookies). To exercise any of the other rights, write to info@kwintex.ee. We will respond within one month, as required by GDPR Article 12(3). For security, we may ask you to confirm your identity before we fulfil a request.
Complaints
If you believe we have mishandled your personal data, you have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon):
- Tatari 39, 10134 Tallinn, Estonia
- info@aki.ee
- www.aki.ee
You may also complain to the supervisory authority in the EU country where you live or work, if that is more convenient for you. In addition, you have the right to seek a judicial remedy under GDPR Article 79 if you believe your rights under data protection law have been violated.
How we keep your data secure
We take reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or disclosure, as required by GDPR Article 32. Enquiry data is held on Wavecom AS infrastructure in Estonia under their standard physical and network security controls. Access to the info@kwintex.ee mailbox is restricted to Kwintex staff who need it to handle your enquiry.
Changes to this notice
We may update this notice when our practices change or when the law requires it. The latest version is always available at kwintex.ee/privacy, with the effective date shown at the top.