Privacy Policy

This policy explains how Globalventures4business OÜ, trading as NOCTRAM, collects and uses personal data when you visit this website or contact us, and what rights you have. It follows the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and the Estonian Personal Data Protection Act (Isikuandmete kaitse seadus).

1. Who is responsible for your data

The controller is Globalventures4business OÜ, registry code 16255280, Tööstuse 75-71, 10416 Tallinn, Estonia, e-mail info@noctram.com, phone +372 5882 4221.

We are not required to appoint a data protection officer. For any question about your data, write to info@noctram.com.

2. What we process, why and for how long

Visiting this website

Data: IP address, date and time, page requested, referring page, browser and operating system, recorded in the server logs.
Purpose: To deliver the website and keep it secure.
Legal basis: Our legitimate interest in running a secure website (GDPR Art. 6(1)(f)).
How long we keep it: For a short period set by our hosting provider for security purposes, after which the logs are deleted.

Visitor statistics

Data: Aggregated information on pages viewed, referring websites, country, browser, device type and page loading performance. The tool does not use cookies or local storage and does not create individual profiles.
Purpose: To understand which content is useful and improve the website.
Legal basis: Our legitimate interest in measuring the use of our website (GDPR Art. 6(1)(f)).
How long we keep it: Only aggregated statistics are kept, for as long as they are useful.

Contact form, e-mail and phone

Data: Name, organisation, e-mail address, phone number if you give it, and the content of your message.
Purpose: To answer your enquiry and, if you wish, prepare a proposal.
Legal basis: Steps at your request before a possible contract (GDPR Art. 6(1)(b)) and our legitimate interest in answering enquiries (Art. 6(1)(f)).
How long we keep it: Up to 24 months after our last exchange. If a contract follows, see “Clients and partners” below.

Free 10-minute diagnostic

Data: Name, organisation, e-mail address, country, topic, your message and preferred days and times. We send an automatic confirmation e-mail.
Purpose: To organise and hold the call and follow up on it.
Legal basis: Steps at your request before a possible contract (GDPR Art. 6(1)(b)).
How long we keep it: Up to 24 months after our last exchange.

Applications through “Work with us”

Data: Name, e-mail address, country, LinkedIn profile if you give it, area of expertise, your introduction and your CV.
Purpose: To assess your profile and contact you about suitable engagements. We share your profile with a client only after agreeing it with you.
Legal basis: Your consent (GDPR Art. 6(1)(a)), which you can withdraw at any time without affecting earlier processing.
How long we keep it: Up to 24 months, or until you withdraw your consent. Please do not include sensitive data, such as health information, in your CV.

Data: Your phone number, profile name and the messages you send us.
Purpose: To reply to you through the channel you chose.
Legal basis: Our legitimate interest in answering enquiries (GDPR Art. 6(1)(f)) and steps before a possible contract (Art. 6(1)(b)).
How long we keep it: Up to 24 months after our last exchange. WhatsApp Ireland Limited processes your data as an independent controller under its own privacy policy.

Clients and partners

Data: Contact details of the people we work with, contract and invoicing information, and project correspondence.
Purpose: To perform our contracts, manage the relationship and meet our legal obligations.
Legal basis: Performance of a contract (GDPR Art. 6(1)(b)) and legal obligations, such as accounting rules (Art. 6(1)(c)).
How long we keep it: For the duration of the relationship. Accounting documents are kept for at least seven years after the end of the financial year, as Estonian accounting law requires.

Giving us your data is voluntary. Without the fields marked as required, we cannot answer your request.

3. Who receives your data

We do not sell personal data. We share it only as far as necessary with these categories of recipients:

Hosting provider: website hosting and the sending of form e-mails.
E-mail service provider: our mailbox at info@noctram.com.
Web analytics provider: privacy-friendly visitor statistics.
E-mail delivery provider: delivery of the messages our website forms generate.
Software and AI service providers that help us manage our correspondence and operations, under data processing terms.
Experts from our network assigned to your project, if your enquiry leads to an engagement, under confidentiality obligations.
Professional advisers and authorities, such as our accountants, or public authorities where the law requires it.

Service providers that process data on our behalf act under our instructions and under a data processing agreement (GDPR Art. 28).

4. Transfers outside the European Economic Area

Some of our providers are based outside the European Economic Area, including in the United States. Transfers rely on the EU-U.S. Data Privacy Framework (European Commission adequacy decision of 10 July 2023) where the recipient is certified under it, or on the Standard Contractual Clauses adopted by the European Commission (GDPR Art. 46(2)(c)). You can ask us for more information about these safeguards.

5. How we protect your data

This website uses an encrypted connection (HTTPS). Access to personal data is limited to the people who need it, and we require our providers to apply appropriate technical and organisational security measures.

6. Your rights

Under the GDPR you have the right to:

access your data and receive a copy of it (Art. 15);
have inaccurate data corrected (Art. 16);
have your data deleted (Art. 17);
restrict the processing of your data (Art. 18);
receive your data in a portable format (Art. 20);
object to processing based on our legitimate interests (Art. 21);
withdraw your consent at any time, where processing is based on consent (Art. 7(3)).

To exercise these rights, write to info@noctram.com. We will reply within one month, as the GDPR requires, and may ask you to confirm your identity.

7. Right to complain

You can lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn, Estonia, info@aki.ee, www.aki.ee, or with the data protection authority of the EU country where you live or work.

8. Automated decisions

We do not take decisions that produce legal or similarly significant effects on you based solely on automated processing, including profiling (GDPR Art. 22).

9. Children

Our services are aimed at organisations. This website is not directed at children, and we do not knowingly collect data from children under 13, the age of digital consent in Estonia.

10. Changes to this policy

We may update this policy when our services or the law change. The date at the top shows the latest version.

Reference: General Data Protection Regulation (EU) 2016/679, EUR-Lex.