Summary: We collect only what we need, never sell your data, keep it only as long as necessary, and honour all GDPR rights. Any privacy request: info@sanj-tech.com.
1. Data Controller
The controller responsible for your personal data is:
A.D Technological Solutions
Sepapaja tn 6, Lasnamäe linnaosa
Tallinn 15551, Estonia
Email: info@sanj-tech.com
Website: sanj-tech.com
2. Scope of This Policy
This Privacy Policy applies to personal data collected through:
- The website sanj-tech.com and any subdomains;
- Contact forms, email correspondence, and enquiries submitted to us;
- Service agreements and delivery of Managed IT Services to business clients;
- Any other interaction where we collect personal data as a controller.
Where we process data on behalf of a client (as a data processor), this policy does not apply — the client's own policy governs that processing.
3. Data We Collect
3.1 Data You Provide Directly
| Category | Examples | How Collected |
|---|---|---|
| Identity data | First name, last name, job title | Contact form, email, service agreements |
| Contact data | Email address, phone number, company name | Contact form, email correspondence |
| Communication data | Messages, support tickets, meeting notes | Email, helpdesk, calls |
| Commercial data | Purchase history, invoices, contract details | Service agreements |
3.2 Data Collected Automatically
| Category | Examples | How Collected |
|---|---|---|
| Technical data | IP address, browser type, OS, device type | Server logs, analytics cookies |
| Usage data | Pages visited, time on site, referral source | Analytics cookies (with consent) |
| Cookie data | Consent preference, session ID | Cookies (see Section 10) |
3.3 Data We Do Not Collect
We do not collect special category data (health, biometric, political opinions, etc.) through this website, nor do we collect payment card data directly — payments are handled by PCI-DSS-compliant third-party processors.
4. Purposes and Legal Bases (GDPR Art. 6)
| Purpose | Legal Basis | Details |
|---|---|---|
| Responding to enquiries | Art. 6(1)(b) Contract / Art. 6(1)(f) Legitimate interest | Replying to your contact form or email. |
| Delivering Managed IT Services | Art. 6(1)(b) Contract performance | Necessary to fulfil our service agreement. |
| Marketing communications | Art. 6(1)(a) Consent | Only where you have opted in. Withdrawable at any time. |
| Website analytics | Art. 6(1)(a) Consent (cookie banner) | Google Analytics with IP anonymisation. |
| Invoicing and accounting | Art. 6(1)(c) Legal obligation | Estonian accounting and tax law. |
| Security and fraud prevention | Art. 6(1)(f) Legitimate interest | Server logs and security monitoring. |
| Compliance and legal claims | Art. 6(1)(c) / Art. 6(1)(f) | Retaining data to defend legal claims. |
Legitimate interest balancing: Where we rely on legitimate interests, we have carried out a balancing test and concluded our interests do not override your rights, given the nature of data collected from a business IT services website.
5. Data Retention
| Data Category | Retention Period | Reason |
|---|---|---|
| Contact form enquiries (non-client) | 3 years from last contact | Legitimate interest |
| Client contractual data | Contract duration + 7 years | Estonian Accounting Act |
| Marketing consent records | Until withdrawn + 3 years | Demonstrate consent |
| Server logs / technical data | 90 days rolling | Security monitoring |
| Analytics data | 26 months (anonymised) | Website improvement |
| GDPR request records | 3 years from response | Accountability obligation |
6. Data Sharing and Processors
We do not sell, rent, or trade your personal data. We share data only with processors bound by GDPR Art. 28 data processing agreements.
| Processor Category | Purpose | Location |
|---|---|---|
| Email delivery provider | Transactional and marketing emails | EU/EEA |
| CRM / helpdesk platform | Client relationships and support | EU/EEA |
| Analytics (Google Analytics) | Anonymous website statistics | USA (SCCs in place) |
| Cloud infrastructure | Website and system hosting | EU/EEA |
| Accounting software | Financial records and invoicing | EU/EEA |
We may also disclose data to authorities where required by law, or to protect the safety and rights of our company, clients, or the public.
7. International Data Transfers
Our operations are based in Estonia (EU/EEA). Where processors are outside the EEA (e.g., Google Analytics), we ensure safeguards under GDPR Chapter V via Standard Contractual Clauses (SCCs) — Commission Implementing Decision (EU) 2021/914 — and supplementary technical measures such as IP anonymisation. You may request a copy of applicable transfer safeguards at info@sanj-tech.com.
8. Your Rights Under GDPR
Contact us at info@sanj-tech.com to exercise any right. We respond within 30 days (extendable by 60 days for complex requests).
Right of Access
Obtain a copy of your data and processing information (Art. 15).
Right to Rectification
Correct inaccurate or incomplete data (Art. 16).
Right to Erasure
Request deletion where there is no compelling reason to continue (Art. 17).
Right to Restriction
Restrict processing in certain circumstances (Art. 18).
Right to Portability
Receive data in a structured, machine-readable format (Art. 20).
Right to Object
Object to processing based on legitimate interest or for direct marketing (Art. 21).
Withdraw Consent
Withdraw consent at any time without affecting prior lawful processing (Art. 7(3)).
Automated Decisions
Not to be subject to solely automated decisions affecting you (Art. 22). We don't carry out such processing.
9. Opt-Out of Marketing Communications
To unsubscribe from marketing emails:
- Click the unsubscribe link in any marketing email we send;
- Email info@sanj-tech.com with subject "Unsubscribe";
- Write to: A.D Technological Solutions, Sepapaja tn 6, Tallinn 15551, Estonia.
We will action your request within 5 business days. Transactional and service emails (invoices, service notifications) are not affected by marketing opt-out.
10. Cookies
We use cookies to operate the site and, with your consent, to analyse usage. A cookie consent banner is displayed on first visit. Strictly necessary cookies are always active; analytics cookies require explicit consent. See the Cookie Policy available via the cookie banner or footer for full details.
11. Children's Privacy
Our services target business professionals. We do not knowingly collect data from individuals under 16. If you believe a minor has provided data, contact info@sanj-tech.com and we will delete it promptly.
12. Security Measures
We implement appropriate technical and organisational measures including TLS encryption for data in transit, access controls and role-based permissions, regular security assessments and staff training, and pseudonymisation where appropriate. In the event of a data breach likely to risk your rights, we will notify the supervisory authority within 72 hours and affected individuals as required under GDPR Art. 33–34.
13. Complaints
If you believe we've not handled your data lawfully, please contact us first at info@sanj-tech.com. You also have the right to lodge a complaint with:
Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)
Tatari 39, Tallinn 10134, Estonia
www.aki.ee · info@aki.ee
Or with the supervisory authority in your EU/EEA country of residence.
14. Changes to This Policy
We may update this policy to reflect changes in our practices or legal requirements. Material changes will be flagged with an updated "Last updated" date. Where required by law, we will seek your consent. We recommend reviewing this page periodically.
15. Contact Us
A.D Technological Solutions
Sepapaja tn 6, Lasnamäe linnaosa
Tallinn 15551, Estonia
Email: info@sanj-tech.com
Subject line for GDPR requests: "GDPR Request – [Your Name]"
Response time: We acknowledge all privacy requests within 3 business days and provide a full response within 30 days as required by GDPR Art. 12.