Last Updated: January 05, 2026

1. WHO WE ARE (Controller) SolmariX OÜ («we,» «us,» or «our») is the Data Controller responsible for your personal data.

• Address: Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-201, 10152, Estonia.

• Email: info@solmarix.com (Contact point for all privacy matters).

2. DATA WE COLLECT

• Identity & Contact Data: Name, email address, phone number (provided by you via forms).

• Consulting Data: Date, time, and place of birth (strictly for chronological profiling analysis requested by you).

• Transaction Data: Payment confirmation details. Note: Full credit card details are processed directly by Stripe and are never stored on our servers.

• Technical Data: IP address, browser type/version, time zone setting (collected automatically).

3. LEGAL BASIS FOR PROCESSING (GDPR) We process your data based on the following legal grounds:

• Performance of Contract (Art. 6(1)(b)): To provide the courses, workshops, and consulting services you booked.

• Legal Obligation (Art. 6(1)(c)): To comply with Estonian accounting and tax laws (e.g., invoicing).

• Consent (Art. 6(1)(a)): For processing specific Consulting Data (birth details) or sending marketing newsletters. You may withdraw consent at any time via the unsubscribe link or by contacting us.

• Legitimate Interest (Art. 6(1)(f)): For network security, fraud prevention, and defending legal claims. We have balanced these interests against your rights and determined they do not override your fundamental freedoms.

4. DATA RETENTION We retain data only as long as necessary:

• Financial/Accounting Records: 7 years (Strictly required by the Estonian Accounting Act).

• Client Account & Consulting Data: 3 years after the last service provided. This aligns with the general statute of limitations for civil claims in Estonia, allowing us to defend our rights if necessary. After this period, data is securely deleted or anonymized.

• Technical Data: Up to 12 months for security logs.

5. DATA SHARING & INTERNATIONAL TRANSFERS We may share data with trusted third parties:

• Stripe (Payment Processor): Acts as an independent Data Controller for payment data. Please review Stripe’s Privacy Policy.

• Service Providers: Email hosting and IT support.

• International Transfers: Some providers (e.g., Stripe, US-based email services) may process data outside the European Economic Area (EEA). We ensure protection through appropriate safeguards, such as the EU-US Data Privacy Framework or Standard Contractual Clauses (SCCs).

6. DATA SECURITY We implement appropriate technical and organizational measures to protect your data, including encryption during transmission (SSL/TLS), access controls (password protection, 2FA for admin accounts), and regular security reviews.

7. YOUR RIGHTS Under GDPR, you have the right to:

1. Access: Request a copy of your data.

2. Rectification: Correct inaccurate data.

3. Erasure («Right to be forgotten»): Request deletion (unless legal obligations require retention).

4. Restriction & Objection: Limit processing or object to processing based on legitimate interest.

5. Portability: Receive your provided data in a structured, machine-readable format (e.g., CSV/JSON).

6. Withdraw Consent: At any time (without affecting past processing).

How to exercise rights: Contact us at info@solmarix.com.

• Verification: To protect your data, we may request proof of identity before fulfilling the request.

• Response Time: We respond within one month. This may be extended by two months for complex requests (we will notify you if so).

8. COOKIES We currently use only Essential Cookies necessary for the website’s functioning (e.g., session security). These do not require consent. If we introduce analytics or marketing cookies in the future, we will ask for your explicit consent via a cookie banner.

9. COMPLAINTS You have the right to lodge a complaint with the Estonian Data Protection Inspectorate (AKI) (website: aki.ee) if you believe your rights have been violated.