Privacy Policy

Privacy Policy

Effective date 19.10.2020

Hepta Group Airborne OÜ, registry code 14311560, address Paju 2, Tartu, Estonia (also referred to as “we”, “us” or “”our”) is the controller of personal data of the users of the website and its sub-domains, and either the controller or processor of personal data regarding personal data processed in offering our services. This privacy policy describes how we collect and process users’ personal data as a data controller. In case we are operating in the capacity of a data processor, we are operating under the regulation of the relevant data processing agreements in place between ourselves and the data controllers, and in accordance with any applicable legal regulations. In addition to ensuring any processing of personal data we undertake either as a controller or a processor is in full compliance with applicable legal acts, we are also committed to keep confidential and safe any other data disclosed to us in connection with providing our services.
​Please carefully read this privacy policy before accessing and using our website or any of our services. If you to any extent object to this privacy policy, please discontinue using the website and our services.
We may update this privacy policy from time to time. Upon such updates, a notification will be published on our website.


1. Personal Data We Collect and Process

In order to achieve the purposes of personal data processing set out in this privacy policy, we may process some or all of the following personal data, whereas the exact set of personal data varies case by case, and whereas we will always follow among other principles the principle of data minimisation, i.e. we will only process what is adequate, relevant and limited to what is necessary in relation to the purposes for which personal data is processed:

• Name;
• E-mail address;
• Telephone number;
• Personal data exchanged and disclosed in e-mail correspondence with our clients or other relevant third parties in the regular course of providing our services;
• Your preferences in communication between us, and in receiving marketing correspondence from us and our third-party marketing partners you have provided your information to. If you correspond with us by email or messaging through the Services, we may retain the content of such messages and our responses.
• Personal data otherwise exchanged and disclosed in the regular course of providing our services;

We also collect non-personally identifiable information, such as data regarding the length of website visits, click counts and user behaviour, in order to make the website more convenient and for analytical purposes. We only use secure services, for example Google Analytics. We also compile relevant statistical summaries for business purposes, whereby your personal data is converted into non-personal data and stored on secure media.

2. Purposes and Legal Basis for Data Processing

In case you send us e-mails or queries through our website’s query form, you acknowledge and agree it is necessary for us to process your personal data (including to retain the contents of such e-mails and queries) in order to reply to your e-mails and queries. In such case we have legitimate interest to process your personal data, in some cases the processing of the same is also necessary for the performance of a contract or in order to take steps at the request of the data subject prior to entering into a contract. The purpose for such personal data processing is therefore to ensure a smooth customer support process, and to hold contractual negotiations for entering into an agreement.
We may process personal data when its necessary for the performance of our customer agreements, and also for any invoicing purposes, or as part of pre-contractual measures we take. This may include the sending of e-mail or other notices concerning the services we offer, e.g. in order to respond to your comments, questions and requests, and to send you technical notices, product updates and administrative messages.
We may also process your personal data to fulfil our lawful obligations, e.g. to ensure the protection of your personal data, retain personal data for any periods necessary to fulfil obligations arising from law (e.g. for accounting purposes), and to fulfil any other obligations arising from applicable legal acts.
We may process your personal data in any cases of contractual or other disputes in order to protect our legitimate interests.
Upon your consent we process your personal data to send you newsletters, blog updates, promotional, marketing, and other information regarding us via e-mail. You can at any time unsubscribe from such mailing lists by clicking the unsubscribe button found in the e-mail.
We will always ask for your prior consent for the processing of personal data for purposes other than those set out herein.

3. Security Measures

We process personal data only if there is a legal basis and only for legitimate purposes. We use measures and store personal data in a way that ensures the security and confidentiality of personal data. Personal data is accessed only by persons for whom it is necessary in connection with the performance of work duties or to whom the disclosure of personal data is in accordance with this privacy policy or legislation.
We are not responsible for any misuse of your personal data caused by malware on your own computer or other device.

4. Recipients

We have the right to disclose and transfer personal data without your prior consent to data processors acting on behalf of us and under relevant data processing agreements, and to fulfil our obligations under the law. For the protection of our rights, we have the right to disclose the personal information to third parties, including legal counsels, auditors, etc.

We might provide access to digital marketing service providers to personal data collected and stored in marketing tools used by us during our marketing campaigns. Therefore, the digital marketing service providers will become data processors on behalf of us.

Marketing technologies used in our digital marketing campaigns to analyse, retarget and remarket to respective audiences include Facebook, LinkedIn and Google (Google Analytics). Please find below details of the companies and links to their privacy policies.

Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA;

Privacy Policy

LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland;

Privacy Policy

Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA;

Privacy Policy

Other marketing technologies used in our marketing campaigns are provided by the following service providers:

Active Campaign – a marketing automation platform.

ActiveCampaign, LLC, 1 North Dearborn Street, 5th Floor, Chicago, IL 60602 USA

Privacy Policy

Unbounce – a landing page design and hosting platform.

Unbounce Marketing Solutions Inc. 400-401 West Georgia Street, Vancouver, BC Canada, V6B 5A1

Privacy Policy

Zapier – an integration tool that connects used marketing technologies together to exchange data.

Zapier, Inc. 548 Market St. #62411. San Francisco, CA 94104-5401, USA

Privacy Policy

Typeform – a survey and assessment tool.

TYPEFORM SL, Carrer Bac de Roda, 163, local, 08018 – Barcelona, Spain

Privacy Policy

Databox – a data presentation tool that provides reporting on the effectiveness and results of marketing campaigns using information from Google Analytics, Facebook, LinkedIn and ActiveCampaign.

DataBox, Inc. 6 Liberty Square PMB #471 Boston, MA 02109 USA

Privacy Policy

IBD Consulting – marketing advisory

SIA “IBD Consulting”, Reg. No. 40203095010, Kaivas street 31/1 – 11, Riga, LV-1021, LATVIA

5. Deletion and Retention

We retain personal data only for as long as it is necessary for the fulfilment of the purposes described herein, for the protection of our rights or for the fulfilment of our obligations arising from legislation. We limit the processing of your personal data and only process personal data under a strict need basis.

6. Your Rights

You may at any time request information from us regarding the processing of your personal data. In certain cases, prescribed in applicable legislation, you have the right to:
• request deletion of your personal data;
• request the rectification of your personal data;
• request the restriction of processing your personal data, however, in this case you may not be able to use our services in the full extent;
• object to the use of your personal data;
• right to receive the personal data concerning you, which you have provided us, in a structured, commonly used and machine-readable format, and to transmit this data to another controller.
In case we use your personal data on the grounds of your consent, you may at any time withdraw your consent. This will not affect the legality of any previous processing of your personal data.
We will respond to your requests as soon as possible, taking into account the requirements set forth in the applicable law.

7. Cookies

We use cookies on our website. Cookies are small files that are stored on your computer in order for your web browser to “remember” you and your preferences, so that we can provide you with relevant information, suggestions and to improve user experience.

The cookies used include mandatory cookies that are necessary for the functioning of the website. In addition, we use cookies to analyse website traffic and user behaviour, but you may refuse the use of such cookies via your web browser settings. The cookies we use do not allow identification. We may share website usage data with our social media and advertising partners and analysts, who may combine the data with other data available to them.

8. Questions and Complaints

If you have any questions or complaints regarding the processing of your personal data, you can contact us Hepta Group Airborne OÜ (Paju 2, Tartu 50603, Estonia; +372 5397 7435) or the Estonian Data Protection Inspectorate (; +372 627 4135).

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