This Privacy Policy explains how personal data is collected, used, and protected when you visit or make a purchase from https://tonupoldma.com (the “Website”).

The Website is operated by Muutuste Loomine OÜ (registry code 16827807, VAT number EE102951400), Oa 39-2, Tartu, Estonia (hereinafter referred to as the “Data Controller”, “we”, or “us”).

We process personal data in accordance with applicable data protection laws, including the European Union General Data Protection Regulation (GDPR).

Digital products are supplied electronically from Estonia. Where applicable, VAT is calculated under the EU One Stop Shop (OSS) scheme.

1. Definitions

A data subject is any identifiable natural person whose personal data we process.

A customer is a person who purchases digital products or services from the Website.

2. What Personal Data We Collect

We may collect and process the following personal data:

  • first and last name

  • email address

  • phone number (if provided)

  • billing details

  • order and purchase information

  • IP address and device/browser data

  • messages sent via forms or email

  • newsletter subscription data

Personal data is collected primarily through the Website, checkout forms, cookies, and email communication.

We do not store full payment card details. Payments are processed by secure third-party payment service providers.

3. Legal Bases for Processing (GDPR Art. 6)

We process personal data on the following legal bases:

  • performance of a contract (order processing and digital product delivery)

  • legal obligation (accounting and tax requirements)

  • legitimate interest (Website security and service improvement)

  • consent (marketing communication and analytics cookies where required)

4. Purposes of Processing

We use personal data to:

  • process and deliver digital products

  • manage orders and payments

  • provide customer support

  • send service-related messages

  • maintain accounting and VAT records

  • comply with tax and regulatory obligations

  • improve Website performance and usability

  • conduct analytics and measure marketing effectiveness

  • send newsletters and educational content

5. Newsletter and Marketing Communication

When a customer makes a purchase from the Website, the customer may be added to the newsletter list.

Newsletter messages may include educational content, updates, and information about new materials or offers.

Every newsletter email includes an unsubscribe link. The customer may unsubscribe at any time. After unsubscribing, marketing emails will no longer be sent.

6. Cookies and Tracking Technologies

The Website uses cookies and similar technologies for functionality, analytics, and marketing.

Cookies are used to:

  • ensure Website operation

  • remember user preferences

  • analyze Website traffic

  • measure marketing performance

Where required by law, non-essential cookies are used only with user consent.

Users can manage cookie preferences through the cookie banner and browser settings.

7. Analytics and Advertising Tools

The Website may use third-party analytics and advertising tools, including:

  • Google Analytics

  • Meta (Facebook) Pixel

These tools collect pseudonymous data about Website usage and interactions. This helps us understand visitor behavior, measure advertising effectiveness, and improve content and user experience.

These providers process data according to their own privacy policies.

8. Data Sharing

We share personal data only when necessary and only with trusted service providers, such as:

  • payment service providers (e.g., Stripe and similar processors)

  • hosting and technical providers

  • accounting service providers

  • email and newsletter platforms

  • analytics and advertising partners

We do not sell personal data to third parties.

9. Data Retention

Personal data is stored only as long as necessary:

  • accounting and transaction data — as required by law

  • order records — up to 7 years

  • customer communication — as needed for records

  • newsletter data — until unsubscribed

10. Data Security

We implement appropriate technical and organizational safeguards to protect personal data against unauthorized access, alteration, disclosure, or destruction.

11. Your Rights

You have the right to:

  • access your personal data

  • request correction

  • request deletion

  • restrict processing

  • object to processing

  • withdraw consent

  • request data portability

To exercise your rights, contact:
tonu.poldma@gmail.com

You also have the right to file a complaint with the Estonian Data Protection Inspectorate.

12. Digital Products and Copyright

All paid digital products are protected by copyright. Copying, distributing, or reselling is prohibited without the author’s written permission.

13. Limitation of Liability

Website content and digital materials are provided for informational and reflective purposes. The operator is not liable for how the content is interpreted or used, nor for consequences arising from its use.

14. Policy Updates

We may update this Privacy Policy from time to time. The latest version will always be published on the Website.

Last updated: February 4, 2026

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