Privacy Policy

Last Updated: August 2026 | Effective Date: August 1, 2026

1. Introduction

THOTH Consulting OÜ (hereinafter "THOTH," "we," "us," or "our") is committed to protecting your privacy and ensuring you have a positive experience on our website and in our interactions. This Privacy Policy explains how we collect, use, disclose, and safeguard your information.

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our website or services.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily provide when you:

• ✓ Complete our contact form on the website
• ✓ Request information about our services or training programs
• ✓ Enroll in The Code training program
• ✓ Engage us for consulting services
• ✓ Subscribe to our mailing list or newsletters
• ✓ Participate in surveys or feedback requests
• ✓ Communicate with us via email, phone, or other channels

This information typically includes:

• • Name and contact information (email, phone, mailing address)
• • Company name and job title
• • Business information and industry details
• • Information about your business needs and challenges
• • Payment information (for course enrollment or services)
• • Preferences and communication history

2.2 Information Collected Automatically

When you visit our website, we automatically collect certain information:

• • IP address and device information
• • Browser type and operating system
• • Pages visited and time spent on the website
• • Referring website and links clicked
• • Cookies and similar tracking technologies
• • General location information (derived from IP address)

2.3 Information from Third Parties

We may receive information about you from third parties, including business partners, marketing partners, and public databases, to verify information or supplement the data we hold.

3. How We Use Your Information

We use the information we collect for the following purposes:

• ✓ Service Delivery – To provide consulting services, training programs, and customer support
• ✓ Communication – To respond to inquiries, provide updates, and send relevant information
• ✓ Marketing – To send promotional materials, newsletters, and updates (only with consent where required)
• ✓ Business Operations – To manage subscriptions, process payments, and maintain our records
• ✓ Improvement – To analyze website usage and improve our services and user experience
• ✓ Legal Compliance – To comply with applicable laws, regulations, and legal obligations
• ✓ Fraud Prevention – To detect, prevent, and address fraudulent activity or security issues
• ✓ Research and Analytics – To conduct research and analytics to better understand our customers

4. Legal Basis for Processing (GDPR)

For users in the European Union, our legal basis for processing your personal data includes:

• • Contract Performance – Processing necessary to provide services you've requested
• • Consent – Your explicit consent for marketing and non-essential communications
• • Legal Obligation – Compliance with applicable laws and regulations
• • Legitimate Interests – Our legitimate business interests in operating and improving our services

5. Who We Share Your Information With

5.1 Service Providers

We share information with third-party service providers who assist us in operating our website, providing services, and conducting business. These include payment processors, email service providers, analytics tools, and customer relationship management platforms. All service providers are contractually obligated to maintain confidentiality and use data only for the purposes we specify.

5.2 Business Partners

We may share limited information with business partners for joint marketing efforts or service delivery, only when you have consented or when necessary to provide the services you've requested.

5.3 Legal Requirements

We may disclose your information when required by law, court order, government request, or to protect our legal rights and the safety of our users.

5.4 What We Will NOT Do

We will never sell, rent, or trade your personal information to third parties for marketing purposes without your explicit consent. We do not share personal data with unrelated businesses except as described above.

6. Cookies and Tracking Technologies

6.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us remember your preferences, improve your experience, and analyze website usage patterns.

6.2 Types of Cookies We Use

• • Essential Cookies – Necessary for website functionality
• • Performance Cookies – Help us analyze how you use our website
• • Marketing Cookies – Enable personalized advertising (with consent)

6.3 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse cookies or alert you when cookies are being sent. Please note that disabling essential cookies may affect website functionality.

7. Data Security

We implement comprehensive security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:

• ✓ SSL/TLS encryption for data in transit
• ✓ Secure password storage and authentication
• ✓ Regular security audits and vulnerability assessments
• ✓ Access controls limiting employee access to personal data
• ✓ Monitoring for unauthorized access attempts

However, no method of transmission over the internet is completely secure. While we strive to protect your information, we cannot guarantee absolute security.

8. Data Retention

We retain your personal information for as long as necessary to:

• • Provide the services you've requested
• • Comply with legal and regulatory obligations
• • Resolve disputes and enforce agreements
• • Support legitimate business interests

Specific retention periods vary by data type and purpose. For example, financial records are typically retained for 7 years for tax compliance, while marketing preferences are retained until you request deletion.

9. Your Rights

9.1 GDPR Rights (EU Residents)

If you are located in the European Union, you have the following rights:

• ✓ Right to Access – Obtain a copy of your personal data
• ✓ Right to Rectification – Correct inaccurate data
• ✓ Right to Erasure – Request deletion of your data (with exceptions)
• ✓ Right to Restrict Processing – Limit how we use your data
• ✓ Right to Data Portability – Receive your data in a structured format
• ✓ Right to Object – Opt-out of certain processing activities
• ✓ Right to Withdraw Consent – Withdraw consent at any time

9.2 How to Exercise Your Rights

To exercise any of these rights, please contact us using the information provided in Section 13. We will respond to your request within 30 days (or as required by law).

9.3 Opt-Out Preferences

You can manage your communication preferences at any time by clicking "Unsubscribe" in our marketing emails or by contacting us directly.

10. International Data Transfers

THOTH Consulting is registered in Estonia (OÜ). Your information may be processed in Estonia or other countries where we operate. By providing your information, you consent to such transfers. We implement appropriate safeguards, including Standard Contractual Clauses, to protect data transferred internationally.

11. Third-Party Links and Services

Our website may contain links to third-party websites and services. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing personal information.

12. Children's Privacy

Our services are intended for individuals aged 18 and older. We do not knowingly collect personal information from children under 18. If we discover that a child has provided personal information, we will delete it promptly. If you believe a child has provided information to us, please contact us immediately.

13. Contact Information

For questions about this Privacy Policy or to exercise your privacy rights, contact us at:

Data Protection Officer: For GDPR-related inquiries, please contact our Data Protection Officer at info@thothconsult.eu with "DPO" in the subject line.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The date of the last update will be displayed at the top of this page. Your continued use of our website following the posting of revised Privacy Policy means that you accept and agree to the changes.

15. Compliance and Jurisdiction

This Privacy Policy is governed by applicable laws including the General Data Protection Regulation (GDPR) for EU residents. THOTH Consulting complies with all relevant data protection laws and regulations in all jurisdictions where we operate.