Privacy Policy
Last updated: October 2025
1. Introduction
Cirstrust Tech OÜ ("CIRS," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, and protect your information when you visit our website trustcirs.com or use our services.
2. Data Controller
Cirstrust Tech OÜ
Registration: 17703240398
Address: Sepapaja tn 6, 15551 Tallinn, Estonia
Email: trustcirs@pm.me
3. Information We Collect
3.1 Information You Provide
- Contact information (name, email, phone) when you fill out forms
- Hotel/company information for partnership inquiries
- Authentication credentials for partner dashboard access
- Communications you send us
3.2 Automatically Collected Information
- IP address and location data
- Browser type and version
- Device information
- Pages visited and time spent
- Referring website
- Google Analytics data (anonymized)
4. Legal Basis for Processing
We process your personal data based on:
- Consent: For marketing communications and cookies
- Contract: To provide our services to partners
- Legitimate Interest: For business operations and fraud prevention
- Legal Obligation: To comply with applicable laws
5. How We Use Your Information
- To provide and improve our review verification services
- To respond to inquiries and support requests
- To send service updates to partners
- To analyze website usage and improve user experience
- To detect and prevent fraud
- To comply with legal obligations
6. Data Sharing
We do not sell your personal data. We may share data with:
- Service Providers: Google Analytics, Netlify (hosting), Formspree (forms)
- Legal Requirements: When required by law or court order
- Business Protection: To protect our rights and prevent fraud
7. Data Security
We implement appropriate technical and organizational measures to protect your personal data, including:
- SSL/TLS encryption for data transmission
- Secure password requirements
- Limited access to personal data
- Regular security assessments
8. Data Retention
- Partner data: Duration of partnership plus 3 years
- Inquiry data: 2 years from last contact
- Analytics data: 26 months (Google Analytics default)
- Legal records: As required by Estonian law
9. Your Rights (GDPR)
Under GDPR, you have the right to:
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate data
- Erasure: Request deletion of your data
- Portability: Receive your data in a portable format
- Object: Object to certain processing
- Restrict: Request processing restrictions
- Withdraw consent: At any time for consent-based processing
To exercise these rights, contact us at trustcirs@pm.me
10. Cookies
We use cookies to improve your experience. See our Cookie Policy for details. You can manage cookie preferences through our cookie banner.
11. International Transfers
Your data may be transferred to countries outside the EEA. We ensure appropriate safeguards through:
- Standard Contractual Clauses
- Adequacy decisions
- Your explicit consent
12. Children's Privacy
Our services are not intended for individuals under 18. We do not knowingly collect data from children.
13. Changes to This Policy
We may update this policy periodically. We will notify partners of material changes via email.
14. Supervisory Authority
You have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at aki.ee
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