Primend Privacy Policy
Applicable to the processing of personal data related to the websites, marketing, sales activities, events and other customer communications of Primend OÜ, Primend SIA and Primend UAB
Last updated: 2 November 2026
1. Purpose of this Privacy Policy
Primend respects your privacy and processes personal data responsibly and in accordance with applicable data protection requirements.
This Privacy Policy explains how Primend processes your personal data when you:
- visit a Primend website;
- contact Primend or submit a web form;
- express an interest in Primend services or communicate with our sales team;
- act as a representative of a Primend customer or business partner;
- receive marketing communications from Primend;
- interact with Primend through social media;
- register for or participate in a Primend event or webinar;
- participate in a survey, campaign or other marketing activity;
- contribute to a customer case study, testimonial, photograph, video or other marketing material.
We process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council, the General Data Protection Regulation (GDPR), and other applicable data protection and electronic communications legislation.
2. Who is responsible for processing your personal data?
Primend operates as a group across the Baltic States. This Privacy Policy applies to the following companies within the Primend Group:
Primend OÜ, Estonia
Registry code: 12621569
Address: Lõõtsa 12, Tallinn, 11415, Estonia
Primend SIA, Latvia
Registry code: 40203210749
Address: Skanstes iela 25, Rīga, LV-1013, Latvia
Primend UAB, Lithuania
Registry code: 305660180
Address: V. Gerulaičio str. 10, Vilnius, 08200, Lithuania
Primend's marketing and website activities are organised on a coordinated basis across the Baltic States. Primend Group companies use common technology platforms, business processes and marketing channels. Certain activities, including digital marketing, website management, social media, marketing communications and cookie management, are managed on a group-wide basis.
The controller of your personal data is the Primend Group company with which you have a customer, contractual or other business relationship, or in connection with whose activities your personal data is processed.
Where two or more Primend Group companies jointly determine the purposes and means of processing for a specific group-wide activity, the relevant companies may act as joint controllers in respect of that processing.
For questions concerning the processing of personal data, please contact:
Priit Timpson
priit.timpson@primend.com
3. What personal data do we process?
Depending on your relationship with Primend and the services or channels you use, we may process the following categories of personal data.
Contact and professional information
For example:
- first and last name;
- company or organisation;
- job title;
- business email address;
- telephone number.
Communication data
For example:
- enquiries and messages submitted to Primend;
- sales and customer communication history;
- feedback and survey responses;
- event and webinar registration information.
Website usage data
For example:
- IP address;
- browser and device information;
- pages visited;
- date, time and duration of website use;
- cookie and similar technology identifiers;
- website usage and traffic data.
Marketing data
For example:
- marketing communication preferences;
- records of consent and withdrawal of consent;
- interaction with marketing communications;
- where applicable, information relating to interests or audience segments.
Event and marketing material data
For example:
- event registration and participation information;
- photographs and video recordings;
- information contained in webinar recordings;
- names, job titles, companies, quotations and other agreed information used in customer case studies or testimonials.
We do not knowingly collect more personal data than is necessary for the relevant purpose.
4. Where do we obtain personal data?
We primarily obtain personal data:
- directly from you;
- from your company or organisation;
- in the course of your communications and relationship with Primend;
- when you use Primend websites and digital channels;
- from business and customer management systems used by Primend;
- from publicly available professional sources;
- from social media platforms;
- from an event, campaign or other cooperation partner where there is an appropriate legal basis for disclosing the data to Primend.
Where we obtain your personal data from a source other than you, we will provide you with information about the processing where and within the timeframe required by the GDPR.
5. Website use and cookies
When you use a Primend website, we may process data necessary for the operation and security of the website, analysis of its use and, subject to your consent, marketing activities.
Technologies strictly necessary for the website are used to ensure its technical operation and security.
Analytics and marketing cookies and other non-essential tracking technologies are used on the basis of your consent.
You may change your cookie preferences or withdraw previously given consent at any time through the cookie settings available on the website.
Further information about cookies, service providers, purposes and retention periods is provided in the Primend Cookie Policy.
6. Enquiries and contact forms
When you contact Primend through a web form, by email, telephone or another channel, we process the information you provide in order to:
- respond to your enquiry;
- provide the requested information;
- prepare a quotation or proposal;
- take steps at your request prior to entering into a contract;
- manage subsequent communications.
Where your enquiry relates to the potential conclusion of a contract, processing may be necessary in order to take steps at your request prior to entering into that contract.
In other cases, processing may be based on Primend's legitimate interest in responding to business enquiries and managing customer and business communications.
If you do not provide the contact information required to respond to your enquiry, we may be unable to respond.
7. Prospective customers and sales contacts
Primend may process the professional contact details of representatives of prospective business customers in order to:
- manage sales opportunities;
- respond to enquiries about our services;
- prepare and provide proposals;
- maintain records of previous business communications;
- develop customer relationships.
The data processed may include your name, job title, company, business email address, telephone number and information relating to business communications with Primend.
Business contact management may be based on Primend's legitimate interest in developing its business and customer relationships. Where we rely on legitimate interests, we assess Primend's interests against the rights and interests of the data subject.
When sending marketing communications, we comply with the GDPR and the applicable electronic direct marketing requirements in the relevant country.
8. Direct marketing
Primend may send customers and prospective customers news, invitations, offers and other marketing communications where an appropriate legal basis exists under applicable law.
Depending on the relationship and type of communication, processing may be based on:
- your consent;
- Primend's legitimate interests where such processing is permissible in the particular circumstances;
- provisions of applicable electronic communications legislation permitting communications concerning similar services within an existing customer relationship.
Where processing is based on consent, giving consent is voluntary and you may withdraw it at any time.
You may opt out of direct marketing at any time and free of charge:
- by using the unsubscribe option provided in the marketing communication; or
- by contacting Primend at priit.timpson@primend.com.
Where you object to the processing of your personal data for direct marketing purposes, Primend will no longer process your personal data for those purposes.
We may retain the minimum information necessary concerning your opt-out on a suppression list in order to ensure that your preference continues to be respected.
9. Events and webinars
When you register for a Primend event or webinar, we may process:
- your name;
- company;
- job title;
- business email address;
- telephone number where necessary for organising the event;
- registration and participation information;
- questions submitted by you;
- feedback.
We process this information to manage registration, organise the event or webinar, communicate with participants, provide practical information and collect feedback.
Mandatory information required for registration will be identified on the relevant registration form. If such information is not provided, we may be unable to confirm your registration.
If we wish to use information collected during registration for subsequent marketing communications, we must have a separate appropriate legal basis for that processing.
10. Photographs, videos and webinar recordings
Photographs or video recordings may be made at Primend events. Where this occurs, participants will be informed before the event or at the event venue.
Where a webinar is recorded, participants will be informed before recording begins.
The legal basis for processing photographs, videos and other recordings depends on the purpose and circumstances of their use.
Where we wish to use a photograph, video, interview or other material focusing on an identifiable individual for marketing purposes, we will obtain the individual's consent where required.
11. Customer case studies, testimonials and references
Where you participate in a Primend customer case study, interview, testimonial or other marketing material, we may process, for example:
- your name;
- job title;
- company;
- photograph or video;
- quotations;
- interview or feedback content.
Where such processing is based on your consent, we will obtain that consent before publication.
Providing consent is voluntary. Refusal to provide consent will not affect your or your organisation's customer relationship with Primend.
When requesting consent, we will explain the purposes and channels for which we intend to use the material.
12. Social media
Primend uses social media platforms, including LinkedIn and Meta platforms, to communicate about its activities and engage with customers and other interested parties.
When you interact with Primend through social media, we may process, for example:
- your username;
- professional information made available through your profile;
- comments;
- reactions;
- messages sent to Primend;
- other information that you make available to Primend or publicly through the platform.
We use this information to manage Primend's social media channels, communicate with users and conduct marketing and communications activities.
Certain processing carried out through social media platforms is subject to the terms and privacy policies of the relevant platform provider.
13. Profiling and automated processing
Primend may use website analytics, advertising and marketing platform functionalities to analyse the use of websites and marketing channels and to make marketing communications more relevant.
As part of such processing, users or contacts may be grouped, for example, according to website activity, interests or interaction with marketing content.
Primend does not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you within the meaning of Article 22 of the GDPR.
If Primend introduces such decision-making in the future, this Privacy Policy will be updated before such processing begins.
14. Retention of personal data
Primend retains personal data only for as long as necessary for the purpose for which it was collected or where retention is necessary to comply with a legal obligation or for the establishment, exercise or defence of legal claims.
When determining retention periods, we take into account, in particular:
- the purpose of processing;
- the duration of the customer or business relationship;
- the nature of the personal data;
- applicable legal obligations;
- limitation periods for potential claims;
- the need to demonstrate consent or an opt-out from marketing.
Where processing is based on consent, we will cease the relevant processing following withdrawal of consent unless another legal basis applies to the continued retention of specific information.
When personal data is no longer required, we delete or anonymise it.
The specific retention periods applicable to cookies and similar technologies are provided in the Primend Cookie Policy.
15. With whom do we share personal data?
Primend uses various technology, marketing and support service providers across the Baltic States.
Where necessary, personal data may be disclosed to, for example:
- cloud and IT service providers;
- customer management and support system providers;
- web hosting and web analytics providers;
- consent and cookie management providers;
- email and marketing platforms;
- social media platforms;
- event and webinar service providers;
- marketing and communications partners;
- professional advisers where necessary to protect our rights or comply with our obligations;
- competent public authorities where disclosure is required by law.
Depending on the relevant activity, the platforms and service providers used by Primend include Microsoft, Google, Meta, LinkedIn, Usercentrics and Mailchimp.
Depending on the relevant service and processing activity, a service provider may act as Primend's processor, an independent controller or, in certain circumstances, a joint controller.
16. Transfers of personal data outside the European Economic Area
Primend seeks to process personal data within the European Economic Area where appropriate.
However, some international service providers used by Primend, or their subprocessors, may process personal data outside the European Economic Area.
Where this occurs, we rely on an appropriate transfer mechanism or safeguard under the GDPR, such as:
- an adequacy decision adopted by the European Commission;
- the EU-US Data Privacy Framework where the recipient is duly certified and the relevant transfer falls within the scope of the certification;
- Standard Contractual Clauses approved by the European Commission;
- another appropriate transfer mechanism permitted under the GDPR.
Further information about specific transfers and applicable safeguards may be requested from priit.timpson@primend.com.
17. Security of personal data
Primend implements appropriate technical and organisational measures designed to protect personal data.
These measures are intended to protect personal data against unlawful or unauthorised access, use, alteration, disclosure, loss and destruction.
Access to personal data is limited to Primend personnel and service providers who require such access for the performance of their duties or provision of services.
18. Your rights
Depending on the circumstances of processing, you have the following rights under the GDPR.
Right to information and access
You have the right to obtain confirmation as to whether Primend processes your personal data, information about such processing and a copy of your personal data.
Right to rectification
You have the right to request correction of inaccurate personal data and completion of incomplete personal data.
Right to erasure
Where the conditions set out in the GDPR are met, you have the right to request the erasure of your personal data.
This right is not absolute. In certain circumstances, Primend may have a right or legal obligation to retain the data.
Right to restriction of processing
You have the right to request restriction of the processing of your personal data in the circumstances provided for by the GDPR.
Right to data portability
Where processing is based on consent or a contract and is carried out by automated means, you may have the right to receive personal data you have provided to us in a structured, commonly used and machine-readable format and to transmit that data to another controller.
Right to withdraw consent
Where processing is based on your consent, you may withdraw that consent at any time.
Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to object
Where processing is based on Primend's legitimate interests, you have the right to object to the processing on grounds relating to your particular situation.
Where your personal data is processed for direct marketing purposes, you have the right to object to such processing at any time. Following your objection, Primend will no longer process your personal data for direct marketing purposes.
19. How to exercise your rights
To exercise your rights or ask a question about the processing of personal data, please contact:
Priit Timpson
priit.timpson@primend.com
We will respond to your request without undue delay and generally within one month of receiving it.
Where a request is complex or a large number of requests have been received, the response period may be extended by up to two additional months in accordance with the GDPR. We will inform you within one month of any extension and the reasons for it.
Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm their identity.
20. Right to lodge a complaint
If you believe that Primend has infringed your rights when processing your personal data, we encourage you to contact us first so that we can investigate and, where possible, resolve the matter.
You also have the right to lodge a complaint with the competent data protection supervisory authority:
Estonia: Andmekaitse Inspektsioon (AKI)
https://aki.ee
Latvia: Datu valsts inspekcija (DVI)
https://www.dvi.gov.lv
Lithuania: Valstybinė duomenų apsaugos inspekcija (VDAI)
https://vdai.lrv.lt/en/
You may also exercise any other remedies available to you under applicable law.
21. Changes to this Privacy Policy
Primend may update this Privacy Policy from time to time where our processing activities, services, technologies or applicable legal requirements change.
The current version of the Privacy Policy will be published on the Primend website.
Where a change materially affects the way we process your personal data, we may also provide notice through other appropriate channels.
Last updated: 2 November 2026