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Privacy Policy

PRIVACY POLICY

Last Updated: December 28, 2025

PROTECTING YOUR PRIVACY

Seamlexly OÜ ('PublicOp', 'we', 'us', 'our'), a company registered in Estonia, is committed to protecting your privacy. We are expressly bound by the principles set forth in the EU General Data Protection Regulation (GDPR). This Privacy Policy ('Policy') explains how we collect, use, store, and disclose your Personal Data.

IMPORTANT DEFINITIONS

  • Data Controller: The natural or legal person who determines the purposes and means of the processing of personal data, and is responsible for the establishment and management of the data filing system.
  • Data Processor: The natural or legal person who processes personal data on behalf of the controller upon their authorization.
  • Data Subject: Any living individual who is the subject of Personal Data and uses our Service.
  • Personal Data: Any information relating to an identified or identifiable natural person. (GDPR Art. 4/1).
  • Special Categories of Personal Data: Data concerning race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance, association, foundation or union membership, health, sexual life, criminal convictions and security measures, and biometric and genetic data.

WHAT IS OUR ROLE IN THE PROCESSING OF PERSONAL DATA?

Before reading the following explanations, we would like to remind you that PublicOp (Seamlexly OÜ) is a Data Processor in the context of the services it provides to its users. As a Data Processor, we carry out data processing activities on behalf of our user (e.g., a research company, foundation, or academic), who is the Data Controller, with respect to the personal data of individuals participating in their surveys ('Data Subjects'). Therefore, PublicOp, as a Data Processor, does not have a determining or decision-making role in the processing of your personal data collected through surveys.

For our daily business operations, we are a Data Controller with respect to the personal data of our own employees, the employees and representatives of our customers (our users), business partners, and vendors.

WHO ARE WE?

Seamlexly OÜ is a technology company registered in Estonia that operates a 'Software as a Service' (SaaS) platform called PublicOp, which enables researchers, academics, and organizations (our users) to create, manage, and analyze surveys to measure societal perceptions.

WHAT KIND OF PERSONAL INFORMATION CAN WE COLLECT AND STORE?

As a Data Processor:

PublicOp provides a platform for our users (Data Controllers) to create and publish surveys. When you participate in a survey ('Survey Participant'), we process your responses on behalf of our user. The type of personal data collected is determined entirely by the user who creates the survey. This data may include, but is not limited to:

  • Demographic information (age, gender, education level, etc.).
  • Opinions, attitudes, and beliefs.
  • Special Categories of Personal Data: Due to the nature of their research, our users may choose to collect special categories of personal data, such as race or ethnic origin, political opinions, or religious beliefs. The purpose and legal basis for collecting this data are entirely the responsibility of the Data Controller, our user.

To obtain information about or exercise your rights regarding your personal data collected through surveys, please first contact the organization that created the survey (the Data Controller).

As a Data Controller:

In our own business operations (administrative, financial, technical, etc.), as a Data Controller, we may collect and process information of the employees and representatives of our users, business partners, and vendors. Depending on the situation, the types of information we may collect as a Data Controller may include:

  • Basic Personal Identifiers: Name, title, affiliated organization, email address.
  • Contact Information: Phone number, business address, or other address information.
  • Identity Data: User ID, User Email, Password (stored encrypted).
  • Payment Details: Billing address, tax number, payment history.
  • Usage and Device Data: Technical data such as device ID, internet protocol (IP) address, and browser type arising from your use of our technology assets (such as our software and website). We also use cookies to improve your experience. For more information, please review our Cookie Policy regarding the specific types of cookies we use (e.g., Essential, Analytics, Marketing) and how you can manage them.

HOW DO WE COLLECT YOUR PERSONAL DATA?

As a Data Controller, we may collect your Personal Data in various ways, including:

  • Directly from you, through our technology assets (registration forms, account settings), phone calls, or emails you send to our company.
  • From other parties, such as your employer.
  • From communication services used by both of us.
  • From our business partners and vendors.
  • When we are required to do so by law.

HOW DO WE USE YOUR PERSONAL DATA?

As a Data Controller, we may hold, use, and disclose your Personal Data as you request or approve in order to provide services to you. Our purposes are:

  • To provide our services to you; to operate, protect, improve, and optimize our platform.
  • To send you service, support, and administrative messages, reminders, technical notices, updates, and security alerts.
  • To comply with our legal obligations, resolve any disputes, and enforce our agreements with third parties.

TO WHOM CAN WE DISCLOSE YOUR PERSONAL DATA?

As a Data Controller, we may disclose your Personal Data to:

  • Our employees.
  • Third-party suppliers and service providers for the operation of our cloud hosting services, websites, and/or our business.
  • Professional advisors.
  • Payment systems operators and billing services.
  • Other persons as required, authorized, or permitted by law, such as government agencies, regulatory bodies, and law enforcement.

COMMUNICATIONS AND MARKETING

As a Data Controller, we may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

HOW DO WE SECURE YOUR INFORMATION?

We use various physical and electronic security measures, including restricting physical access to our offices, implementing network firewalls, secure databases, and access controls, to protect Personal Data from misuse, interference, loss, and unauthorized access, modification, or disclosure.

INTERNATIONAL DATA TRANSFERS AND DATA STORAGE LOCATION

As a company based in Estonia, our primary data storage and processing activities are conducted on secure Google Cloud (GCP) servers located strictly within the European Union (EU). We utilize Google's advanced AI and data processing services, ensuring that all such processing occurs within the EU boundaries in compliance with GDPR.

We engage EasyPrivacy Ltd., a software development partner based in Turkey, to provide technical maintenance and development services. While data storage remains in the EU, specific authorized personnel from EasyPrivacy Ltd. may have limited, monitored remote access to our systems for technical support purposes. To ensure GDPR compliance for this transfer of access, we have signed Standard Contractual Clauses (SCCs) with EasyPrivacy Ltd., guaranteeing that your data remains protected to European standards.

For all other data processing activities, we prioritize keeping data within the European Economic Area (EEA).

WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?

As a Data Subject, you have certain rights granted to you by the Law on the Protection of Personal Data (KVKK, Article 11) and, where applicable, the GDPR. These rights are:

  • To learn whether your personal data is processed.
  • To request information if your personal data has been processed.
  • To learn the purpose of processing your personal data and whether they are used in accordance with their purpose.
  • To know the third parties to whom your personal data is transferred, in the country or abroad.
  • To request correction in case of incomplete or incorrect processing of your personal data.
  • To request the deletion or destruction of your personal data.
  • To request that correction, deletion, or destruction operations be notified to third parties to whom your personal data has been transferred.
  • To object to the occurrence of a result against you by analyzing your processed data exclusively through automated systems.
  • To request compensation for the damage in case you suffer damage due to the unlawful processing of your personal data.

As a Data Controller, we do everything to ensure you can fully exercise these rights.

In cases where we act as a Data Processor (i.e., if you are a Survey Participant), we would like to state that you should first contact the organization that created the survey, which is the Data Controller, to exercise your data rights. In line with requests from the Data Controller, we will assist them with matters such as access, correction, or deletion of your data.

HOW CAN YOU COMPLAIN OR REQUEST MORE INFORMATION ABOUT YOUR PERSONAL DATA?

We take your privacy seriously. If you have any concerns or believe your Personal Data is inaccurate or has been handled in a way that does not comply with the law, please send an email to info@seamlexly.ai.

You have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon). If you constitute a data subject within the EU, you also have the right to lodge a complaint with the data protection authority in your country of residence.

WHAT HAPPENS IF WE CHANGE THIS POLICY?

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. Changes are effective when they are posted on this page. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us or by placing a prominent notice on our website.

CONTACT US

If you wish to contact us regarding this Privacy Policy, please contact us:

  • By email: info@seamlexly.ai
  • By mail: Harju maakond, Tallinn, Kesklinna linnaosa, Sakala tn 7-2, 10141 Estonia (Registry Code: 17021816, VAT: EE102783597)