Privacy Policy

Last Updated: 2025-06-03

This Privacy Policy explains how Strukturist OÜ ("we," "us," or "our") collects, uses, processes, discloses, and protects your personal data when you visit and make purchases from our website levelthebase.com.

We are committed to protecting your privacy and personal data in compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and the laws of the Republic of Estonia.

1. Important Information and Who We Are

  • 1.1. Data Controller:
    • Strukturist OÜ
    • Registry code: 17051987
    • Address: Savi 3, 86501, Pärnu parish, Estonia
    • Email: info@levelthebase.com
    • We are the data controller responsible for your personal data.
  • 1.2. Purpose of this Privacy Policy: This Privacy Policy aims to give you information on how we collect and process your personal data through your use of this Website, including any data you may provide through this Website when you sign up for an account, subscribe to our newsletter, or purchase a product.
  • 1.3. Third-Party Links: This Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the Privacy Policy of every website you visit.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data: Includes first name, last name.
  • Contact Data: Includes billing address, shipping address, email address, telephone numbers, and company name (for business orders).
  • Financial Data: Includes bank account and payment card details (note: we do not store full payment card details; these are securely processed by our payment gateway providers).
  • Transaction Data: Includes details about payments to and from you, the specific products and services you have purchased (your cart items), chosen shipping method, and shipping costs.
  • Technical Data: Includes internet protocol (IP) address, your login data (if applicable), browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
  • Profile Data: Includes your purchase history, your interests, preferences, feedback, and survey responses.
  • Usage Data: Includes information about how you use our Website, products, and services (e.g., pages viewed, time spent, clicks).
  • Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties, and your communication preferences.
  • Correspondence Data: Includes records of your communication with us (e.g., emails, chat logs, customer support tickets).

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect information about criminal convictions and offenses.

3. How Your Personal Data is Collected

We use different methods to collect data from and about you, including through:

  • Direct interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, chat, or otherwise. This includes personal data you provide when you:
    • Purchase our products;
    • Subscribe to our newsletter or other publications;
    • Request marketing to be sent to you;
    • Enter a promotion, or survey;
    • Give us feedback or contact us.
  • Automated technologies or interactions: As you interact with our Website, we may automatically collect Technical Data about your equipment, Browse actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
  • Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from analytics providers (e.g., Google Analytics).
    • Financial and Transaction Data from payment gateway providers (e.g., Montonio).
    • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.

4. How We Use Your Personal Data (Purposes & Legal Bases)

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • To register you as a new customer:
    • Data Used: Identity, Contact
    • Legal Basis: Performance of a contract with you.
  • To process and deliver your order, including:
    • Managing payments, fees, and charges.
    • Collecting and recovering money owed to us.
    • Data Used: Identity, Contact, Financial, Transaction
    • Legal Basis: Performance of a contract with you; Necessary for our legitimate interests (to recover debts due to us).
  • To manage our relationship with you, which will include:
    • Notifying you about changes to our terms or Privacy Policy.
    • Asking you to leave a review or take a survey.
    • Data Used: Identity, Contact, Profile, Marketing and Communications
    • Legal Basis: Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
  • To enable you to partake in a prize draw, competition, or complete a survey:
    • Data Used: Identity, Contact, Profile, Usage, Marketing and Communications
    • Legal Basis: Performance of a contract with you; Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
  • To administer and protect our business and this Website:
    • Including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data.
    • Data Used: Technical, Identity, Contact
    • Legal Basis: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud); Necessary to comply with a legal obligation.
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you:
    • Data Used: Identity, Contact, Profile, Usage, Marketing and Communications, Technical
    • Legal Basis: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy). (Where consent is required by law for cookies, we obtain that consent).
  • To use data analytics to improve our Website, products/services, marketing, customer relationships, and experiences:
    • Data Used: Technical, Usage
    • Legal Basis: Necessary for our legitimate interests (to define types of customers for our products/services, to keep our Website updated and relevant, to develop our business, and to inform our marketing strategy).
  • To make suggestions and recommendations to you about goods or services that may be of interest to you:
    • Data Used: Identity, Contact, Technical, Usage, Profile
    • Legal Basis: Necessary for our legitimate interests (to develop our products/services and grow our business). (Where consent is required for marketing, we obtain that consent).

5. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes described in Section 4.

  • Internal Third Parties: No internal third parties.
  • External Third Parties:
    • Payment gateway providers: Such as Montonio that securely process your payments.
    • Delivery and logistics services: Such as DPD, DHL, Omniva for shipping your orders.
    • IT and system administration service providers: Including hosting providers, website developers, and technical support.
    • Professional advisors: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
    • Government bodies and regulatory authorities: Such as the Estonian Tax and Customs Board, consumer protection authorities, if required by law or to respond to lawful requests.
    • Analytics and search engine providers: That assist us in the improvement and optimisation of our Website (e.g., Google Analytics).
    • Marketing and advertising partners: For managing our marketing campaigns and serving ads.
  • Third-Party Requirements: We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

We are based in Estonia (EU). Your personal data may be stored and processed both within the European Economic Area (EEA) and, in certain cases, by third-party service providers located outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (Standard Contractual Clauses).
  • Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Data Privacy Framework or an equivalent scheme.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention (How Long We Keep Your Data)

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For example, by law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for 7 years in Estonia after they cease being customers for tax purposes.

In some circumstances, you can ask us to delete your data; see Your Legal Rights below for more information.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • The right to be informed: About how your personal data is collected and used (which this Privacy Policy does).
  • The right to access: To request access to your personal data (commonly known as a "data subject access request").
  • The right to rectification: To request correction of the personal data that we hold about you.
  • The right to erasure: To request the deletion or removal of personal data where there is no good reason for us to continue processing it (also known as the "right to be forgotten").
  • The right to restrict processing: To request the suspension of the processing of your personal data in certain scenarios.
  • The right to data portability: To request the transfer of your personal data to you or to a third party.
  • The right to object to processing: Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Rights in relation to automated decision making and profiling: The right to object to decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. (Note: Most e-commerce activities don't involve this unless sophisticated profiling is used).
  • The right to withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw that consent at any time.

If you wish to exercise any of the rights set out above, please contact us at info@levelthebase.com.

You also have the right to make a complaint at any time to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), the Estonian supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

10. Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site.

What are Cookies? A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

How We Use Cookies and Their Legal Basis: We use different types of cookies for various purposes. We generally rely on your consent for all non-essential cookies. For strictly necessary cookies, our legal basis is our legitimate interest to ensure the proper functioning and security of our Website, or for the performance of our contract with you (e.g., enabling your shopping cart).

The types of cookies we may use are:

  • Strictly Necessary Cookies: These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart, or make use of e-billing services. You cannot opt-out of these cookies as the Website cannot function properly without them.
    • Examples: Session cookies for shopping cart, login authentication cookies, security cookies.
    • Legal Basis: Legitimate interest (Website functionality and security) or Performance of a contract.
  • Analytical or Performance Cookies: These allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily. We only use these cookies if you provide your consent.
    • Examples: Google Analytics cookies (e.g., _ga, _gid), website performance monitoring cookies.
    • Legal Basis: Consent.
  • Functionality Cookies: These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name, and remember your preferences (for example, your choice of language or region). We only use these cookies if you provide your consent.
    • Examples: Language preference cookies, currency selection cookies.
    • Legal Basis: Consent.
  • Targeting or Advertising Cookies: These cookies record your visit to our Website, the pages you have visited, and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. We only use these cookies if you provide your consent.
    • Examples: Google Ads cookies, Facebook Pixel cookies, retargeting cookies.
    • Legal Basis: Consent.

First-party vs. Third-party Cookies:

  • First-party cookies: These are cookies set by our Website directly.
  • Third-party cookies: These are cookies set by a domain other than that of our Website. For example, if we use a third-party analytics service like Google Analytics, Google will set its own cookies to provide that service.

Managing Your Cookie Preferences: You have the right to decide whether to accept or reject cookies that are not strictly necessary. You can manage your cookie preferences through:

  1. Our Cookie Consent Tool: When you first visit our Website, or by clicking on the 'Cookie Preferences' link usually found in the footer of our Website, you will be presented with a cookie consent banner/tool that allows you to accept or reject different categories of cookies (excluding strictly necessary ones). You can change your choices at any time through this tool.
  2. Browser Settings: Most web browsers allow you to control cookies through their settings. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.

11. Changes to the Privacy Policy

We keep our Privacy Policy under regular review. This version was last updated on the date stated at the beginning of this policy. Any changes will be posted on this page. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

12. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us in the following ways: