Privacy Policy — Tuluko Group OÜ

Controller information

The Controller responsible for processing your Personal Data is:

Tuluko Group OÜ, registry code: 14335661.
Registered address: Tuukri tn 19-315, 10120 Tallinn, Estonia
Write us: [email protected]
Website: https://reputationtower.ai

Definitions

• Personal Data — any information relating to an identified or identifiable natural person.
• Processing — any operation performed on Personal Data, such as collection, recording, organization, storage, use, disclosure, or deletion.
• Controller — the entity that determines the purposes and means of processing Personal Data.
• Processor — an entity processing Personal Data on behalf of the Controller.
• User / Client — any individual visiting the Website or using the Services.
• Services — any products or services offered through the Website.

Types of data we collect

We may collect and process the following categories of data:

Data you provide

When using our Website or Services, you may provide:

• Name, surname, and identification data
• Date of birth, nationality, gender
• Email address, phone number, postal address
• Government-issued identification (e.g., passport, ID card)
• Financial or billing information (e.g., bank or payment details)
• Employment and professional details
• Photos or identification documents (for verification purposes)

Data collected automatically

When you visit the Website, we may automatically collect:

• IP address, browser type, and device information
• Operating system, language, and referral URLs
• Date/time of access and clickstream data
• Session activity and preferences (through cookies and analytics tools)

Third-party data

You may provide data relating to third parties (e.g., authorized representatives). You must ensure you have the right to share such information.

Sensitive data

We do not intentionally collect sensitive data such as racial or ethnic origin, political opinions, religious beliefs, or health-related data.

Purposes and legal bases of processing

Your Personal Data may be processed for the following purposes:

We process your Personal Data only when we have a valid legal basis to do so under the General Data Protection Regulation (GDPR). We do not sell, rent, or trade your Personal Data to any third parties.

Marketing and communication

If you subscribe to our newsletter or updates, we may send you information about Services, events, and offers. You may unsubscribe at any time by clicking the link in any marketing email or adjusting your communication preferences. Marketing communications are sent only with your consent or when permitted by law.

Cookies and tracking technologies

We use cookies and similar technologies to enhance your experience, analyze performance, and personalize content. For more details, please see our Cookie Policy.

We may use third-party tools for analytics and marketing, including:

• Google Analytics — website analytics
• Hotjar — user experience analysis
• Meta/Facebook Pixel and Google Ads — advertising and remarketing
• LinkedIn Insight Tag — advertising & remarketing
• TikTok Pixel — advertising & remarketing
• Microsoft Clarity — user experience
• Google Tag Manager — tag management

You can manage cookies through your browser settings. Disabling certain cookies may affect website functionality.

Sharing of personal data

We may share your Personal Data with:

• Authorized service providers assisting in hosting, analytics, marketing, payment processing, or IT support
• Payment processors such as Stripe, PayPal, Wise, or Revolut Business
• Legal and regulatory authorities, where required by law
• Business partners or affiliates, where necessary for service delivery
• Third parties in the event of a merger, sale, or business restructuring

We may engage external data processors under written agreements ensuring compliance with GDPR and equivalent security standards. All third-party providers process your data only according to our instructions and with appropriate confidentiality safeguards.

We may transfer your data outside the European Economic Area (EEA). In such cases, we ensure adequate protection using Standard Contractual Clauses or other lawful mechanisms approved by the European Commission.

Data retention

We store your Personal Data only as long as necessary for the purposes described in this Policy or as required by law. Typical retention periods include:

• Service and account data — for the duration of your customer relationship
• Legal or financial records — up to 5–7 years after contract termination
• Marketing data — until you withdraw consent

After expiration, your data will be securely deleted or anonymized.

Your rights

Under the GDPR and applicable data protection laws, you have the following rights:

• Access: request a copy of your Personal Data we hold.
• Rectification: correct inaccurate or incomplete data.
• Erasure (“Right to be Forgotten”): request deletion of your Personal Data under certain circumstances.
• Restriction: limit processing of your Personal Data.
• Data portability: request transfer of your data to another controller.
• Objection: object to processing based on legitimate interests or for direct marketing.
• Withdraw consent: withdraw previously given consent without affecting prior lawful processing.
• Lodge a complaint: with a supervisory authority if you believe your rights have been violated.

Requests regarding your Personal Data may be sent to: [email protected]

Data security

We use appropriate technical and organizational measures to protect your Personal Data, including:

• Data encryption (SSL/TLS)
• Secure servers and firewalls
• Access controls and employee confidentiality agreements
• Regular security audits and monitoring

Despite our efforts, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute protection. If a data breach occurs, affected individuals and supervisory authorities will be notified in accordance with applicable law.

International data transfers

Your information may be transferred and processed outside your country of residence, including countries that may not offer the same data protection standards. Such transfers will be protected by appropriate legal safeguards, such as Standard Contractual Clauses approved by the European Commission.

Children’s privacy

Our Website and Services are not directed to persons under 18. We do not knowingly collect Personal Data from minors. If we learn that data has been collected from a minor, we will delete it promptly.

Policy updates

We may update this Privacy Policy from time to time. The updated version will be published on our Website with a new “Last Updated” date. Continued use of the Website after updates constitutes acceptance of the revised terms.

Contact

If you need any clarification, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Tuluko Group OÜ
Tuukri tn 19-315, 10120 Tallinn, Estonia
Email: [email protected]
Website: https://reputationtower.ai