Privacy Policy

1. Who We Are

Mintreach is operated by Mintagency OÜ, a company registered in the Republic of Estonia (registry code 16972018, Tallinn, Estonia). We are the data controller for personal data we collect directly (your account information) and a data processor for personal data you process through our Service (your campaign data and lead lists).

Data Protection Contact: hello@mintagency.eu

2. Data We Collect

A. Account Data (we are the controller)

When you create an account, we collect your name, email address, company name, and payment information.

Legal basis: Contract performance (Article 6(1)(b) GDPR) — necessary to provide the Service.

B. Usage Data (we are the controller)

We automatically collect IP address, browser type, pages visited, feature usage, and campaign performance metrics (open rates, reply rates).

Legal basis: Legitimate interest (Article 6(1)(f)) — to improve and secure the Service.

C. Business Registry Data (we are the controller)

We source company information from official public government registries, including company names, registry codes, business email addresses, phone numbers, addresses, industry codes, and legal forms.

Data sources:

• Estonian Äriregister (avaandmed.ariregister.rik.ee)
• Finnish Patent and Registration Office, PRH (avoindata.prh.fi) — CC BY 4.0 license
• Norwegian Brønnøysund Register Centre (data.brreg.no)
• Latvian Register of Enterprises (dati.ur.gov.lv)
• Lithuanian Centre of Registers (registrucentras.lt)

Legal basis: Legitimate interest (Article 6(1)(f)) — the data is publicly available, published by governments for business transparency, and used for relevant B2B communications.

D. Campaign Data (we are the processor; you are the controller)

When you create campaigns, we process on your behalf: lead lists, email content, sending schedules, and tracking data. You determine the purposes and means of this processing. We process this data only according to your instructions and these Terms.

3. How We Use Your Data

• To provide and maintain the Service
• To process your transactions and manage your account
• To send you Service-related notifications
• To improve the Service, fix bugs, and develop new features
• To prevent fraud, abuse, and security threats
• To comply with legal obligations

4. Data Sharing

We do not sell your personal data. We may share data with:

• Infrastructure providers: Vercel (hosting), Supabase (database) — acting as sub-processors under appropriate data processing agreements
• Email providers: Google Gmail API, Microsoft Graph API, or your IMAP/SMTP provider — used to send emails from YOUR account on your behalf. We do not share your data with these providers; we use their APIs to send mail through your own connected account.
• AI providers: Anthropic (email content generation) — acting as a sub-processor. Email content is processed to generate personalized outreach but is not stored for training purposes.
• Law enforcement: If required by law or valid legal process

5. Data Retention

• Account data: Retained while your account is active, plus 12 months after deletion for legal and accounting purposes.
• Campaign data: Retained while your account is active. Deleted within 30 days of account termination.
• Business registry data: Updated periodically from source registries. Individual records are removed upon valid deletion request.
• Usage logs: Retained for 12 months, then anonymized or deleted.

6. Your Rights

Under GDPR, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate data.
• Erasure: Request deletion of your data ("right to be forgotten").
• Restriction: Request that we limit how we process your data.
• Portability: Request your data in a machine-readable format.
• Object: Object to processing based on legitimate interest.
• Withdraw consent: Where processing is based on consent, withdraw it at any time.

To exercise any of these rights, contact us at hello@mintagency.eu. We will respond within 30 days.

7. Rights of Email Recipients

If you received an email sent through Mintreach and wish to:

• Opt out of further emails: Reply to the sender or use the opt-out mechanism provided in the email.
• Request data deletion: Contact us at hello@mintagency.eu with your email address. We will remove your data from our database and add you to our global suppression list so that no Mintreach user can contact you again.
• File a complaint: You have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at aki.ee or with your local data protection authority.

8. International Transfers

Your data may be processed outside the EEA by our infrastructure providers. Where this occurs, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission or equivalent adequacy frameworks.

9. Security

We implement appropriate technical and organizational measures to protect your data, including encryption in transit (TLS), secure authentication, access controls, and regular security reviews. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

10. Cookies

We use essential cookies required for the Service to function (authentication, session management). We may use analytics cookies to understand how the Service is used. You can control cookie settings through your browser.

11. Children

The Service is not directed at individuals under 18 years of age. We do not knowingly collect personal data from children.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email or through the Service. Your continued use of the Service after changes constitutes acceptance of the updated Policy.

13. Contact & Supervisory Authority

Data Protection Contact:
Mintagency OÜ
Registry code: 16972018
Tallinn, Estonia
Email: hello@mintagency.eu

Supervisory Authority:
Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)
Tatari 39, 10134 Tallinn
Website: aki.ee
Email: info@aki.ee

Mintreach is a product of Mintagency OÜ