Privacy Policy

ClickSambo Privacy Policy

Last Updated: July 7, 2025
Effective Date: July 7, 2025

1. Introduction and Who We Are
This Privacy Policy describes how ClickSambo OÜ d.b.a. ClickSambo ("ClickSambo," "we," "us," or "our") collects, uses, and shares information about you through our website (clicksambo.com) and associated services (collectively, the "Services").

ClickSambo is a company established under the laws of Estonia, with a principal place of business at Harju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 15551.

For the purpose of the General Data Protection Regulation (GDPR) and other relevant data protection laws, ClickSambo is the data controller of the personal information we process.

We are committed to protecting your privacy. Please read this notice carefully. If you have any questions, please contact us at [email protected].

2. Our Legal Basis for Processing Your Information
We only collect and process your personal data when we have a lawful basis to do so. Our lawful bases include:

• Consent: Where you have given us clear consent for a specific purpose (e.g., subscribing to a newsletter). You can withdraw this consent at any time.
• Contractual Necessity: Where processing is necessary for the performance of a contract with you (e.g., to create your account and provide you with our Services).
• Legitimate Interest: Where we have a legitimate business interest, such as improving our Services, marketing, or protecting our legal rights, provided it does not override your fundamental rights and freedoms.
• Legal Obligation: Where we need to process your information to comply with a legal or regulatory obligation.

3. Information We Collect
We may collect and process the following categories of information:

• Identity Data: Your first name, last name, and username.
• Contact Data: Your email address, phone number, and billing address.
• Financial Data: Payment card details. Please note, we do not store this data. It is collected and processed securely by our third-party payment processors (e.g., Stripe).
• Technical Data: Your Internet Protocol (IP) address, browser type and version, device information, operating system, and time zone setting.
• Usage Data: Information about how you use our website and Services, such as pages viewed, resources accessed, activity logs, and referring/exit pages.
• Marketing and Communications Data: Your preferences for receiving marketing from us and your communication preferences. 

4. How We Use Your Information
We use the information we collect for the following purposes, based on our legal grounds:

• To provide our Services (Contractual Necessity): To create and manage your account, process payments, and deliver the core functionality of our Services.
• To improve our Services (Legitimate Interest): To analyze usage patterns, troubleshoot issues, and develop new features to enhance your experience.
• To communicate with you (Legitimate Interest & Consent): To respond to your inquiries, send you important service updates, and provide information you have requested. We will only send you marketing materials where we have your explicit consent to do so.
• To ensure security (Legitimate Interest): To protect our website, Services, and users from fraud, abuse, and security threats.
• To comply with law (Legal Obligation): To meet our legal, regulatory, and compliance requirements.

5. Cookies and Tracking Technologies
We use cookies and similar technologies to collect information about your computer and general internet use. These are small data files stored on your device.

• Strictly Necessary Cookies: Essential for you to browse the website and use its features.
• Performance Cookies: Collect statistical information about how visitors use our website. This data is aggregated and anonymous and helps us improve our Services.
• Functionality Cookies: Allow the website to remember choices you make and provide enhanced features.

You can adjust the settings on your computer to decline cookies. Please note that if you do, some parts of our website may not function properly.

6. Data Sharing and Disclosure
We will never sell your personal data. We will not disclose your personal information to any other party other than in accordance with this Privacy Policy and in the circumstances detailed below:

• Service Providers (Sub-processors): We use trusted third-party companies to assist us in providing our Services (e.g., payment processors, cloud hosting providers, analytics services). These contractors have limited access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
• Business Transfers: In connection with a merger, acquisition, reorganization, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.
• Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

7. International Data Transfers
We operate globally, which means your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country.

When we transfer your personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards, primarily by using Standard Contractual Clauses (SCCs) approved by the European Commission.

8. Data Retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use, and the purposes for which we process it.

9. Data Security
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

10. Your Data Protection Rights (Under GDPR)
If you reside in the EEA or UK, you have the following rights regarding your personal data: 

• The right to access: You can request copies of your personal data.
• The right to rectification: You can request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
• The right to erasure (the "right to be forgotten"): You can request that we erase your personal data, under certain conditions.
• The right to restrict processing: You can request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing: You can object to our processing of your personal data, under certain conditions.
• The right to data portability: You can request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• The right to withdraw consent: You can withdraw your consent at any time where we are relying on consent to process your data.
• The right to complain to a supervisory authority.

To exercise any of these rights, please contact us at [email protected]

11. Children’s Privacy
Our Services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 16.

12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The updated version will be indicated by a "Last Updated" date and will be effective as soon as it is accessible. We will notify you of any material changes by posting a notice on our website.

13. Contact Us
If you have questions or comments about this policy, you may email us at:
[email protected]
Or by post to:

ClickSambo OÜ
Harju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 15551, ESTONIA