Privacy Policy

1. Who We Are (Data Controller)

Thinkware Design operates this website. We are based in Latvia, European Union. The data controller (the legal entity responsible for how your personal data is processed) is SIA „Akadēmija "SAPŅU OSTA"", company registration number 40103719962, VAT number LV40103719962, registered address Hamburgas iela 8, Rīga, LV-1014.

Privacy contact: hello@thinkwaredesign.com

2. What Data We Collect

Contact Form

When you submit our contact form, we collect your name, email address, and optional message.

Payments and Checkout

When you purchase a program, Stripe collects your name, email, billing address, VAT status/location, and payment card details on our behalf. We do not have access to your full card details.

Analytics and Session Recording

We use Google Analytics 4 (provider: Google) and PostHog (provider: PostHog, US) to understand how the site is used. Google Analytics collects usage data, device information, and approximate location, and sets cookies. PostHog provides product analytics and session recording - session replays are captured with input fields masked, and uses cookies and local storage. These identifiers are personal data, not anonymous data.

We also use Vercel Analytics for aggregate, cookieless page view data and Vercel Speed Insights to measure performance (Core Web Vitals). See our Cookie Policy for the full list of cookies and trackers, categories, and how to change your choice.

3. Why We Process Your Data (Purpose and Legal Basis)

• Payment and checkout: to process your purchase, issue receipts, and meet accounting/VAT obligations - legal basis: performance of a contract and legal obligation.
• Contact form: to respond to your inquiry - legal basis: consent (submitting the form) and our legitimate interest in answering questions about our programs.
• Analytics (Google Analytics 4, Vercel Analytics/Speed Insights): to understand site usage and improve the experience - legal basis: consent, given via the cookie banner.
• Session replay (PostHog): to understand user behavior and diagnose usability issues - legal basis: consent, given separately from general analytics consent.
• Transactional email (Resend): to send purchase confirmations and receipts - legal basis: performance of a contract.

4. Recipients - Who We Share Data With

We share personal data only with the processors strictly needed to run the site and deliver our services, listed in the table below. We do not sell personal data.

5. International Data Transfers

Some of our processors (Google, PostHog, and Vercel) are based in or transfer data to the United States. Where personal data leaves the European Economic Area, we rely on the safeguards each processor puts in place under its data processing agreement, which may include the European Commission's Standard Contractual Clauses and/or participation in the EU-US Data Privacy Framework where applicable. We do not independently certify a processor's Data Privacy Framework status; refer to each processor's own privacy policy (linked in section 7) for their current certification and safeguards.

6. How Long We Keep Your Data

Contact form submissions are sent directly via email and are not stored in our own database. Payment-related personal data (name, email) is not retained in our own systems beyond transient serverless function execution; Stripe retains payment records as required by financial/accounting law. Resend retains email delivery records according to its own retention policy. Analytics and session replay data is retained by Google and PostHog according to their respective retention settings, generally for up to 14 months (Google Analytics) or per our PostHog project configuration.

7. Your Rights (GDPR)

Under the General Data Protection Regulation, you have the right to:

• Access the personal data we hold about you
• Rectify inaccurate personal data
• Request erasure of your personal data
• Restrict processing of your personal data
• Object to processing of your personal data
• Data portability
• Withdraw consent at any time (e.g. via the cookie banner), without affecting processing already carried out

To exercise any of these rights, contact us at hello@thinkwaredesign.com.

You also have the right to lodge a complaint with the Latvian Data Protection Authority, Datu valsts inspekcija (DVI), at www.dvi.gov.lv, or with the supervisory authority in your own EU member state.

8. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal or similarly significant effects on you.

9. Is Providing Your Data Required?

Providing payment and contact details is necessary to purchase a program or to receive a response to your inquiry; without this data we cannot process your order or reply to you. Analytics and session replay data is entirely optional - if you decline or do not consent, the site remains fully usable and no purchase or contact-form functionality is affected.

10. Cookies

For a full list of cookies and trackers used on this site, their provider, purpose, duration, and category, see our Cookie Policy. You can change your consent choice at any time via the cookie banner.

11. Third-Party Services

• Vercel (hosting): vercel.com/legal/privacy-policy
• Google (Google Analytics 4): policies.google.com/privacy
• PostHog (analytics and session recording): posthog.com/privacy
• Stripe (payments): stripe.com/privacy
• Resend (email): resend.com/legal/privacy-policy

12. Changes to This Policy

We may update this privacy policy from time to time. The date at the top of this page indicates when it was last revised.

13. Contact

For any questions about this privacy policy or your personal data, contact us at hello@thinkwaredesign.com.