Privacy Policy
This Privacy Policy explains how Anticitizen OÜ collects, uses, shares, and protects your personal data when you visit anticitizen.com, subscribe to our publication, join our membership community, or otherwise interact with us. It is written to comply with the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and applicable Estonian law.
Please read it carefully. If you do not agree with it, please do not use our website or services.
1. Who we are (the data controller)
The data controller responsible for your personal data is:
Anticitizen OÜ
Contact: via our contact page
Website: anticitizen.com
In this policy, "we," "us," and "our" refer to Anticitizen OÜ.
We have not appointed a Data Protection Officer, as we are not required to do so under Article 37 GDPR. For any privacy question, contact us through our contact page.
2. The personal data we collect
Depending on how you interact with us, we may collect the following categories of personal data:
- Identity and contact data: name, email address, username, and any details you provide when you register, subscribe, or contact us.
- Account and membership data: your membership status, subscription plan, preferences, and content you post inside our community.
- Payment data: billing details and transaction records. Card numbers and full payment credentials are processed directly by our payment provider and are not stored by us.
- Communications data: messages you send us by email, through our community platform, or through messaging tools such as direct messages on social media.
- Technical and usage data: IP address, device and browser type, operating system, pages viewed, referring website, and similar information collected through cookies and similar technologies (see our Cookie Policy).
- Marketing data: your preferences for receiving marketing from us and your engagement with our emails and advertising.
We do not intentionally collect special categories of personal data (such as data on health, religion, or political opinions). Please do not share such data with us unless strictly necessary.
3. How we collect your data
We collect personal data:
- Directly from you, when you subscribe, register, pay, post in the community, or contact us.
- Automatically, through cookies and similar technologies when you use our website (see the Cookie Policy).
- From third parties and platforms, such as our community platform, payment provider, email and messaging tools, and advertising platforms, which may share limited data with us in line with their own terms and privacy notices.
4. Why we use your data and our legal bases
We only process your personal data where we have a lawful basis under Article 6 GDPR. The bases we rely on are:
- Performance of a contract (Article 6(1)(b)): to create and manage your account, provide the publication and membership community, process payments, and provide customer support.
- Consent (Article 6(1)(a)): to send you marketing communications where required, to set non-essential cookies, and where we otherwise ask for your consent. You can withdraw consent at any time.
- Legitimate interests (Article 6(1)(f)): to operate, secure, and improve our website and services, to understand how our content performs, to prevent fraud and abuse, and to grow our business through marketing. Where we rely on legitimate interests, we have weighed them against your rights and interests.
- Legal obligation (Article 6(1)(c)): to comply with accounting, tax, and other legal requirements.
The specific purposes for which we use your data include: providing and administering your subscription and membership; processing payments and keeping financial records; communicating with you about your account and our services; sending newsletters and marketing where permitted; running and measuring advertising campaigns; analysing and improving our website and content; and protecting our rights, users, and systems.
5. Marketing and advertising
If you subscribe to our publication or otherwise opt in, we may send you newsletters and marketing emails. You can unsubscribe at any time using the link in each email or by contacting us.
We also run advertising campaigns on third-party platforms (such as social media). These platforms may use cookies, pixels, and similar technologies to show you our ads and to measure their effectiveness, including by creating audiences based on website visitors. This may involve profiling for marketing purposes, which is carried out on the basis of your consent to non-essential cookies. It does not produce legal or similarly significant effects on you. You can control this through our cookie banner and through your settings on the relevant platform.
6. Who we share your data with
We share personal data only as necessary, with the following categories of recipients, who act as our processors or as independent controllers under their own terms:
- Our community and publication platform provider Circle.
- Our payment provider Stripe.
- Our email and newsletter provider Beehiiv.
- Our messaging and chat automation tools ManyChat.
- Our advertising and analytics providers Meta Platforms and Google.
- Our website hosting and IT service providers Lovable.
- Professional advisors (such as accountants and lawyers) and public authorities, where required by law.
We require our processors to protect your data and to process it only on our instructions. We do not sell your personal data.
7. International transfers
Some of our providers are located outside the European Economic Area (EEA), including in the United States. Where we transfer personal data outside the EEA, we rely on appropriate safeguards under Chapter V GDPR, such as:
- the European Commission's adequacy decisions, including the EU-US Data Privacy Framework where the recipient is certified; or
- Standard Contractual Clauses approved by the European Commission, together with any additional measures needed.
You can request more information about these safeguards using the contact details above.
8. How long we keep your data
We keep personal data only as long as necessary for the purposes described in this policy, including to satisfy legal, accounting, or reporting requirements. As a general guide:
- Account and membership data is kept for as long as your account is active and for a reasonable period afterwards.
- Financial and transaction records are kept for the period required by Estonian accounting and tax law (generally seven years).
- Marketing data is kept until you unsubscribe or object, and for a short period afterwards.
When we no longer need your data, we delete or anonymise it.
9. Your rights
Under the GDPR, you have the right to:
- access your personal data and obtain a copy of it;
- rectify inaccurate or incomplete data;
- erase your data ("right to be forgotten") in certain circumstances;
- restrict processing in certain circumstances;
- object to processing based on legitimate interests, and to object at any time to processing for direct marketing;
- data portability, to receive your data in a structured, commonly used, machine-readable format;
- withdraw consent at any time, where we rely on consent, without affecting processing carried out before withdrawal.
To exercise any of these rights, contact us through our contact page. We will respond within one month, as required by the GDPR. There is normally no charge, although we may charge a reasonable fee or refuse a request that is manifestly unfounded or excessive.
10. Your right to complain
If you believe we have not handled your personal data properly, we ask you to contact us first so we can try to resolve the matter. You also have the right to lodge a complaint with the Estonian supervisory authority:
Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate)
Tatari 39, 10134 Tallinn, Estonia
Email: info@aki.ee
Website: www.aki.ee
Phone: +372 627 4135
You may also complain to the supervisory authority in your country of residence within the EEA.
11. Security
We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse. However, no online service can be guaranteed to be completely secure, and you share data with us at your own risk.
12. Children
Our website and services are intended for adults. We do not knowingly collect personal data from anyone under the age of 18. If you believe a minor has provided us with personal data, please contact us so we can delete it.
13. Changes to this policy
We may update this Privacy Policy from time to time. The current version is always available on this page, with the "last updated" date shown above. If we make significant changes, we will take reasonable steps to notify you.
14. Contact
For any question about this policy or your personal data, contact us through our contact page.
