PRIVACY POLICY

Last updated: 2025-08-15

1) Controller and contacts

Controller: SIA KOSH (ZINIMI), Reg. No. 50203225981, legal address: Kokles iela 8, Mārupe.

Privacy issues and data subject requests: info@zinimi.com.

If you believe that your data is being processed inappropriately, you have the right to contact the Data State Inspectorate (www.dvi.gov.lv).

2) What information we process

Waitlist/newsletter: email (required), name (if provided), language, selected topics/interests, consent status (double opt-in), date/time of registration, IP address, and technical information about the device (in server log files).

Contact form: name, email, message content.

Technical data and cookies: see section 8.

Payment data: not processed (platform top; we will update our policy before introducing payments).

We obtain data directly from you when you fill out our web forms (Fluent Forms) or contact us by email.

3) Purpose and legal basis

Reports on the launch of the platform, news, and links to free introductory courses — processing based on consent (GDPR 6(1)(a)); we use double opt-in confirmation.
Responses to your requests (contact form) — legitimate interests in ensuring communication and support (GDPR 6(1)(f)).
Security and prevention of abuse (server logs, anti-spam solutions) — legitimate interests (GDPR 6(1)(f)).
Compliance with legal obligations (e.g., request logging) — (GDPR 6(1)(c)).
You can withdraw your consent at any time (at the end of each email or by writing to info@zinimi.com). Withdrawal does not affect the lawfulness of processing prior to withdrawal.

4) Data retention

Waiting list/news list: until consent is withdrawn or 24 months after the last activity (whichever comes first).

Contact form requests: up to 12 months after the last communication.

Server logs and security records: up to 12 months.

We may extend these periods if required by legal obligations or dispute resolution.

5) Where is the data stored and to whom is it transferred

WordPress (Fluent Forms/FluentCRM/FluentSMTP) — data is stored in our server database (Hostinger/EU).

Google Workspace (Gmail API via FluentSMTP) — for sending transaction/opt-in emails (Google is our data processor, Google DPA and SCC apply).

Cloudflare — for DNS/CDN and security purposes (data may be transferred outside the EEA with appropriate safeguards).

Other third parties (only if activated):

Google reCAPTCHA / hCaptcha (anti-spam protection for forms),

Embedded videos (YouTube/Vimeo) — if you view content on our site.

We do not sell personal data or disclose it to marketing partners outside of those mentioned here. Information may be transferred to supervisory authorities or law enforcement agencies if required by law.

6) Transfer outside the EEA

When using Google and Cloudflare, data may be processed outside the EEA. In such cases, Standard Contractual Clauses (SCC) and other security measures under Article 46 of the GDPR are used.

7) Your rights

You have the right to:

receive information about the processing and access your data;

correct inaccurate data;

request erasure ("right to be forgotten");

restrict processing;

object to processing based on legitimate interests;

receive data in a portable format (if applicable);

withdraw consent at any time.

Please send requests to info@zinimi.com. We will respond within 30 days.

8) Cookies

We use:

Necessary cookies (for website functionality, security, form submission).

Analytics cookies (e.g., GA4) — only with your consent; currently [if not used — delete this sentence].

Third-party cookies if you load external content on the page (e.g., YouTube/Vimeo).

Targeted advertising cookies are not currently used.

You can manage your cookie settings in the website banner or in your browser settings.

9) Automated decision-making

No automated individual decision-making with legal effects is carried out.

10) Security

We apply appropriate technical and organizational measures (SSL/TLS, access control, regular updates, principle of minimum access).

11) Changes

The policy may be updated. The current version is always available on this page; changes take effect upon publication.