Privacy

Last updated: 9 November 2026.

1. Data controller

The Imagine\TBWA website is operated by Imagine AD OÜ, registry code 10885979, Tartu mnt 63, Tallinn, Estonia. For questions about personal data, contact imagine@imagine.ee.

This notice covers visits to the main website, newsletter subscriptions and communication through the contact details published on it.

2. What information do we use and why?

• Enquiries and correspondence. If you email or call us, we use the contact information and message content you provide to respond and discuss possible work together. Providing information is voluntary, but we need suitable contact details to reply. The main website does not create a separate enquiry database. Processing necessary to prepare or perform a contract with you is based on those contractual steps. Other business correspondence is based on our legitimate interest in responding to enquiries and managing cooperation.
• Newsletter. With your consent, we use your email address and subscription-related information to send our Estonian newsletter and manage the subscription in Smaily. You can unsubscribe using the link in any newsletter or by contacting us. Smaily provides statistics on newsletter opens and link clicks to help us assess readership and the relevance of our content. This information may be linked to the recipient’s email address.
• Website analytics. With your consent, we use Google Analytics to understand and improve website use. Information may include pages viewed, referral sources, visit times, and browser and device information. We do not add email addresses or form contents to measurement data.
• Technical operation and abuse prevention. Web server logs may contain the IP address, request time and address, response details, and browser and referring-page information. To limit abuse of the newsletter form, we use a keyed identifier derived from the IP address and a request count. This processing is based on our legitimate interest in keeping the website secure, operational and protected against automated spam.

3. Cookies and privacy choices

The site uses a language-preference cookie and browser storage to remember privacy choices. Analytics code loads only after you allow analytics. Rejecting analytics does not prevent you from viewing projects, playing videos or using contact links.

• Language preference: pll_language remembers the selected language. The lifetime is up to one year.
• Privacy choice: imagine_site_consent_v1 stores your choice in this browser’s local storage for up to 180 days.
• Analytics: Google Analytics uses _ga and _ga_* cookies to distinguish visits. Their validity is up to 180 days from their most recent use. They are enabled only with consent.

You can change your choice or withdraw analytics consent using “Cookie settings” in the footer. Withdrawal stops future measurement; it does not automatically erase data already collected. You can also remove existing cookies through your browser settings.

4. Service providers and disclosures

We use Zone for hosting and email, Smaily (Sendsmaily OÜ) for newsletter management, and Google Analytics for consent-based analytics. Providers receive the information needed for their respective tasks and process it on our behalf under their data processing terms.

Google Analytics may involve processing outside the European Economic Area, including the US. For relevant transfers to the US, Google relies on the EU–US Data Privacy Framework and, where applicable, European Commission standard contractual clauses. More information and a description of the safeguards are available in Google’s international data transfer terms.

Service providers may use subprocessors to provide their services. Details about Smaily’s processing and providers are available in its privacy notice and subprocessor list. Further information about hosting and email is available in Zone’s privacy policy.

Social media and other external links take you to services with their own privacy notices. Project videos are served as our own website media files.

5. Retention

Your newsletter subscription continues until you unsubscribe. Unsubscribing stops newsletter delivery; we retain the necessary unsubscribe record to prevent further emails to that address.

Unsubscribing does not automatically erase previous campaign delivery, open and click history in Smaily. This information remains until it is deleted or anonymised. We may retain aggregate statistics that cannot be linked to an individual over the long term to compare newsletter results across different periods.

We retain correspondence as needed to respond to enquiries and handle subsequent business matters. We normally delete messages that are no longer needed after three months. Necessary correspondence may be kept longer depending on the business need. Deleted messages may remain in Zone’s email backups for up to 14 days.

• Google Analytics: event data is retained for 2 months and user data for 14 months. New user activity resets the user-data retention period. Data in aggregate reports may be retained longer. These periods are separate from the cookie lifetimes described above.
• Web server logs: in addition to the current log, hosting retains compressed logs for up to the previous four days. Up to three months of log history may be available through Zone support.
• Newsletter request limit: the count remains valid for one hour after the latest counted attempt; expired technical records are removed during regular cleanup.

6. Your rights

You can request information about how your data is used, access your information, and ask for inaccuracies to be corrected. Where the legal conditions apply, you can request erasure, restriction or portability, and object to processing.

You can withdraw consent at any time without affecting the lawfulness of earlier processing. To exercise your rights, contact imagine@imagine.ee. We may request information needed to confirm your identity. We respond without undue delay, normally within one month, and notify you of any extension permitted by law.

You can lodge a complaint with the Estonian Data Protection Inspectorate if you believe your rights have been infringed.

7. Updates to this notice

We update this notice when website features or data use change. The current version and revision date will be available on this page.