Last updated: 2025 10 15

This Privacy Policy explains how SeaWave Marketing OÜ, operating under the brand Momentas, collects, uses and protects personal data in accordance with the EU General Data Protection Regulation (GDPR).

1. Data Controller

SeaWave Marketing OÜ
Registry code: 17091662
Address: Karamelli tn 2, 11317, Kesklinna linnaosa, Tallinn, Harju maakond, Estonia
Email: info@momentasbrand.com

2. Personal Data We Collect

We process personal data only for the purpose of providing our services. This may include:

2.1 Data You Provide to Us

• • Photographs of individuals for creating personalised colouring book illustrations

• • Name and email address (e.g. for ordering, communication, delivery)

• • Billing and shipping details when a purchase is made

2.2 Automatically Collected Data

When using our website, we may collect:

• • Cookies and similar technologies

• • IP address, browser type, device information, browsing activity on our website

3. Purpose and Legal Basis for Processing

Purpose of Processing	Legal Basis
Creating colouring book illustrations from photos	GDPR Art. 6(1)(b) – contract fulfilment / Art. 6(1)(a) – consent
Storing and deleting photos securely	GDPR Art. 6(1)(f) – legitimate interest in providing safe service
Order processing, communication and delivery	GDPR Art. 6(1)(b) – contract fulfilment
Payment transactions via Stripe	GDPR Art. 6(1)(b) – contract fulfilment
Website analytics & cookies	GDPR Art. 6(1)(a) – consent
Compliance with legal obligations (taxes, accounting)	GDPR Art. 6(1)(c) – legal obligation

We do not use photos for marketing or advertising without explicit written consent.

4. How We Handle Photographs

• • Photos are used only to create illustrations.

• • Photos are stored temporarily using secure tools (FTP, Gmail, Shopify file system).

• • Once the illustration is completed and delivered, all original images are permanently deleted.

• • We do not sell, share or reuse customer photos.

• • Illustrations may be stored securely for re-delivery purposes, unless you request deletion.

5. Data Retention Periods

Data Type	Retention Time
Original photos	Deleted immediately after illustration is completed and delivered
Final illustration files	Stored securely unless you request deletion
Order, billing and communication data	Up to 7 years (as required by Estonian accounting law)
Cookies and analytics data	According to cookie settings and browser preferences

6. Data Sharing and Processors

We only share data with third parties when necessary for service provision and only with GDPR-compliant processors:

Service	Provider	Purpose
Website & hosting	Shopify	Website functionality and store management
Payment processing	Stripe	Secure payment transactions
Email services	Gmail (Google)	Communication with customers
File transfer/storage	FTP, Shopify system	Temporary storage of photos for illustration
Accounting & legal	Local service providers (if used)	Legal compliance, invoicing

We do not transfer personal data outside the European Economic Area (EEA).

7. Cookies

Our website uses cookies to:

• • Enable basic site functionality

• • Process orders and maintain a shopping cart

• • Analyse website traffic (if analytics tools are used)

You can disable cookies in your browser settings at any time. Some functions of the website may not work fully without cookies.

8. Your Rights Under GDPR

You have the right to:

• • Access your personal data

• • Request correction or deletion of your data

• • Withdraw consent at any time (for example, request deletion of your photos and illustrations)

• • Restrict or object to processing

• • Receive data in a machine-readable format (data portability)

• • Lodge a complaint with a supervisory authority

Supervisory authority in Estonia:
Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate)
Website: www.aki.ee
Email: info@aki.ee

9. Security Measures

We take appropriate technical and organisational measures to protect personal data, including:

• • Secure FTP and password-protected systems

• • Access limited to authorised personnel only

• • Immediate deletion of original photos after the service is completed

• • Encrypted payment processing via Stripe

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our website. Continued use of our services after changes means you accept the updated policy.

11. Contact Us

For questions about this policy or your personal data, contact us at:
📩 info@momentasbrand.com