PRIVACY POLICY
Personal Data Processing Policy

 

Privacy Policy

Last updated: 30 July 2026

1. Introduction

This Privacy Policy explains how personal data is collected, used, stored and protected when you visit or interact with phonitura.com (the “Website”).

For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the operator of the Website is the data controller (“we”, “us” or the “Controller”). The identity and current contact details of the Controller are available on the Website’s Contact Us page.

This Privacy Policy is provided for transparency purposes. It does not itself constitute consent to the processing of personal data. Where consent is required, it will be requested separately through a clear affirmative action.

2. Personal Data We Collect

We may collect the following personal data when you submit an enquiry or use a contact form on the Website:

  • first name and last name;
  • telephone number;
  • email address;
  • company name and job title, where provided;
  • information contained in your enquiry, including the products, services or acoustic solutions in which you are interested;
  • city, country or region, where required to assess delivery or service availability; and
  • any other information you choose to provide.

We may also collect certain technical and usage data, subject to your cookie preferences and applicable law:

  • IP address;
  • cookie identifiers and consent preferences;
  • browser, operating system and device information;
  • pages visited and interactions with the Website;
  • date and time of visits; and
  • referring website or traffic source.

3. Purposes of Processing

We process personal data for the following purposes:

  • to receive, review and respond to enquiries;
  • to provide information and consultations regarding our products and services;
  • to prepare product selections, acoustic recommendations, quotations and other requested materials;
  • to communicate with you regarding an enquiry, order, contract or service;
  • to take steps at your request before entering into a contract and to perform a contract;
  • to organise delivery and provide customer support;
  • to maintain the security, availability and performance of the Website;
  • to improve the Website, our products and our customer service;
  • to measure Website usage and prepare aggregated statistics, where permitted by law and your cookie preferences;
  • to establish, exercise or defend legal claims; and
  • to comply with legal and regulatory obligations.

We do not send direct marketing communications by email or telephone unless we have a valid legal basis to do so. Where marketing is based on consent, you may withdraw that consent at any time.

4. Legal Bases for Processing

Depending on the circumstances, we rely on one or more of the following legal bases under Article 6 of the GDPR:

  • Consent: where you have freely given specific, informed and unambiguous consent, including for non-essential cookies or marketing communications where required;
  • Contract: where processing is necessary to take steps at your request before entering into a contract or to perform a contract with you;
  • Legal obligation: where processing is necessary to comply with a legal obligation applicable to us; and
  • Legitimate interests: where processing is necessary for our legitimate interests or those of a third party, provided that your interests, rights and freedoms do not override those interests. These interests may include responding to business enquiries, improving our services, maintaining Website security, preventing fraud and managing legal claims.

Where we rely on legitimate interests, you may request further information about the balancing assessment and may object to the processing in the circumstances described below.

5. Retention of Personal Data

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including to satisfy legal, accounting, tax, reporting and dispute-resolution requirements.

As a general rule, information submitted through enquiry forms may be retained for up to three years after the last meaningful interaction, unless a longer period is required by law, necessary for the performance of a contract or justified by the establishment, exercise or defence of legal claims.

When personal data is no longer required, it will be securely deleted or irreversibly anonymised. Retention periods for cookies and analytics data are described in the applicable cookie settings or Cookie Policy.

6. Recipients and Service Providers

We do not sell personal data.

We may disclose personal data only where necessary and lawful, including to:

  • hosting, IT, security, customer relationship management and website service providers;
  • professional advisers, including legal, accounting and audit providers;
  • delivery, logistics and other service partners involved in fulfilling your request or contract;
  • analytics providers, where you have given any consent required by law;
  • public authorities, courts or regulators where disclosure is required by law; and
  • another party in connection with a corporate transaction, subject to appropriate confidentiality and data protection safeguards.

Where a service provider processes personal data on our behalf, it is required to act only on documented instructions, maintain confidentiality and implement appropriate technical and organisational safeguards.

7. International Data Transfers

The Controller and some service providers may be located outside the European Economic Area (“EEA”). As a result, personal data may be transferred to and processed in countries that may not provide a level of data protection equivalent to that in the EEA.

Where the GDPR applies and personal data is transferred outside the EEA, we use an appropriate transfer mechanism where required, such as an adequacy decision, the European Commission’s Standard Contractual Clauses, or another lawful safeguard under Chapter V of the GDPR. Where necessary, supplementary technical and organisational measures are applied.

You may request information about the safeguards used for a relevant international transfer through the Contact Us page.

8. Data Security

We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures may include:

  • access controls based on business need;
  • encrypted transmission of data using HTTPS;
  • system and security updates;
  • backup and recovery procedures;
  • staff confidentiality obligations and data protection training; and
  • monitoring and review of relevant security controls.

No transmission or storage system can be guaranteed to be completely secure. We review and update our safeguards in light of the risks associated with the processing.

9. Cookies and Analytics

The Website may use cookies and similar technologies for the following purposes:

  • to provide functions that are strictly necessary for the operation and security of the Website;
  • to remember your choices and preferences;
  • to measure Website usage and performance; and
  • to improve the Website and user experience.

Strictly necessary cookies may be used without consent where permitted by law. Analytics, advertising and other non-essential cookies are not activated for visitors in the EEA until the visitor has provided valid consent through the cookie banner or preference centre.

Where enabled with your consent, the Website may use services such as Google Analytics or Yandex Metrica. These providers may process online identifiers, device information and usage data and may transfer data outside the EEA. Further details, including the cookies used, their duration and available controls, should be provided in the Website’s Cookie Policy or cookie preference centre.

You may accept, refuse or withdraw consent for non-essential cookies at any time through the cookie preference centre. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal. Browser settings may also be used to delete or block cookies, although some Website functions may then be unavailable.

10. Your Rights

Where the GDPR applies, you may have the following rights, subject to the conditions and limitations set out in applicable law:

  • Right of access: to obtain confirmation as to whether your personal data is processed and to receive a copy of that data;
  • Right to rectification: to have inaccurate or incomplete personal data corrected;
  • Right to erasure: to request deletion of personal data in certain circumstances;
  • Right to restriction: to request restriction of processing in certain circumstances;
  • Right to data portability: to receive personal data you provided in a structured, commonly used and machine-readable format and, where technically feasible, have it transmitted to another controller;
  • Right to object: to object to processing based on legitimate interests and to object at any time to processing for direct marketing;
  • Right to withdraw consent: to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal; and
  • Right to lodge a complaint: to lodge a complaint with the data protection supervisory authority in the EEA country where you live, work or believe an infringement occurred.

We do not currently make decisions based solely on automated processing that produce legal effects or similarly significant effects concerning Website users.

To exercise a data protection right, use the contact method provided on the Website’s Contact Us page. We may request information necessary to verify your identity and respond securely. We will respond without undue delay and normally within one month, subject to any extension permitted by Article 12 of the GDPR.

11. Consent

Where processing is based on consent, consent will be requested separately and will be freely given, specific, informed and unambiguous. You are not required to consent to optional processing in order to access the core content of the Website.

You may withdraw consent at any time using the same or an equally simple method as the one used to provide it, including through the cookie preference centre or the method described on the Contact Us page.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our processing activities, legal requirements or the operation of the Website.

The updated version will be published on this page with a revised “Last updated” date. Where required by law, we will provide additional notice or request renewed consent before a material change takes effect.

Continued use of the Website does not by itself constitute consent to any new processing activity for which consent is legally required.

13. Contact and Complaints

Questions about this Privacy Policy, requests to exercise data protection rights and enquiries about international transfer safeguards may be submitted through the Website’s Contact Us page.

You also have the right to contact the competent data protection supervisory authority in the EEA country where you live, work or believe that a breach of data protection law has occurred.