Privacy Policy

Last updated: 29 October 2026

This Privacy Policy explains how fraqmented OÜ ("fraqmented", "we", "us") collects, uses and protects personal data when you visit fraqmented.com, contact us, book a tour, attend our events, or use our coworking space at Pikk 7, Tallinn. We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and the Estonian Personal Data Protection Act.

1. Who is responsible for your data

The data controller is fraqmented OÜ, Pikk 7, 10123 Tallinn, Estonia. For any question about this policy or your personal data, contact us at connect@fraqmented.com or +372 5355 0574.

2. What data we collect

• Contact and enquiry details you send through our forms (contact, meeting room and event enquiries): your name, email address, phone number, company name, the topic you choose and your message.
• Newsletter sign-ups: your email address.
• Membership and booking data when you become a member, buy a day pass or book a room through our member portal (member.fraqmented.com): name, contact details, company and billing details, membership plan, bookings and payment history.
• Tour and event registrations made through our booking and event pages (Calendly and Luma): the details you enter there.
• Video recordings from security cameras in our premises.
• Technical data: when you visit our website, our hosting provider automatically processes your IP address and basic browser information to deliver the site and keep it secure.

Our website does not use analytics, advertising or tracking cookies.

3. Why we use your data and on what legal basis

• To answer your enquiries and arrange tours and bookings — to take steps at your request before entering into a contract, or our legitimate interest in responding to you (GDPR Art. 6(1)(b) and (f)).
• To provide memberships, room bookings and invoicing — performance of our contract with you (Art. 6(1)(b)) and our legal obligations, for example accounting (Art. 6(1)(c)).
• To send our newsletter — your consent (Art. 6(1)(a)). You can unsubscribe at any time.
• To keep our premises, members and property safe through video surveillance — our legitimate interest in security (Art. 6(1)(f)).
• To run and protect our website — our legitimate interest (Art. 6(1)(f)).

4. Who we share data with

We do not sell your personal data. We share it only with service providers who help us run our business and who process it on our behalf, under agreements that protect your data:

• our website hosting provider;
• the form service that delivers website form submissions to our email inbox;
• our email provider;
• our member management and booking system (member.fraqmented.com) and its payment processor;
• Calendly (tour bookings) and Luma (event registrations), which also have their own privacy policies;
• our accountant, and authorities where the law requires it.

Data is stored on secure external systems and on Company-managed systems hosted by Render. Some providers may process data outside the European Economic Area. In that case we rely on safeguards recognised by the GDPR, such as the European Commission's adequacy decisions or Standard Contractual Clauses.

5. How long we keep your data

• Enquiries and form submissions: as long as needed to handle your request, and no longer than 2 years after our last contact unless you become a member.
• Membership and booking data: for the duration of your membership and as long as needed afterwards to settle accounts and handle claims.
• Accounting records: 7 years, as required by the Estonian Accounting Act.
• Newsletter: until you unsubscribe.
• Video recordings: only as long as needed for security purposes, after which they are deleted automatically.

6. Your rights

You have the right to access your personal data, to have it corrected or deleted, to restrict or object to its processing, to data portability, and to withdraw your consent at any time (this does not affect processing that took place before). To use any of these rights, email connect@fraqmented.com. We will reply within one month.

If you believe we have not handled your data properly, you can lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee).

7. Security

We use appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access, and we limit access to the people who need it to do their work.

8. Changes to this policy

We may update this policy from time to time. The latest version is always available on this page, with the date it was last updated.