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Privacy Policy

Real Thing Marketing, RTM, operated by TheRTMAgency OÜ

Last Updated On 14-Apr-2026
Effective Date 14-Apr-2026

1. Who we are

Real Thing Marketing (RTM) is a trading name of TheRTMAgency OÜ, a company registered in Estonia (Registrikood 17200648, VAT EE102843932) with its registered office at Sepapaja 6, 15551 Tallinn, Estonia ("we", "us", "our"). We are the controller of the personal data described in this Policy, unless we are processing it on behalf of a client, in which case our client is the controller and we act as the processor under a separate Data Processing Agreement.

2. Scope of this Policy

This Policy explains how we collect and use personal data when you visit our website (realthingmarketing.com), contact us, engage us as a service provider, or are introduced to us by a prospect or partner. If we process personal data on behalf of a client in the course of delivering services to that client, the client's privacy notices and our Data Processing Agreement with the client govern that processing.

3. What we collect and why

3.1 Website visitors

When you visit our website we may collect: the information your browser sends by default (IP address, user-agent, referring URL, pages viewed), privacy-friendly analytics events (pages viewed, approximate location at country level, device type), and — only with your consent where consent is required by law — additional analytics and advertising identifiers. We use this information to operate the site, understand how it is used, and improve our content.

3.2 Prospects and enquirers

If you contact us by form, email, LinkedIn, calendar-booking or other channel, we collect your name, business email, company, role, the information you give us about your enquiry, and any follow-up correspondence. We use this to respond, to evaluate whether we can help, and — where we have your consent or a legitimate interest — to send occasional business-to-business marketing communications that you can unsubscribe from at any time.

3.3 Clients and client contacts

In delivering services to clients, we process limited personal data about the client's employees and agents who interact with us: name, business email, job title, Slack/Notion/HubSpot identifiers, and the content of correspondence. We use this to deliver the engagement, account for our time and outputs, and comply with our legal and contractual obligations.

3.4 Suppliers and contractors

We process limited personal data about our suppliers and contractors (name, business contact details, identity/right-to-work documentation, bank details for payment, tax identifiers) to engage them and to meet our legal obligations.

3.5 Personal data we process on behalf of clients

In delivering SEO, content, AI visibility, analytics, web-development, UX and related services, we may be given access to personal data that belongs to the client — for example, end-user data in the client's Google Search Console, Google Analytics 4, CMS backend, HubSpot or equivalent. For that data we act as the client's processor under a written Data Processing Agreement. This Policy is not our legal basis for processing that data; the client's own privacy notice is.

4. Legal bases (GDPR)

Where the EU General Data Protection Regulation applies to our processing, we rely on the following legal bases:

  • Performance of a contract — to deliver services to clients and to manage our relationships with suppliers and contractors.
  • Legitimate interests — to respond to enquiries, to run our business (including business-to-business direct marketing to organisations that have expressed an interest), and to maintain and secure our systems. We balance these interests against your rights and you may object at any time.
  • Consent — for non-essential cookies and similar technologies on our website where consent is required, for marketing communications to individuals where consent is the correct basis, and for other specific purposes where we ask for it. Consent can be withdrawn at any time.
  • Legal obligation — to meet accounting, tax, anti-money-laundering, sanctions-compliance and employment-law obligations.

5. Cookies and similar technologies

Our website uses a small number of strictly necessary technologies to function. Where additional analytics or marketing technologies are enabled we ask for your consent on first visit and you can change your choices at any time through the cookie-preferences control on the site. A current list of the technologies we use, their purpose and retention is available on our cookie information page.

6. Sharing and sub-processors

We share personal data with carefully selected service providers that help us run the business: email and productivity (Google Workspace), documentation and project tracking (Notion), CRM and marketing (HubSpot, where engaged), messaging (Slack), credential management (1Password), code and infrastructure (GitHub), accounting and invoicing providers, calendar and scheduling, analytics and website platform providers, and payment processors. These providers act as our processors or as independent controllers for limited narrow purposes (e.g., payment processors). A current sub-processor register for client-delivery purposes is available on request.

We do not sell personal data. We may disclose personal data where required by law, in response to lawful requests from public authorities, to protect our rights, or in connection with a restructuring or transfer of our business (in which case we will take steps to ensure your personal data remains protected).

7. International transfers

Some of our providers are based outside the European Economic Area. Where personal data is transferred to a country that has not been found to provide an adequate level of protection, we rely on the European Commission's Standard Contractual Clauses, the EU-US Data Privacy Framework where the recipient is certified, or other lawful transfer mechanism. Copies of the relevant safeguards are available on request.

8. Retention

We keep personal data only as long as we need it for the purposes for which it was collected, or as required by law. In practice: enquiry correspondence is typically retained for up to 24 months from the last contact; client-delivery records are retained for the duration of the engagement and for a reasonable tail period (normally up to 6 years) to meet accounting and professional-liability obligations; marketing records are retained until you unsubscribe plus a short suppression period so we can honour your preference.

9. Your rights

If the GDPR or a similar law applies to our processing of your personal data, you have the right to:

  • access the personal data we hold about you and receive a copy;
  • request correction of inaccurate or incomplete data;
  • request deletion of your data in certain circumstances;
  • request restriction of, or object to, our processing in certain circumstances;
  • receive your data in a portable format where the processing is based on consent or contract and is carried out by automated means;
  • withdraw consent at any time where we rely on consent;
  • complain to a supervisory authority — our lead authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee).

To exercise any right, email us at george@realthingmarketing.com and we will respond within one month. We may ask for information to verify your identity.

10. Security

We protect personal data with the measures described in our Information Security Policy and supporting policies: unique accounts with multi-factor authentication, least-privilege access, credential management in 1Password, endpoint hardening, secure sub-processors, and documented incident handling. No system is completely secure; we will notify you without undue delay if a personal data breach affecting you occurs and the law requires us to do so.

11. Children

Our services are aimed at businesses. We do not knowingly collect personal data from children. If you believe we have collected data from a child, contact us and we will delete it.

12. Changes to this Policy

We may update this Policy from time to time to reflect changes to our services or to the law. The "Effective date" at the top of this document records the last update; where the change is material we will also notify you directly or prominently on our website.

13. Contact

Questions, requests and complaints: george@realthingmarketing.com. Postal address: TheRTMAgency OÜ, Sepapaja 6, 15551 Tallinn, Estonia.