LEGAL / PRIVACY

Privacy Policy

This Privacy Policy explains how CG Investments OÜ, trading as Silver Peanut, collects and uses personal data when you visit silverpeanut.com, request an Automation Audit, book a call or correspond with us.

Last updated: 29 September 2026

1. Who is responsible for your data

The controller of your personal data is CG Investments OÜ, registry code 16500041, Parda tn 6, 10151 Tallinn, Estonia ("Silver Peanut", "we", "us"). For any privacy question or request, contact us at hello@silverpeanut.com.

This policy does not cover personal data we process on behalf of clients while delivering our services, such as contacts held in a client's CRM. There we act as a processor under a data processing agreement, and the client's own privacy notice applies.

2. What personal data we collect

Category
Contact and professional details
What it includes
Full name, email address, job title, company name, company website
Where it comes from
You, via the Automation Audit form or email
Category
Business qualification details
What it includes
Annual revenue, number of employees, marketing and sales team sizes, annual marketing department costs, annual performance marketing spend, main challenge, technology stack, growth objective
Where it comes from
You, via the Automation Audit form
Category
Booking details
What it includes
Chosen date and time, time zone, meeting link, attendance, rescheduling or cancellation
Where it comes from
You, via our calendar booking tool
Category
Communications
What it includes
Emails and messages exchanged with us, notes taken during calls
Where it comes from
You and our team
Category
Technical and usage data
What it includes
IP address, browser and device type, pages viewed, referring source, cookie identifiers, approximate location derived from your IP address
Where it comes from
Your device, via cookies and similar technologies (section 9)
Category
Publicly available professional information
What it includes
Your role, company and professional profile, for example from your company website or LinkedIn
Where it comes from
Public sources, or a person who referred you to us

Business qualification details mainly describe your company. They are personal data only where they can be linked to you, for example because they sit alongside your name.

Fields marked as required on the form are needed to assess your enquiry and schedule the call. Without them, we may not be able to book an Automation Audit. Please do not send us special categories of personal data, such as health data.

We do not record calls unless we tell you in advance and, where required, obtain your consent.

3. Why we use your data and our legal basis

Purpose
Responding to your enquiry, assessing fit, and scheduling and conducting the Automation Audit
Legal basis under the GDPR
Legitimate interests (Art. 6(1)(f)) in handling business enquiries; where you act in your own name, steps taken at your request before entering into a contract (Art. 6(1)(b))
Purpose
Sending booking confirmations, reminders and other messages about your enquiry
Legal basis under the GDPR
Legitimate interests (Art. 6(1)(f)); Art. 6(1)(b) where applicable
Purpose
Preparing proposals and entering into and performing a services agreement
Legal basis under the GDPR
Contract or pre-contractual steps (Art. 6(1)(b)); legitimate interests (Art. 6(1)(f)) where the contract is with your company
Purpose
Following up and sending occasional updates about our services
Legal basis under the GDPR
Legitimate interests (Art. 6(1)(f)) in business-to-business marketing, or consent (Art. 6(1)(a)) where the law requires it
Purpose
Contacting business decision-makers identified from public sources about our services
Legal basis under the GDPR
Legitimate interests (Art. 6(1)(f))
Purpose
Keeping business records in our CRM
Legal basis under the GDPR
Legitimate interests (Art. 6(1)(f))
Purpose
Operating, securing and improving the Website
Legal basis under the GDPR
Legitimate interests (Art. 6(1)(f))
Purpose
Analytics and measuring advertising performance with non-essential cookies
Legal basis under the GDPR
Consent (Art. 6(1)(a))
Purpose
Complying with accounting, tax and other legal obligations
Legal basis under the GDPR
Legal obligation (Art. 6(1)(c))
Purpose
Establishing, exercising or defending legal claims
Legal basis under the GDPR
Legitimate interests (Art. 6(1)(f))

You can opt out of marketing and object to processing based on legitimate interests at any time (section 8). Where we rely on legitimate interests, we have balanced them against your rights, and you can ask us for details of that assessment.

4. Automated tools and AI

We may use automated tools, including AI, to organise, summarise and prioritise enquiries and to prepare for calls. A member of our team reviews every enquiry. We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing.

We use AI providers only as processors under contract, and we do not permit them to use your data to train their models.

5. Who we share your data with

We share personal data only as needed for the purposes above:

  • Service providers acting on our behalf under data processing agreements, including Cloudflare (website hosting, content delivery and security), Google (calendar booking via Google Calendar), Customer.io (email communications and contact management), and providers of analytics, video hosting and AI tools.
  • Our team and contractors working on Silver Peanut in Spain, the United States and Brazil, on a need-to-know basis and under confidentiality obligations.
  • Advertising and analytics partners, only where you have consented to the relevant cookies.
  • Professional advisers, such as lawyers, accountants and auditors, under confidentiality obligations.
  • Authorities, courts and regulators, where required by law or to protect our legal rights.
  • A buyer or successor, if our business or assets are reorganised, merged or sold.

We do not sell your personal data.

6. International transfers

Some of our team members work from the United States and Brazil, and some service providers are based outside the European Economic Area (EEA). When personal data is transferred outside the EEA, we rely on a European Commission adequacy decision, such as the EU–US Data Privacy Framework for certified US recipients, or on Standard Contractual Clauses with additional safeguards where needed.

You can request a copy of the relevant safeguards by contacting us.

7. How long we keep your data

Data
Enquiries and bookings that do not lead to an engagement
Retention period
Up to 24 months after our last contact
Data
Client and contract records
Retention period
For the engagement, then as required by law (generally 7 years for accounting records in Estonia)
Data
Marketing preferences
Retention period
Until you opt out; we then keep a minimal record so that we respect your opt-out
Data
Website analytics data
Retention period
Up to 14 months
Data
Server and security logs
Retention period
Up to 90 days

After these periods, we delete or anonymise your data.

8. Your rights

Under the GDPR you have the right to:

  • access the personal data we hold about you and receive a copy;
  • have inaccurate data corrected;
  • have your data erased in certain circumstances;
  • restrict our processing in certain circumstances;
  • receive data you gave us in a portable format;
  • object to processing based on our legitimate interests, and object at any time to direct marketing;
  • withdraw your consent at any time, without affecting processing that took place before withdrawal.

To exercise your rights, email hello@silverpeanut.com. We will reply within one month, which may be extended by two further months for complex requests. We may ask you to confirm your identity first. Every marketing email also includes an unsubscribe link.

You have the right to lodge a complaint with a supervisory authority. In Estonia, where we are registered, this is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari tn 39, 10134 Tallinn, info@aki.ee, www.aki.ee. You may also complain to the authority in the EU country where you live or work, such as the Spanish Data Protection Agency (AEPD).

9. Cookies and similar technologies

Strictly necessary cookies are set without consent because the Website cannot work properly without them. All other cookies are set only after you accept them in our cookie banner, which lists the individual cookies and providers in each category.

Type
Strictly necessary
Purpose
Security, remembering your cookie choices, running the booking form
Consent needed
No
Providers
Cloudflare and our consent management tool
Type
Analytics
Purpose
Understanding how visitors use the Website so we can improve it
Consent needed
Yes
Providers
As listed in our cookie banner
Type
Marketing and conversion tracking
Purpose
Measuring the performance of our advertising and showing relevant ads on other platforms
Consent needed
Yes
Providers
As listed in our cookie banner
Type
Embedded content
Purpose
Playing videos and showing the booking calendar within the Website
Consent needed
Yes, where the provider sets non-essential cookies
Providers
Google Calendar and our video hosting provider

You can change or withdraw your consent at any time via the Cookie settings link in the Website footer, or by clearing cookies in your browser.

10. Security

We use appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls and multi-factor authentication on our business systems. No method of transmission or storage is completely secure, but we review our measures regularly.

11. Additional information for Brazil and the United States

If you are in Brazil, you have rights under the Lei Geral de Proteção de Dados (LGPD). These include confirmation of processing, access, correction, anonymisation, blocking or deletion, portability, information about who we share data with, and withdrawal of consent. You can exercise them by contacting us, and you may complain to the Autoridade Nacional de Proteção de Dados (ANPD).

If you are in the United States, you may have rights under your state's privacy law. These can include accessing, correcting and deleting your personal information and opting out of targeted advertising. You can exercise them by contacting us, and we will not discriminate against you for doing so.

12. Children

The Website is intended for business professionals and is not directed at anyone under 18. We do not knowingly collect personal data from children.

13. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version on this page with a new "Last updated" date and, where changes are significant, notify you by email where appropriate.

14. Contact

CG Investments OÜ (Silver Peanut) · Parda tn 6, 10151 Tallinn, Estonia · Registry code 16500041 · hello@silverpeanut.com

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