Effective date: July 1st 2026
Privacy Policy
1. Who We Are
SpotPriceDesk is a commodity price intelligence service operated by BSKY OÜ, a company registered in Estonia (registration number 16378930) at Viru väljak 2, 3rd floor, 10111 Tallinn, Estonia.
BSKY OÜ is the data controller for all personal data collected through the SpotPriceDesk website at spotpricedesk.com and related services. This means we decide how and why your data is used, and we are responsible for keeping it safe.
For all data protection matters, including requests to access, correct, or delete your personal data, contact us at:
Email: info@spotpricedesk.com
Post: BSKY OÜ, Viru väljak 2, 3rd floor, 10111 Tallinn, Estonia
We are registered in the EU and are subject directly to the General Data Protection Regulation (GDPR). Our lead supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn. Visit www.aki.ee.
2. What Data We Collect and Why
We collect personal data only when you actively provide it to us. Here is what we collect at each point, and why.
Trial Signup
When you start a free trial we collect your full name, business email address, company name, and country. Phone number and commodities of interest are optional. We use this data to configure your indicators and deliver the service. The lawful basis is performance of a contract (Article 6(1)(b) GDPR). You are initiating a service and we need these details to provide it.
Contact Form
When you send us a message we collect your full name, email address, inquiry category, and message content. We use this to respond to your inquiry. The lawful basis is legitimate interests (Article 6(1)(f) GDPR). We have a legitimate interest in responding to business inquiries directed to us.
Marketing Opt-In
If you tick the optional marketing checkbox on the Contact form, we use your name and email address to send you market reports, offers, and news. The lawful basis is consent (Article 6(1)(a) GDPR). The checkbox is unticked by default. You can withdraw consent at any time by clicking unsubscribe in any email.
Advertising Pixels
If you accept marketing cookies, our advertising pixels collect pages visited, events triggered, approximate location, device type, and (where you have consented) hashed email for custom audience matching. The lawful basis is consent (Article 6(1)(a) GDPR). These pixels are only activated after you accept marketing cookies via our cookie banner.
Website Analytics
If you accept analytics cookies, Google Analytics collects anonymised usage data including pages visited, session duration, approximate location at country and city level, and device type. The lawful basis is consent (Article 6(1)(a) GDPR). Analytics tracking is only activated after you give consent via our cookie banner.
3. How We Use Your Data
We use personal data only for the purposes described at the point of collection:
- Service delivery: to configure your commodity price indicators, prepare your daily briefings, and send them to you by email (or WhatsApp, if you have selected that add-on).
- Trial management: to set up your 7-day free trial, communicate during onboarding, and manage your account if you become a paying subscriber.
- Invoicing: to issue subscription invoices by email. We do not process payments online, and no payment card or bank account data passes through our systems.
- Responding to inquiries: to reply to messages sent via the Contact form.
- Marketing communications: to send market reports, offers, and news to subscribers who have explicitly opted in. You can unsubscribe at any time using the link in any email.
- Advertising: to measure the performance of our paid campaigns on Meta, Google, and LinkedIn, and to build audiences for those campaigns. This only happens when you have consented to marketing cookies.
- Website analytics: to understand how visitors use our website and improve it. Only when you have consented to analytics cookies.
We do not use your data for automated decision-making or profiling. Commodities of interest selected at signup are used only to configure your service and are never used for advertising retargeting.
4. Cookies and Tracking
When you first visit SpotPriceDesk, a cookie consent banner managed by Cookiebot will ask for your preferences. You can accept all cookies, reject non-essential cookies, or adjust your choices at any time by clicking “Cookie settings” in the website footer.
We use three categories of cookies:
Strictly Necessary
These cookies are required for the Cookiebot consent banner to function. They remember your cookie preferences. No consent is needed for these.
Analytics
Google Analytics 4, operating under Consent Mode v2. Only activated if you accept analytics cookies. Collects anonymised data on pages visited, session duration, and approximate location. Requires your consent.
Marketing and Advertising
Meta Pixel (Facebook and Instagram Ads), Google Ads conversion tag, and LinkedIn Insight Tag. Only activated if you accept marketing cookies. Used for conversion measurement, ad performance reporting, and building lookalike or retargeting audiences on those platforms. Managed via Cookiebot Consent Mode v2 (ad_storage signal). Requires your consent.
To manage or withdraw your cookie consent, click “Cookie settings” in the footer of any page. You may also manage cookies directly through your browser settings at any time.
5. Who We Share Your Data With
We do not sell, rent, or trade your personal data. We share it only with the following service providers, and only to the extent necessary for each purpose.
GoDaddy
Website hosting. GoDaddy hosts the SpotPriceDesk website and processes server logs and form submission data that passes through their infrastructure. Based in the USA; transfers protected by Standard Contractual Clauses (SCCs).
Google LLC (Analytics and Advertising)
Google Analytics 4 processes anonymised website usage data when you consent to analytics cookies. The Google Ads conversion tag processes advertising performance data when you consent to marketing cookies. IP anonymisation is enabled. Based in the USA; transfers protected by SCCs and the EU–US Data Privacy Framework.
Usercentrics A/S (Cookiebot)
Cookie consent management. Cookiebot stores your cookie preferences and manages the Consent Mode v2 signals that gate analytics and advertising cookies. Based in Denmark, EU — no international transfer required.
Meta Platforms
Advertising and WhatsApp. The Meta Pixel processes website visitor data for Facebook and Instagram ad conversion measurement and audience targeting, when you consent to marketing cookies. Meta also processes phone numbers and names for subscribers who have selected the WhatsApp Business delivery add-on. Based in the USA; transfers protected by SCCs.
LinkedIn Ireland Unlimited Company
LinkedIn Ads. The LinkedIn Insight Tag measures ad conversions and supports audience targeting for LinkedIn Ads campaigns, when you consent to marketing cookies. LinkedIn’s EU entity is based in Dublin, Ireland — no international transfer is required.
6. International Data Transfers
BSKY OÜ is based in Estonia, EU. Where sub-processors are located outside the EU/EEA (GoDaddy, Google, Meta), data transfers are protected by Standard Contractual Clauses (SCCs) approved by the European Commission, or by an adequacy decision such as the EU–US Data Privacy Framework. LinkedIn’s EU entity is based in Ireland and requires no transfer mechanism.
You can request a copy of the applicable transfer safeguards by contacting us at info@spotpricedesk.com.
7. How Long We Keep Your Data
We keep your data only for as long as is necessary for the purpose it was collected, or as required by law.
Trial and Subscriber Account Data
For the duration of the customer relationship, plus 6 months after cancellation or the end of the last paid period.
Contact Form Inquiries (Non-Converting)
12 months from the date of the inquiry, or until you ask us to delete it, whichever comes first.
Marketing Opt-In Records (Non-Converting)
Until you unsubscribe, or 24 months of inactivity (no opens or clicks), whichever comes first.
Invoice and Billing Records
7 years from the invoice date, as required by Estonian accounting law (Raamatupidamise seadus).
Analytics Data (Google Analytics)
14 months, the default Google Analytics retention setting. Data is anonymised and aggregated.
Cookie Consent Records (Cookiebot)
12 months from the date of your consent, after which the cookie banner will reappear to refresh your preferences.
8. Your Rights
Under GDPR, you have the following rights in relation to your personal data. To exercise any of them, email us at info@spotpricedesk.com. We will respond within 30 days.
Right of Access
Request a copy of the personal data we hold about you.
Right to Rectification
Ask us to correct inaccurate or incomplete data.
Right to Erasure
Ask us to delete your data. Note: we may need to retain certain records for legal or contractual reasons (see Section 7).
Right to Restrict Processing
Ask us to pause processing your data in certain circumstances, for example while a dispute is being resolved.
Right to Data Portability
Receive your data in a structured, machine-readable format and transfer it to another provider.
Right to Object
Object to processing based on legitimate interests. We will stop unless we can demonstrate compelling grounds that override your interests.
Right to Withdraw Consent
Where processing is based on consent (marketing emails, analytics cookies, or advertising cookies) you may withdraw at any time. Withdrawal does not affect any processing carried out before withdrawal.
Right to Lodge a Complaint
You have the right to complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at www.aki.ee, or to the supervisory authority in your country of residence.
9. Data Security
We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse. These include secure hosting via GoDaddy, HTTPS encryption on all pages, and restricting access to personal data to those who need it to deliver the service.
In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify the Estonian Data Protection Inspectorate within 72 hours and inform affected individuals without undue delay, as required by GDPR Articles 33 and 34.
10. Children
SpotPriceDesk is a professional B2B service intended for use by businesses and business professionals. We do not knowingly collect data from individuals under the age of 18. If you believe a minor has submitted data to us, please contact us at info@spotpricedesk.com and we will delete it promptly.
11. Changes to This Policy
We may update this privacy policy from time to time to reflect changes in our services, legal requirements, or data practices. When we make material changes, we will update the effective date at the top of this page and, where appropriate, notify active subscribers by email. We encourage you to review this page periodically.
12. Contact Us
For any questions about this privacy policy, to exercise your data rights, or to request a copy of the Standard Contractual Clauses we rely on, please contact:
BSKY OÜ
Viru väljak 2, 3rd floor
10111 Tallinn, Estonia
Email: info@spotpricedesk.com