Last updated: August 23, 2026
This Privacy Policy describes how Clockwork Media OÜ (“we”, “us”, or “our”) collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from ducerr.pro, xmp.pro, or vikingram.com (the “Site”) or otherwise communicate with us regarding the Site (collectively, the (“Services”). For purposes of this Privacy Policy, “you” and “your” means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.
Please read this Privacy Policy carefully.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the “Last updated” date and take any other steps required by applicable law.
How We Collect and Use Your Personal Information
To provide the Services, we collect personal information about you from a variety of sources, as set out below. The information that we collect and use varies depending on how you interact with us.
In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide or improve the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.
What Personal Information We Collect
The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term “personal information”, we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.
Information We Collect Directly from You
Information that you directly submit to us through our Services may include:
Contact details including your name, address, phone number, and email.
Order information including your name, billing address, shipping address, payment confirmation, email address, and phone number.
Account information including your username, password, security questions and other information used for account security purposes.
Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.
Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.
Information We Collect about Your Usage
We may also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, pixels and similar technologies (“Cookies”). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.
Some Usage Data is collected only if you consent to it. See Cookies and Analytics below.
Information We Obtain from Third Parties
Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:
Our payment provider Paddle, which collects payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfill your orders and provide you with products or services you have requested, in order to perform our contract with you.
Our analytics provider, where you have consented to analytics cookies. See Cookies and Analytics below.
Our email provider, which reports whether messages we sent you were delivered, opened, clicked or bounced.
When you visit our Site, we, or third parties we work with, may automatically collect certain information using cookies and similar technologies, as described under Cookies and Analytics and Advertising. When we send you email, our email provider records whether the message was opened and whether you clicked a link in it, using a tracking pixel and redirected links. We use this to confirm that important messages — such as sign-in links and booking confirmations — actually arrived, and to measure our marketing.
Any information we obtain from third parties will be treated in accordance with this Privacy Policy. Also see the section below, Third Party Websites and Links.
How We Use Your Personal Information
Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfill your orders, to send notifications to you related to your account, purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, facilitate any returns and exchanges and other features and functionalities related to your account.
Marketing. We may send you marketing and promotional communications by email, text message or postal mail. We send marketing email through Brevo, our email provider, to people who have asked to receive it — either by ticking the marketing option when creating an account or completing a purchase, or by subscribing through a form on our Site. If you are an EEA resident, the legal basis for direct marketing to our existing customers about our own similar products and services is our legitimate interest in promoting our business, according to Art. 6 (1) (f) GDPR; for all other marketing communications the legal basis is your consent, according to Art. 6 (1) (a) GDPR. You may opt out of marketing communications at any time using the unsubscribe link in any such message, and we record that choice.
Advertising. Where you consent to advertising cookies, we use your personal information to measure and improve our advertising. The legal basis is your consent, according to Art. 6 (1) (a) GDPR. See Advertising below for what this covers and who receives the data. Advertising cookies are never set unless you have switched them on.
Analytics. Where you consent to analytics cookies, we use your personal information to understand how the Services are used and to improve them. The legal basis is your consent, according to Art. 6 (1) (a) GDPR. See Cookies and Analytics below.
Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately. If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in keeping our website secure for you and other customers, according to Art. 6 (1) (f) GDPR.
Communicating with You and Service Improvement. We use your personal information to provide you with customer support and improve our Services. This is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you according to Art. 6 (1) (f) GDPR.
Cookies and Analytics
Like many websites, we use Cookies on our Site. For specific information about the Cookies that we use, see our Cookie Policy.
Cookies that are strictly necessary — including those that keep you signed in, remember your language and time zone, and record your cookie choice itself — are set without consent, because the Services cannot be provided without them. Everything else is off until you turn it on.
Analytics. We use Google Analytics 4, provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) and Google LLC, to understand which pages are used and how the Services perform. Analytics cookies are set only after you accept them, and analytics remains disabled if you decline or ignore the banner. The legal basis is your consent, according to Art. 6 (1) (a) GDPR.
We have switched Google Signals off and enabled ad-data redaction, so analytics data is not used to build advertising audiences. Google retains analytics data for 14 months. That figure describes analytics data only and is separate from how long we keep your account data, which is set out under Security and Retention of Your Information.
Google may process this data in the United States. Where it does, the transfer relies on the European Commission's Standard Contractual Clauses, as described under International Users.
Your choices. When you first visit the Site you are asked to choose. You can accept everything, reject everything, or open Customize and switch Analytics and Advertising on or off individually. You can change your choice at any time through Cookie settings, and withdrawing consent is as easy as giving it — the same control, the same number of clicks, with no penalty for saying no. Withdrawing consent does not affect the lawfulness of processing carried out before you withdrew it.
You can also set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Browser controls are a blunt instrument and are not a substitute for the choice above.
Advertising
As of the “Last updated” date above, we do not set any advertising cookies and no advertising pixel is active on the Site. This section describes what happens if and when you switch the Advertising category on.
Where you consent to advertising cookies, we and the following providers may set cookies or similar identifiers to measure and improve our advertising:
Google Ads — Google Ireland Limited and Google LLC
Meta — Meta Platforms Ireland Limited (Facebook, Instagram and Threads)
Reddit — Reddit, Inc. and Reddit Ireland Limited
TikTok — TikTok Information Technologies UK Limited and TikTok Technology Limited
These providers may combine the information they receive from the Site with information they already hold about you, and may act as independent controllers for their own purposes. Their handling of your data is governed by their own privacy notices.
The Advertising category is denied by default. It is granted only by you switching it on, and switching it off again stops any further collection. We do not set advertising cookies for visitors who reject, ignore the banner, or leave the category off.
Depending on where you live, disclosure of information to advertising providers of this kind may be treated as a “sale” or “share” of personal information, or as processing for “targeted advertising”, under applicable privacy laws. Where those laws apply to you, your Advertising choice is also your opt-out for those purposes. See Your Rights.
We do not sell your personal information to data brokers, and we do not use the data described under Connected social accounts for advertising.
How We Disclose Personal Information
In certain circumstances, we may disclose your personal information to third parties for contract fulfillment purposes, legitimate purposes and other reasons subject to this Privacy Policy. Such circumstances may include:
With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, analytics, customer support, cloud storage, fulfillment and shipping).
With Paddle.com Market Ltd, our payment provider and the Merchant of Record for the digital products and subscriptions sold here, which handles payment and tax on our behalf. Paddle receives the details needed to take payment and to meet its own legal obligations, and handles that data under its own privacy notice.
With advertising providers, where you have consented to advertising cookies, as set out under Advertising.
With our email provider, Brevo, which sends transactional and marketing email on our behalf, manages our mailing lists, and reports delivery, opens, clicks and bounces back to us. If you subscribe to a mailing list through a form on our Site, your details are submitted to Brevo for that purpose.
When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations, with your consent.
With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.
In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.
We disclose the following categories of personal information about users for the purposes set out above in “How we Collect and Use your Personal Information” and “How we Disclose Personal Information”:
CategoryIdentifiers such as basic contact details and certain order and account information
Commercial information such as order information, shopping information and customer support information
Internet or other similar network activity, such as Usage Data
Geolocation data such as locations determined by an IP address or other technical measures
Categories of RecipientsVendors and third parties who perform services on our behalf (such as Internet service providers, payment processors (Paddle), our email provider, fulfillment partners and customer support partners)
Our analytics provider, and advertising providers, in each case only where you have consented
Affiliates
We do not use or disclose sensitive personal information without your consent or for the purposes of inferring characteristics about you.
With your consent we share personal information for the purpose of engaging in advertising and marketing activities, as set out under Advertising above.
Connected social accounts
Ducerr lets you connect your own YouTube, TikTok or Instagram account. Connecting is
optional, is always started by you, and can be undone at any time in Account settings.
What we receive
When you connect an account, the platform shows you its own authorization screen listing
the permissions we ask for. If you approve, the platform issues us an access token, and we
use it to read only the following:
- TikTok (scopes user.info.profile, user.info.stats, video.list): your open ID,
display name, username (@handle), avatar and profile link; your follower count, following
count, total likes and video count; and, for posts you published yourself, the post ID,
title or description, cover image, duration, publish time, share URL, and view, like,
comment and share counts.
- Instagram (Instagram Graph API, Business and Creator accounts): your account ID,
username, avatar and profile link; your follower and media counts; and, for media you
published yourself, the media ID, caption, thumbnail, permalink, publish time and its
insights metrics.
- YouTube (YouTube API Services): your channel ID, title, avatar, and public channel and
video statistics.
We never receive your password. We do not read your private messages or drafts, and we
receive nothing from accounts you have not connected yourself.
How we use it
- We show your connected account, its handle and its public counts on your Ducerr profile,
so other members can see the track record behind advice they give and receive.
- We record those public counts over time so you can see your own growth and measure the
goals you set.
- Our access is read-only. We never post, comment, message, follow, or make any other change
on your behalf.
- We do not use this data for advertising, and we do not sell, rent or trade it. We share it
only with the infrastructure providers that host Ducerr on our behalf, and where the law
requires it.
Storage and retention
Access and refresh tokens are stored encrypted and are used only to refresh the data
described above. We keep collected statistics for as long as the account stays connected,
because their value is the history itself.
Disconnecting and deletion
You can disconnect a platform at any time in Account settings. Disconnecting immediately
deletes the stored tokens and stops all further collection. To delete the collected history
as well, or your Ducerr account entirely, use Account settings or write to
[email protected]; we action such requests within 30 days.
You can also revoke our access from the platform itself, which stops collection just as
disconnecting does: TikTok (Settings and privacy > Security and permissions > Manage app
permissions), Instagram (Settings > Apps and websites), Google (myaccount.google.com/permissions).
Our use of TikTok data complies with the TikTok Developer Terms of Service; our use of
Instagram data complies with the Meta Platform Terms; and our use of YouTube data complies
with the YouTube Terms of Service (https://www.youtube.com/t/terms) and the Google Privacy
Policy (https://policies.google.com/privacy).
Third Party Websites and Links
Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.
Children's Data
The Services are not intended to be used by children under 16 years of age, and we do not knowingly collect any personal information about children under 16. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.
As of the “Last updated” date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 16 years of age.
Security and Retention of Your Information
Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.
How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies. As a general rule:
We retain conversations and personal information for 6 years while your account remains open.
If you delete your account, we dispose of the associated data in accordance with our Terms of Service and this Privacy Policy, and in any event within 60 days, except where we are required to keep specific records for longer by law.
Analytics data held by Google is retained for 14 months, as described under Cookies and Analytics.
Support correspondence is the exception to the six-year period above. We keep the messages you send us through our contact form, by email, and through our Telegram support bot — including any files or images sent with them — for as long as your relationship with us continues. We do this so that whoever answers you can see what you have already been through: a member who had a serious problem two years ago is still the same member, and asking them to explain it again from the beginning is worse support. You can ask us to erase this correspondence at any time under Art. 17 GDPR, using the contact details below, and if you close your account it is disposed of on the same 60-day basis as everything else.
Your Rights
Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.
Right to Access / Know: You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.
Right to Delete: You may have a right to request that we delete personal information we maintain about you.
Right to Correct: You may have a right to request that we correct inaccurate personal information we maintain about you.
Right of Portability: You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
Right to Opt out of Sale or Sharing or Targeted Advertising: You may have a right to direct us not to “sell” or “share” your personal information or to opt out of the processing of your personal information for purposes considered to be “targeted advertising”, as defined in applicable privacy laws. You can exercise this by leaving the Advertising category switched off, or switching it off later, in Cookie settings. Please note that if you visit our Site with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will automatically treat this as a request to opt-out of the “sale” or “sharing” of information for the device and browser that you use to visit the Site.
Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information.
Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent. For cookies, use Cookie settings; withdrawing is as easy as giving consent.
Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.
Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.
You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below. We handle these requests manually; there is no automated export or deletion flow, and we will respond within the time required by applicable law.
We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.
Complaints
If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority. As we are established in Estonia, our lead supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon). For the EEA, you can find a list of the responsible data protection supervisory authorities here.
International Users
Please note that we may transfer, store and process your personal information outside the country you live in. Your personal information is also processed by staff and third party service providers and partners in these countries.
If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.
This applies in particular to Google, which may process analytics and advertising data in the United States under those Standard Contractual Clauses. We accepted Google's Ads Data Processing Terms on 14 May 2018, and Google Ireland Limited is the entity contracting with us for the EEA.
Contact
Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please email us at [email protected], or write to us at:
Clockwork Media OÜ
Reg. nr. 14476172
Sepapaja 6
Tallinn 15551
Estonia
For privacy-specific requests you can also write to [email protected]. For data-protection and legal matters, including requests concerning this Privacy Policy, write to [email protected].
For the purpose of applicable data protection laws and if not explicitly stated otherwise, Clockwork Media OÜ is the data controller of your personal information.