Privacy Policy

1Data controller

2What this policy covers

This website is informational. It has no contact forms, user accounts, newsletter, online payments or analytics, and does not collect personal data by itself.

This policy covers personal data you share when you:

• write to me by email or Telegram;
• book a session through Cal.com;
• work with me on a consultation or project.

3Personal data I may receive

• name and contact details, such as email address or Telegram username;
• booking details, such as the date and time you choose and your answers to booking questions;
• information about you or your business that you choose to share in messages or during sessions.

Please don't send information that isn't needed for the consultation, such as ID documents, card details or health data.

4Purposes and legal bases

A. To reply to your enquiry and agree on the work. Legal basis: steps taken at your request before a contract.

B. To provide consultations and projects. Legal basis: performance of a contract.

C. To meet legal, accounting and tax obligations. Legal basis: compliance with legal obligations.

I don't use your data for marketing or newsletters.

5Cookies

This website does not use analytics, advertising or tracking cookies. It only stores your language choice (RU or EN) in your browser so the site opens in the same language next time. This is strictly necessary for the site to work as you expect and does not require consent. You can clear it in your browser settings.

6Service providers

Personal data may be processed by the services used to run the website and to communicate with you:

• Cloudflare (website hosting and security; may process technical data such as IP address);
• Cal.com (session booking);
• Proton Mail (email);
• Telegram (messaging, if you choose to contact me there).

Each provider handles data under its own privacy policy. I do not sell your personal data or share it for advertising.

7International transfers

Some providers may process data outside the European Economic Area, including in the United States. In such cases they rely on safeguards recognised under the GDPR, such as an adequacy decision or standard contractual clauses.

8Data retention

• enquiry data: up to 12 months after our last contact if we don't start working together;
• client data: for the duration of our work and for as long as required by accounting and tax law.

9Your rights

Under the GDPR you have the right to access, correct or delete your personal data, to restrict or object to its processing, and to data portability. To exercise these rights, email gorbanerro@proton.me. I will reply within one month.

You can also lodge a complaint with the Spanish data protection authority, Agencia Española de Protección de Datos (AEPD), aepd.es.

10Changes to this policy

I may update this policy if the website or the services I use change. The current version is always on this page, with the date at the top.