1. Who is responsible for your data
The controller of personal data is:
- Oleh Yuriiovych Marechko, individual entrepreneur (ФОП), Ukraine
- Taxpayer registration number: 3764809416
- Address: 1 Vidkryta St., room 223, Lviv, 79008, Lviv Region, Ukraine
- Email: [email protected]
For any question about your data, write to the email above. We respond to such requests within 30 days.
2. What data we collect
2.1. Contact form
When you submit the form on the Contact page we receive: your name, phone number, email (optional), the message text, and the page address the form was sent from. We need this to reply to you.
2.2. Website chat
The chat widget stores the text of your messages plus technical session data: the page address where the conversation started and your browser's User-Agent string. If you submit a request through the chat, we additionally store the name, phone, email and comment you provide.
To make the chat work, an anonymous session identifier is created in your browser. It is not linked to your name unless you provide it, and it is kept in your browser's local storage.
2.3. Analytics (only with your consent)
If you clicked “Accept” in the consent bar, we use the Plerdy analytics service. It collects: IP address, device and browser data, referral source, pages viewed, clicks and scrolling, as well as session recordings and heatmaps. Without your consent Plerdy is not loaded at all.
2.4. Aggregate visit statistics
We use Cloudflare Web Analytics to see anonymous statistics: how many pages were viewed, where visitors came from, and how fast the site loads. This service writes no cookies and no identifiers into your browser, does not fingerprint your device, and does not track you across other sites. That is why it does not require your consent, but we disclose it here.
2.5. What we do NOT collect
We do not collect payment data through the website, do not use advertising pixels (Meta, Google Ads), do not sell data to third parties, and do not make automated decisions about you that produce legal effects.
3. Legal basis for processing
- Form and chat: steps taken at your request prior to entering into a contract (Art. 6(1)(b) GDPR) and our legitimate interest in responding to inquiries (Art. 6(1)(f) GDPR).
- Analytics: solely your consent (Art. 6(1)(a) GDPR and Art. 5(3) of Directive 2002/58/EC). You may withdraw it at any time.
- Technical operation of the site: our legitimate interest in a secure and functioning website (Art. 6(1)(f) GDPR).
4. Who receives the data
We use the following processors. Each of them processes data only on our instructions:
| Service | Purpose | Data location |
|---|---|---|
| Cloudflare | Website hosting, attack protection | Global network |
| Cloudflare Web Analytics | Anonymous visit statistics (no cookies, no identifiers) | Global network |
| Supabase | Chat database | Ireland (EU) |
| Plerdy | Analytics (only with consent) | Germany (EU) |
| Self-hosted n8n | Processing form submissions | EU |
We may also disclose data where required by law (for example, upon a lawful request from a competent authority).
5. Transfers outside the EEA
We are registered in Ukraine. The European Commission has not adopted an adequacy decision for Ukraine. Therefore, if you are located in the EEA, your data is transferred to a country outside the EEA.
The basis for such transfer is the necessity to perform a contract with you or to take steps at your request before entering into it (Art. 49(1)(b) GDPR), and for analytics it is your explicit consent (Art. 49(1)(a) GDPR). The chat and analytics databases themselves are physically located in the EU.
6. How long we keep data
- Requests and correspondence: up to 3 years from the last contact, then deleted.
- Chat history: up to 12 months.
- Analytics data: per Plerdy's retention settings, but no longer than 14 months.
- Record of your consent: for as long as the consent is valid, plus 12 months after withdrawal, as proof.
7. Your rights
Wherever you are located, you have the right to:
- know which of your data we process and receive a copy of it;
- have inaccurate data corrected;
- request erasure of your data (“right to be forgotten”);
- restrict processing or object to it;
- receive your data in a machine-readable format and port it to another company;
- withdraw your analytics consent at any time. This does not affect the lawfulness of processing before withdrawal.
To exercise any of these rights, write to [email protected]. This is free of charge.
8. Cookies and local storage
This site sets no advertising cookies. It does, however, store a small amount of data in your browser's local storage. Legally, this is treated the same as cookies.
| What is stored | Purpose | Consent needed? |
|---|---|---|
ba2-lang |
Selected interface language | No, strictly necessary |
ba2-consent |
Your analytics choice | No, strictly necessary |
atlas-chat-*, sb-* |
Chat functionality, your conversation | No, necessary for the chat |
plerdy_*, _suid, ip |
Plerdy analytics | Yes, only with consent |
You can change your decision at any time: .
Fonts on this site are self-hosted, so your browser does not contact any third-party font service.
Cloudflare Web Analytics is deliberately absent from this table: it stores nothing in your browser, so there is nothing to delete.
9. Where to complain
If you believe we have infringed your rights, please contact us first and we will try to resolve the matter. You also have the right to lodge a complaint with a supervisory authority:
- In Ukraine: the Ukrainian Parliament Commissioner for Human Rights (ombudsman.gov.ua).
- In the EU: the data protection authority of your country. List: edpb.europa.eu.
10. Changes to this policy
If we change how we process data, we will update this page and the version date at the top. If the changes are material (for example, a new analytics service is added), we will ask for your consent again.