Privacy Policy

1. Who we are

2. What personal data we collect

• Contact form data: your name, email address, and any other information you choose to include in your message (e.g. company name, phone number, or details of your enquiry).
• Correspondence data: if you email or otherwise contact us directly, we keep a record of that correspondence, including your contact details and the content of your message.
• Client and engagement data: if a service engagement follows your enquiry, we collect the additional information needed to deliver and invoice our consulting services, under a separate signed agreement.
• Technical data: standard server and hosting logs (such as IP address, browser type, device type, and access times) collected automatically by our website hosting platform for security and site-operation purposes.

3. Why we process your data and our legal basis

•  To respond to enquiries you send us through the contact form or by email — Art. 6(1)(b) GDPR (steps taken at your request prior to entering into a contract), or Art. 6(1)(f) GDPR (our legitimate interest in responding to business enquiries) where no contract follows.
• To perform and administer a consulting services agreement once one is in place — Art. 6(1)(b) GDPR.
• To comply with legal obligations, in particular accounting, invoicing and tax record-keeping requirements under Luxembourg commercial and tax law — Art. 6(1)(c) GDPR.
• To keep our website secure and functioning correctly — Art. 6(1)(f) GDPR (legitimate interest in the security and integrity of our systems).
• To establish, exercise, or defend legal claims — Art. 6(1)(f) GDPR

4. Who we share your data with

• Service providers acting as our data processors, in particular our website hosting and no-code website platform, Webflow, Inc. (398 11th Street, 2nd Floor, San Francisco, CA 94103, USA), engaged strictly to host and operate this website under a data processing agreement compliant with Art. 28 GDPR.
• Our website developer/agency, engaged solely to build and maintain this website, where technically necessary.
• Professional advisers (e.g. accountant), where necessary to comply with our legal and tax obligations.
• Competent public authorities, where we are required to do so by law.

5. International data transfers

6. How long we keep your data

• Service providers acting as our data processors, in particular our website hosting and no-code website platform, Webflow, Inc. (398 11th Street, 2nd Floor, San Francisco, CA 94103, USA), engaged strictly to host and operate this website under a data processing agreement compliant with Art. 28 GDPR.• Contact form enquiries that do not lead to a service engagement: kept for up to 12 months from your last contact with us, unless a longer period is required to establish, exercise or defend legal claims.
• Client and engagement data (including invoices): kept for the duration of the business relationship and thereafter for the retention periods required by Luxembourg commercial and tax law, generally up to 10 years from the end of the relevant financial year.
• Technical/server log data: kept for the shorter period required for security purposes, in line with our hosting provider's standard retention practices.

7. Your rights

• Access the personal data we hold about you (Art. 15 GDPR);
• Request rectification of inaccurate or incomplete data (Art. 16 GDPR);
• Request erasure of your data, the so-called “right to be forgotten” (Art. 17 GDPR);
• Request restriction of processing in certain circumstances (Art. 18 GDPR);
• Receive your data in a structured, commonly used, machine-readable format and have it transmitted to another controller, where technically feasible (Art. 20 GDPR);
• Object to processing based on our legitimate interest (Art. 21 GDPR);
•  Withdraw your consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.

8. Cookies

9. Children's data

10. Security

11. Changes to this Policy

12. Contact