Draft: complete the highlighted fields and have a lawyer review before publishing.
Privacy policy
Las páginas legales están disponibles en inglés.
Last updated: [date]. This policy explains which personal data is processed when you visit javiersugo.com, send a message or send an order request for the Website Atelier, according to the EU General Data Protection Regulation (GDPR) and the Austrian Data Protection Act (DSG).
Controller
Javier Sugo, Javier Sugo Strategy, Seitenstettengasse 5/37, 1010 Vienna, Austria. Email: hello@javiersugo.com
Hosting
This website is hosted by Netlify, Inc., USA. When you open a page, Netlify processes technical data such as your IP address, date and time, requested page and browser information, to deliver the site and keep it secure (legitimate interest, Art. 6 (1) (f) GDPR). [Verify Netlify's current EU-US Data Privacy Framework certification and data processing agreement]
Contact and order forms
The contact form and the Website Atelier order request are processed by Netlify Forms and forwarded to me by email. This includes your name, email, optional phone and company, the design and options you chose and your message. I use this data only to answer you and to prepare and deliver your order (pre-contract and contract steps, Art. 6 (1) (b) GDPR). To deliver an Atelier order, I create a Netlify hosting account with your email address, so Netlify, Inc. receives that address. [lawyer review] Submissions are deleted [retention period, for example 12 months after the last contact, unless tax law requires longer].
Payments
No payment is taken on this website. After an order request, I send a payment request by email (bank transfer or a payment link from [payment provider]). Invoices and payment records are kept for 7 years as required by Austrian tax law (§ 132 BAO, Art. 6 (1) (c) GDPR).
Fonts, cookies and tracking
Fonts are hosted on this website; no connection to Google Fonts is made on these pages. No tracking or advertising cookies and no analytics are used. [update if analytics are added]
Live demos
The live demos of the Website Atelier open in a new tab and show real website designs. Some of them load fonts from Google Fonts, sample photos from Unsplash or maps from Google, so these services receive your IP address when a demo is open. [lawyer review]
If you write to me, I process your message and email address to reply (Art. 6 (1) (b) or (f) GDPR). Email provider: [provider and location].
Your rights
You have the right to access, rectification, erasure, restriction of processing, data portability and objection. Write to hello@javiersugo.com. You can also lodge a complaint with the Austrian Data Protection Authority (Datenschutzbehörde), Barichgasse 40 to 42, 1030 Vienna, www.dsb.gv.at.