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Privacy Policy

Last updated: 13 September 2026

Public offer·Privacy policy·Terms of service·Payment methods·Refund policy

ℹ️ This document is available in English and Ukrainian. The English version is the official and legally binding version.

Цей документ доступний англійською та українською мовою. Англійська версія є офіційною та юридично обов'язковою.

This Privacy Policy explains how we process personal data of visitors to sirenko.studio and persons who contact us via the contact form or email.

The data controller is IE Vasyl Sirenko (Individual Entrepreneur) (the “Controller”, “Contractor”). Sirenko studio is the commercial name of the Controller’s web studio. “We” or “our team” on the site is a convenient way to communicate: the Contractor organises the services. Individual tasks may be performed by engaged freelancers or subcontractors under a subcontract; this does not create employment or a payroll of hired employees of the Contractor. Legal responsibility to you lies with the Contractor (IE Vasyl Sirenko).

This Policy covers browsing the site, cookies, analytics, and enquiries before a paid contract. If you become a Client under the Public Offer, the contract terms on personal data (Offer Section 17) also apply; processing within a project is described there and in this Policy.

For clients in the European Union and other jurisdictions where GDPR applies, we respect your data subject rights to the extent required by applicable law.

Controller: IE Vasyl Sirenko (Individual Entrepreneur) Tax ID (INN): 322960649 Legal form: Individual Entrepreneur (IE), registered under the laws of Georgia Registered address: Ambrolauri Municipality, Didi Chorjo village, 5th street, N28, Georgia Privacy enquiries: [email protected] Billing and refunds (where relevant): [email protected] Website: sirenko.studio Commercial name on the site: Sirenko studio

We collect only data needed to operate the site, respond to enquiries, or perform a contract.

Contact form

— Form fields (e.g. name, email, message; depending on form settings — phone or company name).

— Purpose: reply to your request, discuss a possible project, send a proposal or invoice with your consent.

— Legal basis (GDPR): your consent (Art. 6(1)(a)) and/or our legitimate interest in responding to business enquiries (Art. 6(1)(f)).

Email and messaging

— If you write to [email protected] or continue the conversation in a channel you choose, we process the content and contact details you provide.

— Legal basis: consent or performance of a contract / steps prior to entering a contract (Art. 6(1)(b)), and legitimate interest in communication (Art. 6(1)(f)).

Client data under contract

— Name, email, phone, payment reference details, project materials — to deliver services, accounting, and perform the Offer.

— Legal basis: contract (Art. 6(1)(b)) and legal obligation (Art. 6(1)(c)).

Technical data when you visit the site

— IP address, browser type, date and time of request, page URL — in hosting logs and (where used) content delivery and security services.

— Purpose: security, site stability, error diagnosis.

— Legal basis: legitimate interest in operating and protecting the service (Art. 6(1)(f)).

We do not sell personal data or share it with third parties for their marketing.

Cookies are small files or browser records. We may also use localStorage to store your cookie choices.

Strictly necessary (functional)

— Language cookie (Polylang) — remembers your chosen language (EN/UK). Required for the site to work as expected; no separate consent required.

— Cookie banner choice (once the banner is live) — stored locally so we do not ask on every visit.

Analytics and marketing (with consent)

— The site may use Google Tag Manager (GTM), which can load Google Analytics 4 (GA4) and Google Ads tools (e.g. conversion tracking). These help us understand site usage and measure advertising.

— Until a consent banner is deployed, such tools may load; after the banner is live, we configure non-essential cookies and similar identifiers to activate only after you consent in the banner (e.g. “statistics” / “marketing” categories as shown in the banner).

— You may withdraw consent via the banner or browser settings; core site functions will remain available.

Managing cookies

— Most browsers let you delete or block cookies in settings.

— Once the banner is on the site — Accept, Reject, or Configure with a link to this Policy.

We do not use Meta Pixel or other third-party ad networks except those explicitly listed here and in GTM settings at the time of the last Policy update.

We use form and message data only to:

— respond to your enquiry;

— prepare a proposal, invoice, or contract if you agree to proceed;

— perform orders under the Offer and support the project;

— comply with law (accounting, taxes, lawful requests from authorities).

We do not use your messages for bulk marketing without separate opt-in.

Enquiries without a contract — usually up to 24 months from last contact, unless you request earlier deletion.

Client project data — for the contract term and up to 3 years after completion for accounting, warranty claims, and protection of the Controller’s rights, unless law requires longer retention.

Server access logs — up to 7 days at the hosting provider (see Section 7), unless the provider retains them longer for security reasons.

After retention periods, data is deleted or anonymised unless there is a lawful reason to keep it.

Where GDPR or similar rules apply, you have the right to:

— access — obtain a copy of personal data we process;

— rectification — correct inaccurate data;

— erasure — be forgotten where there is no lawful basis to retain data;

— restriction of processing;

— object to processing based on legitimate interests;

— data portability — receive data in a structured, machine-readable format where processing is based on consent or contract;

— withdraw consent — where processing is based on consent; withdrawal does not affect lawfulness before withdrawal.

To exercise your rights, email [email protected]. We respond within 30 days unless law sets a different deadline.

You may lodge a complaint with a supervisory authority in your country of residence or stay.

The site is hosted on servers operated by Hetzner Online GmbH (Germany, EU). Processing within the European Economic Area generally does not require additional GDPR safeguards beyond standard vendor terms where applicable.

The site may be served via a content delivery and security network (e.g. Cloudflare), which processes IP address and technical request data for performance and abuse protection.

Google (Analytics, Ads, Tag Manager) is a US company; when their services are used, data may be processed outside the EU under Google’s terms and transfer mechanisms (including framework agreements and supplementary measures where required).

We apply reasonable organisational and technical measures (access limits, software updates, backups). No internet transmission is completely secure; we cannot guarantee zero risk but aim to minimise it.

The site links to external resources (e.g. client portfolio sites, social networks, payment or cloud services). After you follow a link, that site’s privacy policy applies, not this Policy.

If we integrate third-party services on your project at the Client’s request, processing in those services is governed by you as site owner; we may assist with technical setup under the contract.

Public Offer — governs paid services; Offer Section 17 covers Client personal data under the contract.

Terms of Service (when published) — rules for using the site and ordering services.

If documents conflict on processing under a signed contract, priority is: individual written contract, then the Offer for the Client, while this Privacy Policy describes processing on the site and communication before a contract.

Public Offer (UK): https://sirenko.studio/legal/publichna-oferta/ · EN: https://sirenko.studio/en/documents/public-offer/

The official English version of this Policy is at https://sirenko.studio/en/documents/privacy-policy/. If translations differ, the English text prevails.

We may update this Policy when site services, law, or our practices change (e.g. after launching a cookie banner).

The “Last updated” date at the top shows the current version. Continued use after changes means you have read the updated Policy; where new processing requires consent, we will ask separately (e.g. via banner or form).

Privacy and this Policy: [email protected]

Billing and refunds: [email protected]

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