Privacy Policy
Information on the processing of personal data under Article 13 of Regulation (EU) 2016/679 (GDPR) and Legislative Decree 196/2003 (Italian Personal Data Protection Code), as amended by Legislative Decree 101/2018.
Fokina Anastasiia — ditta individuale
P.IVA 14948520961 (VAT IT14948520961)
E-mail: [email protected] · Phone: +39 331 393 2159
1. Data controller
The data controller is Fokina Anastasiia, ditta individuale, P.IVA 14948520961. E-mail: [email protected], phone: +39 331 393 2159.
No Data Protection Officer (DPO) has been appointed, as the law does not require one for this activity.
2. What data I process
- Contact data and correspondence: name, e-mail address, phone number and the content of the messages you send me by e-mail, WhatsApp or phone.
- Data needed for the consulting work: information about your business, your Instagram account and the materials you choose to share with me. Please do not share special categories of data (for example, health data) unless strictly necessary.
- Payment data: amount, date and status of the payment, and the limited card details provided by Stripe (for example, card type and last four digits). Full card numbers are processed by Stripe and are never stored by me.
- Billing data: name or business name, address, tax code or VAT number, needed to issue invoices.
- Technical data: IP address, browser type, date and time of the request, processed by the hosting provider to deliver and protect the website. The website does not use analytics.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Answering your requests and preparing an offer at your request | Pre-contractual measures taken at your request (Art. 6(1)(b) GDPR); for general enquiries, my legitimate interest in answering them (Art. 6(1)(f)) |
| Providing the consulting services, scheduling consultations, giving access to the video lectures, handling payments | Performance of the contract (Art. 6(1)(b)) |
| Invoicing, bookkeeping and tax obligations under Italian law | Legal obligation (Art. 6(1)(c)) |
| Establishing, exercising or defending legal claims | Legitimate interest (Art. 6(1)(f)) |
| Operating and securing the website | Legitimate interest (Art. 6(1)(f)) |
I do not send newsletters or marketing messages. If I ever want to, I will ask for your consent separately.
4. Is providing data mandatory?
Data needed to answer your request, provide the services and meet tax obligations is necessary: without it I cannot provide the consulting package. Any other information you share is optional.
5. How data is processed
Data is processed with electronic tools and appropriate technical and organisational security measures, only by me and by the providers listed below, to the extent needed for each purpose.
6. Who receives the data
Data may be shared with providers acting as data processors (Art. 28 GDPR) or as independent controllers:
- Stripe — payment processing;
- Google — e-mail (Gmail);
- Cloudflare — hosting and delivery of the website;
- WhatsApp (Meta) — only if you choose to contact me via WhatsApp;
- Zoom (Zoom Communications, Inc.), used for the one-to-one calls, and the platform that hosts the video lectures;
- my accountant, for tax and bookkeeping obligations;
- public authorities, where required by law.
Data is not disseminated or sold.
7. Transfers outside the EEA
Some of these providers may process data outside the European Economic Area, in particular in the United States. Such transfers take place on the basis of the European Commission’s adequacy decision for the EU–US Data Privacy Framework (for certified providers) or of the Standard Contractual Clauses adopted by the Commission (Art. 46 GDPR). You can ask for more information at [email protected].
8. How long data is kept
- Enquiries that do not lead to a contract: for as long as needed to handle your request.
- Contract data and correspondence with clients: for the duration of the contract and afterwards for the ordinary limitation period of 10 years (Art. 2946 of the Italian Civil Code), to protect the rights of both parties.
- Invoices and accounting records: 10 years, as required by Art. 2220 of the Italian Civil Code.
- Technical data: for the short periods set by the hosting provider for security purposes.
9. Your rights
Under Articles 15–22 GDPR you have the right to access your data, have it rectified or erased, restrict its processing, receive it in a portable format and object to processing based on legitimate interest. To exercise these rights, write to [email protected]. I will reply without undue delay and in any case within one month.
10. Right to lodge a complaint
If you believe your data is processed unlawfully, you can lodge a complaint with the Italian supervisory authority, the Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Roma (garanteprivacy.it), or with the authority of the EU country where you live or work, or apply to the courts.
11. Automated decision-making
No decisions are made by automated means, including profiling.
12. Cookies
This website does not set cookies and does not use analytics, profiling or advertising tools, third-party trackers or embedded content; fonts are served from the website itself. For this reason there is no cookie banner. If the hosting provider uses strictly necessary technical cookies for security, these do not require consent (Art. 122 of the Italian Personal Data Protection Code). Links to WhatsApp and e-mail open external services, which have their own privacy policies.
13. Changes
I may update this policy when the processing changes. The date at the top of the page shows the current version.