Privacy Policy

Information I collect

• Information you provide voluntarily through the contact form (e.g., name, email, optional business details). Form submissions are securely transmitted and stored using HubSpot CRM. You can read more about their practices here.
• Technical information automatically collected for security purposes (e.g., IP address, browser type, basic server logs).
• Anonymous website usage statistics collected via Fathom Analytics (no cookies, no personal identifiers).
• Website behaviour data collected via Google Analytics 4 with BigQuery export for advanced analysis.
• User experience data collected via Hotjar (heatmaps, session recordings, feedback).

Commission Calculator

When you use the commission calculator, all data you input remains local to your device and browser. It is not saved, stored, transmitted, or tracked. No information is collected unless you separately choose to submit a contact form.

WhatsApp Contact

When you contact me via WhatsApp, personal data such as your phone number, message content, and timestamps is processed.

Using WhatsApp is entirely voluntary. You can always reach me by email or via the contact form instead.

Controller and roles

• The controller under GDPR is Keferboeck Ltd.
• WhatsApp (Meta Platforms Ireland Ltd.) is an independent provider and processes data under its own privacy policy.
• There is no joint controllership under Art. 26 GDPR.

Nature of processing

• Communication is strictly reactive, meaning it only happens on the initiative of the user.
• No WhatsApp messages are actively initiated by me.
• Processing takes place exclusively to handle the respective request.

Storage and security

• Messages are transmitted end to end encrypted by WhatsApp.
• WhatsApp stores messages on servers within the EU (Frankfurt am Main) and may also replicate them to servers outside the EU such as the United States. For such third country transfers, the EU Standard Contractual Clauses (SCCs) apply.
• Access on my side is role based and restricted to authorised persons. Messages are not stored locally on unmanaged end user devices.

Disclosure and purpose limitation

• Data transmitted via WhatsApp is not used for marketing, profiling, or automated decision making.
• No data from WhatsApp conversations is shared with third parties.

Deletion

Messages are deleted as soon as the processing purpose no longer applies, unless statutory retention obligations require otherwise.

Further information about data processing can be found in the respective sections of this privacy policy.

How I use your information

• To respond to your enquiries.
• To assess potential collaborations (if you submit a contact form).
• To secure and maintain the website's functionality.
• To improve the website through anonymised traffic insights and user behaviour analysis.

Newsletters and email subscriptions

If you subscribe to my newsletter or blog post updates (Intelligence page), your email address and name will be stored for the purpose of sending you relevant content. I comply with the UK Information Commissioner's Office (ICO) regulations and the Privacy and Electronic Communications Regulations (PECR).

• I will not contact you more than once per week.
• Every email includes an unsubscribe link at the bottom, allowing you to opt out at any time.
• Your subscription preferences are managed through HubSpot CRM, and you can update them at any time via the links provided in each email.

If you choose to mark my emails as spam rather than unsubscribing (which I hope you will not), I will remove you from the mailing list. I review spam complaints on a bi-daily basis to ensure compliance and maintain a clean sending reputation.

If you have any feedback, complaints, or suggestions regarding my newsletters, please contact me at [email protected].

Right to be forgotten

Under Article 17 of the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (EU GDPR), you have the right to request the erasure of your personal data, commonly known as the "right to be forgotten". This right is also upheld by the ICO as part of their data protection framework.

If you wish to exercise this right, please contact me at [email protected].

• Remove your name, email address, and newsletter preferences from my database.
• Delete your contact information from HubSpot CRM.
• Remove your email from any marketing and remarketing lists on Google Ads, LinkedIn, and any other advertising platforms I may use.

I will process your request within 30 days, as required by the UK GDPR and EU GDPR, and confirm deletion by email.

Confidentiality of submitted business data

Any business information you submit through the contact form is treated as strictly confidential. It will not be shared with third parties and is only used for assessing potential growth opportunities. You retain full ownership of any information submitted.

Cookies and tracking

This website uses cookies for security, analytics, user experience improvements, and marketing purposes. For detailed information about cookies used on this website, please refer to my Cookie Policy. Essential cookies (such as __cf_bm from Cloudflare) are used to protect against malicious bots. Analytics cookies are used by Fathom Analytics (cookie free) and Google Analytics 4. User experience cookies are used by Hotjar. Marketing cookies are used by Google Ads and LinkedIn.

Hosting

This website is hosted by Digital Ocean on servers located in London, United Kingdom. When you access the website, some technical data such as your IP address may be processed by Digital Ocean to maintain site security and performance. You can read more about their privacy practices here.

Data retention

Personal data is kept only for as long as necessary to fulfil the purpose it was collected for or as required by law. Business data submitted via contact forms is not retained unless ongoing collaboration is agreed.

Your rights

• Access the personal data I hold about you.
• Request correction of inaccurate or incomplete data.
• Request deletion of your personal data.
• Object to or restrict how I process your data.
• Lodge a complaint with a data protection authority if you believe your rights have been violated.

Changes to this policy

I may update this Privacy Policy to reflect changes to my practices. The updated policy will be published on this page.