Privacy Policy

Date : August 13, 2025

Australian privacy compliance
I am committed to complying with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) in the collection, use, disclosure and handling of personal information for individuals in Australia. By using this site or/and our services, you consent to the Processing of your Personal Data as described in this Privacy Policy.

Definitions

Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
I, We – Andrei Iunisov, independent digital marketing consultant.

Data protection principles

I promise to follow the below data protection principles:

Processing is lawful, fair, transparent. My Processing activities have lawful grounds. I always consider your rights before Processing Personal Data. I will provide you information regarding Processing upon request.
Processing is limited to the purpose. My Processing activities fit the purpose for which Personal Data was gathered.
Processing is done with minimal data. I only gather and Process the minimal amount of Personal Data required for any purpose.
Processing is limited with a time period. I will not store your personal data for longer than needed.
I will do my best to ensure the accuracy of data.
I will do my best to ensure the integrity and confidentiality of data.

Data subject’s rights

The Data Subject has the following rights:

Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from my records.
Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
Right for the help of supervisory authority– meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.

Data I gather

Information you have provided me with

I may obtain the following types of information from you or concerning your computer or device (“Information”), which may include information that can be used to identify you as specified below (“Personally Identifiable Information”):

Name
Email Address
Mailing Address
Telephone Number(s)
Blog or Website URL
Social Networking Handle or Username
Photo
Demographic Information (e.g., age, gender, interests, and preferences)
Professional Title
Company
Industry
Activities or Content Viewed on My Website
Information Collected Automatically ( detailed below)

In certain cases, I may request that you provide some of the Information identified above in order to obtain my personal consultation. If you choose not to provide the Information, you may still read the content of this website.

When you register to receive any consultations or services from me or provide information to me in any other manner, you agree to provide only true, accurate, current and complete information.

Information automatically collected about you

Our website may automatically receive and log certain types of information when you visit or interact with my website, services, mobile applications or other products, including:

Browser Information
Operating System Information
Mobile Device Information (e.g., device identifier, mobile operating system, etc.)
IP Address
Internet Service Provider
Content Viewed
Geographic Location
Connection Speed
Time of Visit
Referring Site, Application, or Service
Registration Time

Publicly available information

I might gather information about you that is publicly available.

Notification of collection

When I collect personal information, I will take reasonable steps to ensure you are aware of:

my identity and how to contact me;
the purposes for which the information is collected;
whether any collection is required or authorised by law;
the main consequences if the information is not provided (for example, I may be unable to provide certain services);
the types of organisations to which I usually disclose personal information, including any overseas recipients;
how to access and correct your personal information and how to make a privacy complaint.

Anonymity and pseudonymity

Where lawful and practicable, you may interact with me anonymously or by using a pseudonym. However, in many cases I may need your identifiable details (such as your name and contact information) in order to provide my services or respond to your inquiries.

Unsolicited information

If I receive personal information that I did not request, I will determine whether I could have lawfully collected it under this Privacy Policy and the Australian Privacy Principles. If not, I will take reasonable steps to destroy or permanently de-identify the information, provided it is lawful and reasonable to do so.

Government identifiers

I do not use government-related identifiers (such as tax file numbers, Medicare numbers, or driver’s licence numbers) as my own identifiers of individuals. If such identifiers are provided to me, they will only be used where required by law.

Sensitive information

I do not intentionally collect sensitive information. If it becomes reasonably necessary for my functions and you choose to provide such information, I will only collect and use it with your explicit consent or as otherwise permitted by law.

How I use your personal data

I use your Personal Data in order to:

Provide digital marketing and other relevant services
Fulfill your requests
Improve this website
Personalize and tailor your experience on this website
Understand how users are engaging with this website

I use your Personal Data on legitimate grounds and with your Consent.

On the grounds of entering into a contract or fulfilling contractual obligations, I Process your Personal Data for the following purposes:

To identify you for communication purposes;
To provide you a service or to send/offer you a proposal;
To communicate either for sales or invoicing.

On the ground of legitimate interest, I Process your Personal Data for the following purposes:

To send you personalized offers (from me and/or my carefully selected partners);
To administer and analyze my client base (purchasing behavior and history) in order to improve the quality, variety, and availability of services offered/provided;
To conduct questionnaires concerning client satisfaction.

As long as you have not informed me otherwise, I consider offering you services that are similar or same to your purchasing history/browsing behavior to be our legitimate interest.

With your consent I Process your Personal Data for the following purposes:

To send you newsletters and campaign offers (from me and/or my carefully selected partners);
To build a database of relevant search information to improve the quality, variety, and availability of my consulting services;
For other purposes I have asked your consent for.

Direct marketing

I may use your personal information to provide you with information about services, promotions or events that may be of interest. You may opt out at any time by using the unsubscribe link in emails or by contacting me at [email protected]. I do not sell personal information.

I Process your Personal Data in order to fulfill obligation rising from law and/or use your Personal Data for options provided by law. I reserve the right to anonymize Personal Data gathered and to use any such data. I will use data outside the scope of this Policy only when it is anonymized. I save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law.

I might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, I will ensure that:

The link between purposes, context and nature of Personal Data is suitable for further Processing;
The further Processing would not harm your interests and
There would be appropriate safeguard for Processing.

I will inform you of any further Processing and purposes.

Data retention

I will retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or to comply with legal, accounting, or reporting requirements. The retention periods for different categories of Personal Data are as follows:

Data Type	Retention Period	Reason
Contact details provided for consultations (name, email, phone)	5 years from last contact	To respond to follow-up inquiries or repeat service requests
Client records and service-related communications	5 years from project completion	For reference, dispute resolution, and service improvement
Billing and financial information	7 years	To comply with tax and accounting obligations
Newsletter subscription data	Until you unsubscribe	Marketing communications
Analytics and website usage data (non-identifiable)	26 months (Google Analytics’ default data retention setting)	Website performance and improvement
Cookie data	As per the cookie duration listed in the Cookies section of this policy	Functionality, analytics, advertising

Legal basis for processing personal data

I process your Personal Data only where there is a valid legal basis. Each processing activity is linked to one or more of the following legal bases: consent, contract, legal obligation, or legitimate interest.

Purpose of processing	Data collected	Legal basis
To provide digital marketing consultations and related services	Name, Email, Phone, Professional Title, Company Name, Billing Information	Contract (Article 6(1)(b) GDPR)
To send you proposals, invoices, or contractual information	Name, Email, Phone, Professional Title, Company Name, Billing Information	Contract (Article 6(1)(b) GDPR)
To send you newsletters or promotional offers	Name, Email	Consent (Article 6(1)(a) GDPR)
To improve this website and analyze usage patterns	IP address, Browser data, Necessary, Analytics and Performance cookies	Legitimate Interest (Article 6(1)(f) GDPR)
To comply with legal obligations (e.g., tax, accounting)	Billing records, Transaction data	Legal Obligation (Article 6(1)(c) GDPR)
To respond to your inquiries	Name, Email, Any information you provide in your message	Legitimate Interest or Contract depending on context

Who else can access your Personal Data

I do not share your Personal Data with strangers. Personal Data about you is in some cases provided to my trusted partners in order to either make providing the service to you possible or to enhance your customer experience. I share your data with:

Our processing partners:

Connected third parties:

I only work with Processing partners who are able to ensure an adequate level of protection to your Personal Data. I disclose your Personal Data to third parties or public officials when we are legally obliged to do so. I might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.

International data transfers

Some of my trusted partners and service providers are located outside your country. This means your Personal Data may be transferred to, and processed in, countries that may not provide the same level of data protection as your home country. Whenever I transfer your Personal Data internationally, I ensure that appropriate safeguards are in place to protect it, including:

Adequacy Decisions – Where the European Commission have determined that the destination country provides an adequate level of protection for personal data.
Standard Contractual Clauses (SCCs) – Using contractual terms approved by the European Commission that require the recipient to protect your Personal Data.
Other Lawful Mechanisms – Such as Binding Corporate Rules or your explicit consent, where applicable.

Transfers to service providers such as Google, Amazon Web Services, Microsoft, and GoDaddy may involve processing in the United States, member states of the European Union or other countries. These providers have committed to appropriate contractual safeguards to ensure your data remains protected in line with GDPR requirements. In addition, for individuals in Australia, I take reasonable steps to ensure that any overseas recipients of personal information do not breach the Australian Privacy Principles (APPs). Likely countries where your information may be processed include the United States and member states of the European Union.

How I secure your data

I do my best to keep your Personal Data safe. I use safe protocols for communication and transferring data (such as HTTPS). I use anonymizing and pseudonymizing where suitable. I monitor our systems for possible vulnerabilities and attacks. Stored data is encrypted when possible.

Even though I try my best I can not guarantee the security of information. However, I promise to notify affected individuals and the Office of the Australian Information Commissioner (OAIC) of eligible data breaches in accordance with the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth). I will also notify you if there is a threat to your rights or interests. I will do everything I reasonably can to prevent security breaches and to assist authorities should any breaches occur.

Children

I do not intend to collect or knowingly collect information from children. I do not target children with my services.

Cookies and other technologies I use

I use cookies and/or similar technologies to analyze customer behavior, administer the website, track users’ movements, and to collect information about users. This is done in order to personalize and enhance your experience with me.

A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only I can access the cookies created by my website. I can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.

I use cookies for the following purposes:

Essential cookies – these cookies are required for you to be able to use some important features on this website. These cookies don’t collect any personal information.
Analytics cookies – these cookies are used to track the use and performance of my website.
Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organizations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organization.

If you are located in the European Economic Area (EEA), the United Kingdom, or other regions with similar privacy laws, non-essential cookies (such as analytics and advertising cookies) will only be placed on your device after you have given your explicit consent through the cookie banner that appears on your first visit to this website. You can withdraw your consent at any time by adjusting your cookie preferences via the banner or your browser settings. Essential cookies, which are necessary for the operation of the site, will be set regardless of consent.

Here are the cookies we use:

Google Analytics _ga first-party analytics cookie, 1 year 1 months expiration
Language pll_language first-party essential cookie, 1 year expiration
LinkedIn third-party li_gc essential cookie, 5 months 4 weeks expiration
YouTube third-party essential VISITOR_PRIVACY_METADATA cookie, 5 months 4 weeks expiration
Cookie Script first-party essential CookieScriptConsent cookie, 4 weeks 2 days expiration
PHP session first-party essential PHPSESSID cookie, end-of-session expiration
Cloudflare third-party essential cf_clearance cookie, 1 year expiration
Leadfeeder _lfa first-party advertising cookie, 1 year expiration
Microsoft (LinkedIn) bcookie third-party advertising cookie, 1 year expiration
LinkedIn lidc third-party advertising cookie, 1 day expiration
YouTube VISITOR_INFO1_LIVE third-party advertising cookie, 5 months 4 weeks expiration
YouTube YSC third-party advertising cookie, end-of-session expiration
Microsoft Clarity CLID third-party analytics cookie, 1 year expiration
Reddit _rdt_uuidfirst-party advertising cookie, 2 months 4 weeks expiration

You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.

We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.

Governing law and disputes

This policy and consent forms part of our Terms and Conditions and as such it shall be governed by and construed in accordance with Australian law and, if you are a resident of the European Economic Area (EEA) we maintain your personal data subject to the General Data Protection Regulation. Unless there is a conflict between these two, you irrevocably agree that the courts of the Commonwealth of Australia shall have exclusive jurisdiction to resolve any dispute or claim of whatever nature arising out of or relating to this policy and consent or otherwise to the use of your personal data, and that such laws shall govern such dispute or claim.

Contact information

If you wish to access, correct, delete, or restrict the processing of your Personal Data, or exercise any other rights under applicable data protection laws, you can submit a request by contacting me using the details below.

When making a request, please include:

Your full name and contact details
A clear description of the request and the rights you wish to exercise
Any additional information needed to verify your identity (if applicable)

I will respond to your request without undue delay and in any event within one month of receiving it, as required under most regulations. In certain circumstances, this period may be extended by up to two additional months if the request is complex or if multiple requests are made. You will be informed if an extension is necessary.

You may request access to the personal information I hold about you and request that it be corrected if it is inaccurate, out-of-date, incomplete, irrelevant or misleading. I will respond to such requests within a reasonable time. I may request identity verification and, where permitted, charge a reasonable administrative fee for access. If I refuse access or correction, I will provide written reasons and information on how to make a complaint.

If you are not satisfied with how I handle your request or complaint, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or on 1300 363 992.

Contact details
Data Controller: Andrei Iunisov
Email: [email protected]

Availability of this policy

This policy is publicly available on my website free of charge. If you require it in an alternative format (for example, large print or accessible digital copy), please contact me and I will provide it where reasonably practicable.

Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy.
Last modification was made 2025-August-13.