Privacy Policy
1. Who is responsible for your data?
Daniel Dmitriouk
Zürich, Switzerland
ddmitriouk@gmail.com
+41 79 800 87 28
This policy applies to the website danieldmitriouk.com and is governed by Swiss law (Federal Act on Data Protection, nDSG, in force since 1 September 2023). Where visitors are located in the EU/EEA, the GDPR applies in parallel.
2. What data I collect and why
Contact form
When you submit the contact form, I collect:
- Your name
- Your email address
- The message you write
This data is used solely to respond to your enquiry. The legal basis is your consent (Art. 6(1)(a) GDPR / nDSG Art. 31).
Form submissions are processed by EmailJS (EmailJS Ltd, United Kingdom), which acts as a data processor on my behalf. EmailJS transmits your message to my inbox and does not store it beyond what is technically necessary for delivery. Their privacy policy is available at emailjs.com/legal/privacy-policy.
Google Fonts
This site loads fonts from Google Fonts. When your browser requests a font, your IP address is transmitted to Google's servers. This is a technically necessary operation for displaying the site correctly. Google's privacy policy applies: policies.google.com/privacy.
Server logs
My web hosting provider may log standard server access data (IP address, browser type, pages visited, timestamps) for security and operational purposes. These logs are not used for marketing or profiling and are deleted automatically after a short retention period.
3. Cookies and measurement
Two different rules apply, depending on where you are. This is not a trick, it is simply the law that applies to each of you:
From Switzerland. Swiss law does not require prior consent for cookies. Art. 45c lit. b of the Telecommunications Act requires that I inform you and give you the ability to refuse. That is what the notice on your first visit does: measurement is running, and one click on Don't measure switches it off. The legal basis is my overriding interest in evaluating my own website and advertising (Art. 31(1) revDSG).
From the EU or EEA. The GDPR and the ePrivacy Directive apply, and they require active, prior consent. So nothing loads for you until you click Accept in the banner. If you do not click, or you decline, Google Analytics and the Meta Pixel stay off entirely. The legal basis is your consent (Art. 6(1)(a) GDPR).
Can you change your answer? Yes, at any time and in one click, using the Cookie settings link in the footer of every page.
Google Analytics 4 (Google Ireland Limited) measures how many people visit, which pages they read, and which buttons they click. IP addresses are shortened by Google before storage, and the data is used only in aggregate to improve the site. It is never used to identify you personally, and it is never sold.
Meta Pixel and Conversions API (Meta Platforms Ireland Limited). If you consent, this site loads the Meta Pixel to measure which advertisements lead to enquiries and bookings. It records page views, views of service pages, and clicks on booking links. When you complete a booking, the confirmation page also reports that booking to Meta a second time from my server through the Conversions API, so that a single booking is counted once rather than twice. For that server-side report your email address and name, if you entered them when booking, are converted into an irreversible cryptographic hash (SHA-256) before they leave my server. Meta can use those hashes to recognise an existing account, so please treat this as a transfer of personal data even though the plain values are never sent. Meta acts as an independent controller for this data and may use it for its own purposes; Meta's privacy policy applies: facebook.com/privacy/policy.
What is actually stored
_ga,_ga_*· Google · tells visitors apart · up to 2 years_fbp· Meta · links a browser to an advertisement · around 90 days_fbc· Meta · remembers the ad click · around 90 days, only set if you arrive via an advertisementdd_consent· mine, in your browser's local storage, not a cookie · remembers your answer so you are not asked on every visitdd_no_analytics· mine, in local storage · excludes my own devices from measurement
If you decline, the only item from that list which is set is dd_consent, and only because otherwise I could not remember that you declined.
Country detection. On your first visit the site determines which country your connection comes from, solely in order to apply the correct rule above. The country is not stored, not logged, and not linked to you.
You can also opt out of Google Analytics separately for your browser using Google's opt-out add-on.
Booking. Appointments run through Cal.com (Cal.com, Inc., USA). Clicking a booking link takes you off this website, and whatever you enter there is processed by Cal.com under their privacy policy. After booking, Cal.com returns you to /danke and passes the booking details along. That page strips them out of the address bar and browser history immediately and sends no referrer to third parties, so your email address cannot leak to Google or Meta.
4. How long I keep your data
Messages received via the contact form are kept in my inbox for as long as necessary to respond to your enquiry and for a reasonable period thereafter (typically up to 2 years). You may request deletion at any time (see Section 6).
5. International transfers
EmailJS is based in the United Kingdom, which the EU considers a country with adequate data protection. Google Fonts servers are operated globally by Google LLC (USA). Google Analytics and the Meta Pixel both involve transfers to the United States, to Google LLC and Meta Platforms, Inc. respectively; these services load only with your consent (see Section 3). Where data is transferred to countries without an EU adequacy decision, appropriate safeguards (Standard Contractual Clauses) apply.
6. Your rights
Under the nDSG and GDPR you have the right to:
- Access · request a copy of personal data I hold about you
- Correction · ask me to correct inaccurate data
- Deletion · ask me to delete your data
- Restriction · ask me to limit how I use your data
- Objection · object to processing based on legitimate interest
- Portability · receive your data in a structured, machine-readable format
- Withdraw consent · at any time, without affecting lawfulness of prior processing. For measurement this is one click: Cookie settings
To exercise any of these rights, email me at ddmitriouk@gmail.com. I will respond within 30 days.
You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) at edoeb.admin.ch, or with your national data protection authority if you are in the EU.
7. Changes to this policy
I may update this policy from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the site after changes constitutes acceptance of the updated policy.
Questions? Email ddmitriouk@gmail.com · I'll get back to you within 24 hours.