Policy
policy

1. General

This page says what data spheredigital.org collects about you and what we do with it. We work in Europe and Ukraine, so we follow the GDPR (Regulation 2016/679) and the Ukrainian law on personal data protection.

The data controller, «we» below: the Sphere Digital team. Data questions: spheeredigital@gmail.com.

2. What data we collect

Only what we need to handle your request and run the site.

• From the request form: your name, the name and trade of your business, city, contact method (Telegram or phone) and your message.
• From messages you send us on Telegram, Instagram or by email: your contact and the content of the message.
• Technical data about the visit: IP address, approximate region, device type, browser and its language, which pages you opened and which links you followed.
• Analytics data about behaviour on the site, including session recordings. It is collected only after you press «Accept» in the cookie banner and is described in the cookie policy.

We do not collect special categories of data (health, beliefs, biometrics and the like) and ask you not to put them in the free text fields.

3. Why we process data and on what grounds

Each purpose has its own legal basis under Article 6 of the GDPR.

• To answer your request, prepare a demo and a quote and discuss the project. Basis: steps taken at your request before a contract, and then performance of what we agreed.
• To serve the site, protect it from attacks and failures and keep technical logs. Basis: our legitimate interest in a safe and stable site.
• To count visits and analyse behaviour through analytics. Basis: your consent, given in the cookie banner and withdrawable at any time.

We send no newsletters you did not ask for and sell our contact base to nobody.

When we build a booking system for your business, your clients' data belongs to you and we act as a processor on your instructions. This is covered by a separate data processing agreement (DPA) under Article 28 of the GDPR: we send the template before the work starts.

4. Who we share data with

Our providers process data on our instructions and only as far as they need to.

• Cloudflare, Inc. (USA): hosting, content delivery and protection from attacks. Processes technical data and IP addresses.
• FormSubmit: delivery of form requests to our mailbox. Processes the form contents.
• Google LLC (Google Fonts): when a page loads, the browser requests font files and Google receives the IP address and request data.
• Microsoft Corporation (Microsoft Clarity): behaviour analytics and session recordings. Loaded only after you consent to cookies.

We disclose data to state authorities only on a justified lawful request. Otherwise data goes to no third party.

5. Transfers outside the country

Some providers work outside the European Economic Area, mostly in the USA. Data goes there under the European Commission standard contractual clauses, that is with protection at the level the GDPR requires.

6. How long we keep data

• Requests and project correspondence: while we are in touch and up to three years after the last contact, unless the law requires otherwise or you ask us to delete it sooner.
• Data on completed projects: for the period set by the applicable tax and accounting law.
• Technical logs and analytics data: for the periods set by those providers, usually up to two years.

Once the period ends the data is deleted or anonymised.

7. Your rights

Under the GDPR you have these rights and we respect them.

• Confirm that we process your data and get access to it (Art. 15).
• Correct inaccurate data (Art. 16).
• Erase data, the «right to be forgotten» (Art. 17).
• Restrict processing (Art. 18).
• Receive your data in a machine-readable form and pass it to another controller (Art. 20).
• Object to processing based on legitimate interest (Art. 21).
• Withdraw consent at any time, which does not affect processing done before the withdrawal.

To use any of these rights write to spheeredigital@gmail.com. We answer within a month. If you believe we are breaking your rights, you can complain to the data protection authority in the country where you live or work.

8. Children's data

The site is for business owners, not for anyone under 16. We do not collect children's data, and if any reaches us by mistake we delete it on request.

9. Automated decisions

We make no decisions with legal effect for you on automated processing alone, and we do no profiling in that sense.

10. Security

The site runs over https only. Access to our mail and working systems is limited and protected. No way of sending data over the internet is a hundred percent safe, but we take reasonable organisational and technical measures to keep the risk low.

11. Cookies

How the site uses cookies and similar technologies is described in a separate cookie policy.

12. Changes to the policy

We may update this policy, for example when we connect a new service. The new version is published on this page and applies from the moment of publication. The date of the last update is at the bottom of the page.

Version of 16 July 2026. In force from the moment of publication on spheredigital.org.