Legal

Privacy Policy

Last updated: 16 September 2026

The short version. This website has no analytics, no advertising trackers and sets no cookies of its own. If you email me, I keep the email. If you become a client, I handle your business and customer data only to run the service you are paying for. I do not sell anyone's data, ever.

1. Who is responsible for your data

Ruslan Kurbanov, based in Rīga, Latvia, is the data controller for this website and for the Growth Engine service. Contact: [[EMAIL]].

2. If you are just visiting this website

This site is deliberately minimal about data:

• No analytics. There is no Google Analytics or equivalent on this site.
• No advertising or tracking pixels. Nothing here follows you around the web.
• No cookies set by this site. There is nothing to consent to, which is why you are not being asked.

Two things do happen automatically, and you should know about them:

Server logs

My hosting provider records standard technical information when a page is requested — IP address, browser type, the page requested and the time. This is used to keep the site running and secure, and to spot abuse. It is not used to build a profile of you.

Fonts

The typefaces on this site are loaded from Google Fonts, which means your IP address is visible to Google when the fonts are fetched. If you would rather avoid that, a content blocker will stop it and the site will still work.

3. If you email me

I receive whatever you write and whatever your email program sends with it — usually your name, email address, and anything you tell me about your business.

I use it only to reply and to work out whether I can help you. The legal basis is my legitimate interest in responding to an enquiry about my service, and, if we go ahead, taking steps to enter into a contract with you.

If nothing comes of the conversation, I delete the correspondence within 24 months. You can ask me to delete it sooner and I will.

4. If you become a client

To run the service I handle three kinds of information.

Your business details

Business name, address, contact details, billing details, and the logins or access you give me for your domain, hosting, Google Business Profile and similar. I keep these for as long as you are a client, and for up to six years afterwards where accounting or tax law requires it.

Payment information

Card payments are handled by a third-party payment processor. I never see or store your full card number. I only see what the processor shows me: that a payment succeeded or failed, the amount, and the last four digits of the card.

Your customers' data

The lead application holds information about the people who contact your business — names, phone numbers, email addresses, messages and call records. For that data, you are the controller and I am your processor: I handle it on your instructions, only to run the service, and never for my own purposes.

You are responsible for having a lawful basis to collect your customers' data, and for telling them how you use it. When your subscription ends I will return a copy of that data on request and then delete it from my systems within 90 days.

5. Who else sees the data

I do not sell data, rent it, or share it for anyone else's advertising. I share it only with the service providers needed to run things, and only as far as each one needs:

• Hosting provider — serves this website and your website.
• Payment processor — takes the subscription payment and handles refunds.
• Lead application platform — stores the leads and messages in your dashboard.
• Email provider — carries the messages between us.
• Google — where the review system and your Google Business Profile are involved.

I may also disclose information where the law requires it. If that ever happens and I am allowed to tell you, I will.

6. International transfers

I am in Latvia and most of my clients are in the United States, so data moves between the European Economic Area and the US. Where that happens, it is covered by the transfer mechanisms the relevant provider has in place, such as the EU Standard Contractual Clauses or the EU–US Data Privacy Framework.

7. Security

Access is limited to me. Connections to this site and to the tools I use are encrypted in transit, accounts use multi-factor authentication where the provider supports it, and access is removed when it is no longer needed. No system is perfectly secure, but if a breach affects your data I will tell you promptly and tell you what I am doing about it.

8. Your rights

Under the GDPR, if you are in the EEA or the UK, you can ask me to:

• Tell you what data I hold about you, and give you a copy;
• Correct anything that is wrong;
• Delete it, where I have no legal reason to keep it;
• Restrict or object to how I use it;
• Send it to you, or to someone else, in a portable format;
• Withdraw consent, where consent was the basis for using it.

If you are in the United States, several states give you comparable rights — to know what is collected, to get a copy, to have it deleted, and not to be discriminated against for asking. I do not sell personal information or share it for cross-context behavioural advertising, so there is nothing for you to opt out of.

Email [[EMAIL]] and I will deal with it within 30 days, free of charge. If you are unhappy with how I handle it, you can complain to the Latvian Data State Inspectorate (Datu valsts inspekcija) or your local supervisory authority.

9. Children

This service is sold to businesses and is not directed at children. I do not knowingly collect data from anyone under 16. If you believe I have, tell me and I will delete it.

10. Changes to this policy

If I add anything to this site that collects data — a contact form, or analytics — I will update this page before it goes live. The date at the top always reflects the current version.