Privacy Policy
Effective date: 22 June 2026
1. Who we are (Controller)
This website is operated by Mike Vakulenko, working as a self-employed professional (autónomo) in Spain, trading as Adnetico.
Registered address: Calle Cardenal Gardoqui 6B, 48008 Bilbao, Bizkaia, Spain
NIF: Z0057502F
Contact for privacy matters: mike@adnetico.com
For the purposes of the EU General Data Protection Regulation (GDPR), Mike Vakulenko is the controller of the personal data processed through this website.
2. What data we process, and why
a) Website delivery and security
When you visit the site, our hosting and CDN provider may process limited technical data in standard server/CDN logs — such as IP address, date and time, requested URLs, HTTP status codes, referrer, and user-agent.
Legal basis: our legitimate interest in delivering a secure, reliable website and preventing abuse (Art. 6(1)(f) GDPR).
b) The /audit quiz and the advertorial order brief
If you complete the audit quiz or submit an advertorial order brief, we process the information you provide — for example your email, company or offer name, product details, and the answers you enter — so we can respond, scope the work, and prepare a quote or invoice.
Legal basis: taking steps at your request prior to entering a contract (Art. 6(1)(b) GDPR), and our legitimate interest in handling business enquiries (Art. 6(1)(f) GDPR).
c) Newsletter
If you sign up for the newsletter, we process your email address to send you occasional updates. You can unsubscribe at any time.
Legal basis: your consent (Art. 6(1)(a) GDPR).
d) Booking a call
If you book a strategy call or working session, our scheduling provider processes the details you enter (such as name, email, and the time you pick) to confirm and manage the booking.
Legal basis: taking steps at your request prior to a contract (Art. 6(1)(b) GDPR).
We do not use your data for profiling, advertising, or automated decision-making.
3. Cookies and similar technologies
We do not set non-essential (analytics or advertising) cookies, and we do not use a cookie banner because we do not deploy such cookies. Our CDN may set strictly-necessary security cookies to protect the site; these are essential and do not require consent under the ePrivacy rules. Note that when you choose to book a call, the embedded scheduling tool is a third-party service that may set its own cookies once you interact with it — see the processors below.
4. Service providers (processors) and recipients
- Cloudflare, Inc. — website hosting, content delivery, and security.
- Formspree, Inc. (USA) — receives and forwards the audit, order, and newsletter form submissions.
- Cal.com, Inc. — scheduling for strategy calls and working sessions.
- Zoho Mail (Zoho Corporation) — email hosting, used to receive and respond to your messages and notifications.
These providers act as processors on our behalf where applicable, under appropriate data-processing terms.
5. International data transfers
Some providers (for example Formspree) are based outside the European Economic Area. Where data is transferred outside the EEA, we rely on EU adequacy decisions where available, or on Standard Contractual Clauses (SCCs) with additional safeguards.
6. Retention
- Server/CDN logs: kept for a short period for security and troubleshooting.
- Enquiries, audit and order data: kept for as long as needed to handle your request and our engagement, and thereafter as required for our legal and accounting obligations.
- Newsletter: kept until you unsubscribe.
7. Your rights
Subject to the conditions in the GDPR, you have the right to access, rectification, erasure, restriction, objection (to processing based on legitimate interests), data portability, and to withdraw consent where we rely on it (for example, the newsletter). To exercise your rights, email mike@adnetico.com. We may need to verify your identity before responding.
8. Complaints
You can lodge a complaint with your local EU supervisory authority. In Spain this is the Agencia Española de Protección de Datos (AEPD), www.aepd.es. We would appreciate the chance to address your concerns first.
9. Security
We apply reasonable technical and organizational measures to protect your data (HTTPS, CDN security features, restricted access). No method of transmission or storage is fully secure, but we work to protect your information.
10. Children
This website is not directed to children under 16, and we do not knowingly collect their data.
11. Changes to this notice
We may update this Privacy Policy when our services or legal requirements change. The "Effective date" above reflects the latest version.
12. Contact
For any privacy question or request, contact mike@adnetico.com.