Privacy Policy

Irina Shurmina, Unipessoal LDA, Lisbon, Portugal. Contact: irina.shurmina@gmail.com. No Data Protection Officer is appointed, as one is not required under Article 37 GDPR for processing of this scale.

Only what you provide yourself through the forms on this site: your name, your email address, and the content of any message you choose to send. Where a form asks about the topic of your enquiry or which programme option interests you, that selection is stored with your message.

When you buy a place in the GROW programme, payment is processed by Stripe. Card details never reach this website; only the confirmation of the payment, the amount and your email address are stored.

Emails sent through the newsletter provider may record whether a message was delivered, opened, or a link was clicked, so that sending quality can be monitored. No profiling or automated decision-making with legal or similarly significant effects takes place.

Replies to enquiries — to answer the message you sent. Legal basis: steps taken at your request prior to entering into a contract, or the legitimate interest in responding to correspondence (Art. 6(1)(b) and 6(1)(f) GDPR).

GROW newsletter and webinar recording — to send you the emails you asked for. Legal basis: your consent, given when you submit the form (Art. 6(1)(a) GDPR). You may withdraw consent at any time; withdrawal does not affect the lawfulness of processing before withdrawal.

Programme delivery and payments — to provide the programme you purchased and to issue invoices. Legal basis: performance of a contract (Art. 6(1)(b)) and compliance with tax and accounting obligations (Art. 6(1)(c) GDPR).

Your data is never sold, rented, or used for advertising, and it is not shared with third parties beyond the processors listed below.

The following providers process personal data on our behalf, under data processing agreements and only on our instructions: Supabase (data storage and hosting), Lovable (website hosting), Brevo (email delivery, France/EU), Stripe (payments) and Telegram (internal notification that a new form has been submitted).

Where a provider processes data outside the European Economic Area, the transfer is covered by the European Commission's Standard Contractual Clauses together with supplementary safeguards. A copy of the relevant safeguards can be requested at the address above.

Newsletter subscriber details are kept until you unsubscribe or ask to be removed, and deleted shortly afterwards (a minimal record of the unsubscribe may be retained to avoid re-contacting you). Enquiries and webinar requests are kept for up to 24 months from the last contact. Records related to purchases and invoicing are kept for 10 years, as required by Portuguese tax law.

Under the GDPR you have the right to access your data, to have it corrected or erased, to restrict or object to its processing, to receive it in a portable machine-readable format, and to withdraw consent at any time. Every newsletter email includes a one-click unsubscribe link, which stops all newsletter emails immediately. For any other request, write to irina.shurmina@gmail.com. Requests are answered within one month.

Providing your data is voluntary; if you choose not to provide it, the corresponding form or service simply cannot be delivered.

If you believe your data has been handled improperly, you may lodge a complaint with a supervisory authority — in Portugal, the Comissão Nacional de Proteção de Dados (CNPD), cnpd.pt.

Data is stored on access-controlled servers, transmitted over encrypted connections (HTTPS), and accessible only to Irina Shurmina and the processors listed above, strictly as needed to deliver these services.

This website and its services are intended for professionals and are not directed at children under 16. No data is knowingly collected from them.

This site does not use advertising, analytics or tracking cookies, so no cookie consent banner is required. Only technical storage strictly necessary for the site to function is used.

If this policy changes, the updated version will be published on this page with a new date at the top.