Privacy Policy
Last updated: May 2026
1. Data Controller
The Data Controller is Ganna Lytvynenko (hereinafter "Controller"), operating as a sole proprietor under Italian law.
Contact: hello@ganna.guide
2. Legal Basis for Processing
Personal data processing is carried out in accordance with:
- Regulation (EU) 2016/679 (GDPR — General Data Protection Regulation)
- Decreto Legislativo 196/2003 (Italian Privacy Code) as amended by D.Lgs. 101/2018
- Guidelines of the Garante per la protezione dei dati personali (Italian Data Protection Authority)
3. Data We Collect
When purchasing a digital guide, we collect:
- Email address — for delivering the purchased guide and order-related communication
- Name (optional) — for personalizing communication
- Payment data — processed exclusively by the payment provider Stripe, Inc. We do not store your credit card details
Technical data (IP address, browser type, referring page) may be collected automatically for security and analytics purposes.
4. Purpose of Data Processing
Your data is used for:
- Contract performance (Art. 6(1)(b) GDPR) — order processing, guide delivery via email, customer support
- Legitimate interest (Art. 6(1)(f) GDPR) — fraud prevention, accounting in compliance with Italian law
- Consent (Art. 6(1)(a) GDPR) — sending informational communications (only with your consent)
5. Third-Party Data Sharing
Your data may be shared with:
- Stripe, Inc. (USA) — for payment processing. Stripe is certified under the EU-US Data Privacy Framework. Stripe Privacy Policy
- Email service (SMTP) — for delivering the guide to your email
We do not sell, rent, or share your data for third-party marketing purposes.
6. Data Retention
- Order data: retained for 10 years in accordance with Italian tax law requirements (art. 2220 Codice Civile)
- Email and name: retained until order fulfillment + statutory retention period, or until a deletion request is received
7. Your Rights
Under GDPR (Articles 15-22) and Italian law, you have the right to:
- Access — obtain a copy of your personal data
- Rectification — correct inaccurate data
- Erasure — request data deletion ("right to be forgotten")
- Restriction — limit how your data is used
- Portability — receive data in a structured format
- Objection — object to processing of your data
- Withdraw consent — withdraw previously given consent
To exercise your rights, contact: hello@ganna.guide
You also have the right to lodge a complaint with the Garante per la protezione dei dati personali: www.garanteprivacy.it
8. Cookies
This website uses only technical cookies necessary for functionality (e.g., admin session). We do not use profiling or marketing cookies. In accordance with Garante guidelines (Provvedimento 229/2014), technical cookies do not require consent.
9. Data Security
We implement appropriate technical and organizational measures to protect your data in accordance with Art. 32 GDPR, including SSL/TLS encryption, secure storage, and restricted access.
10. Policy Changes
We reserve the right to update this policy. The date of the last update is indicated at the top. For significant changes, we will notify you by email.