Privacy Policy

Who we are

Anton Kunashenko, sole proprietor (FOP Kunashenko A.A.), is the controller of personal data processed through artbrain.studio. The business has been registered in Kharkiv, Ukraine since 2018. We are a web and software development studio serving small and medium businesses in Europe. We have not appointed a data protection officer or an EU representative.

What data we collect and why

We collect the following data. For inquiries and client work, our basis is performance of a contract or steps before a contract, GDPR Art. 6(1)(b). For server logs, security, first-party usage events and answering messages, our basis is legitimate interest, GDPR Art. 6(1)(f).

• Contact form data: your name, phone number or email, message text, the page it was sent from and traffic source, including referrer and ad click IDs
• Server logs: IP address, user agent, requested pages and timestamps
• First-party usage events: page views, contact-button clicks and form steps tied to a random session identifier in our own database. We do not use cross-site tracking.
• Client data: contract, invoicing and project communication data if you become a client

Cookies and analytics

Google Analytics 4 and Google Ads tags are loaded only with your consent under GDPR Art. 6(1)(a). You may withdraw consent at any time by clearing site data or choosing Reject in the cookie banner.

• cookie_consent: stores your cookie choice
• Preferences: language and theme settings stored in local storage
• Google cookies: Google Analytics and Google Ads cookies are set only after you click Accept
• Reject: choosing Reject prevents Google Analytics and Google Ads tags from loading. Necessary choice and preference storage still works.

Who receives the data

Our leads and events database and server logs are hosted by Hosting Ukraine LTD in Kyiv, Ukraine. Each contact form submission is sent by a bot to the studio's Telegram account, so Telegram processes the message. Google processes data when Google Analytics 4 or Google Ads tags are loaded after consent, and Gmail is used for correspondence.

Google Maps

We display Google Maps content, including reviews, on the homepage. Data handling by Google services is described in the Google Privacy Policy.

Transfers outside the EU

The studio and its server are in Ukraine. Ukraine does not have an EU adequacy decision. For inquiries and client work, transfers are necessary for a contract or steps before a contract under GDPR Art. 49(1)(b). We minimise data and restrict access. For client projects, we can sign standard contractual clauses on request.

How long we keep data

Inquiries without a contract are deleted or anonymised no later than 24 months after the last contact. Client contract data is kept for the contract term and for the period required by Ukrainian accounting law, up to 3 years. Server logs are kept for 30 days, first-party usage events for 24 months, and Google Analytics data for 14 months under Google's settings.

Your rights

You can exercise these rights by emailing kunashenko.ant@gmail.com. We answer within one month as the GDPR requires. You may also complain to the supervisory authority in the EU country where you live.

• Access your personal data
• Rectify inaccurate data
• Request erasure of your data
• Restrict processing of your data
• Receive your data in a portable format
• Object to processing based on legitimate interest
• Withdraw consent at any time

Security

The site is served over HTTPS. Access to the leads database and server is limited to the studio owner. We collect only the data listed above and keep it no longer than stated.

Children

This site is not intended for children under 16.

Changes to this policy

We may update this policy. The current version is published on this page.

Contact

For privacy questions, contact Anton Kunashenko at kunashenko.ant@gmail.com or +380 95 108 62 12.