This policy explains how Mykhaylo Yuzak (trading as CashFlowedX) handles personal data collected through this website. The wording below is a structural draft only and has not yet been reviewed by a solicitor.
1. Who we are
[PLACEHOLDER — pending solicitor review]
Identify the data controller, its legal status and how to reach it. Controller: Mykhaylo Yuzak, a sole trader registered in Poland (NIP 5273137232 · REGON 540067842), at ul. Jana Kazimierza 32B/55, 01-248 Warsaw, Poland. Confirm whether ICO registration as a data controller is required and, if so, add the registration number here.
Data protection enquiries: cflowedx@gmail.com
2. What data we collect
Information you give us
[PLACEHOLDER — pending solicitor review]
Describe the fields captured by the enquiry and investor-registration forms on this site (for example name, email address, telephone number, investor type, indicative ticket size and free-text message), and note that submission is voluntary.
Information collected automatically
[PLACEHOLDER — pending solicitor review]
Describe analytics and device data collected via cookies and similar technologies — for example IP address, approximate location, browser and device type, pages viewed, referring source and campaign parameters. Cross-reference the Cookie Policy for the full list.
3. Lawful basis for processing
[PLACEHOLDER — pending solicitor review]
State the lawful basis relied on for each processing purpose under UK GDPR Article 6 — likely consent for analytics and advertising cookies, and legitimate interests (or steps prior to entering a contract) for responding to enquiries. Confirm the legitimate interests assessment has been documented.
4. How we use your information
[PLACEHOLDER — pending solicitor review]
Set out each purpose: responding to enquiries, assessing investor eligibility, sending requested information about opportunities, improving the website, and measuring marketing performance. Confirm whether direct marketing is sent and on what basis (PECR soft opt-in vs. express consent).
5. Sharing and processors
We use third-party service providers to operate this website. The processors currently in use are:
- Formspree — receives and forwards contact form submissions.
- Google Analytics — website usage measurement.
- Vercel — website hosting, delivery and server logs.
[PLACEHOLDER — pending solicitor review]
Confirm this list is complete before publication (add Google Ads / Google Tag Manager, email provider, and any CRM if applicable). Confirm a written data processing agreement is in place with each processor, and state that we do not sell personal data.
6. International transfers
[PLACEHOLDER — pending solicitor review]
Identify which processors transfer personal data outside the UK/EEA and the transfer mechanism relied on (UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or an adequacy decision). Confirm a transfer risk assessment has been completed.
7. How long we keep your data
[PLACEHOLDER — pending solicitor review]
State a retention period for each category — enquiry correspondence, investor registration records, and analytics data — together with the justification for each period and what happens at the end of it.
8. Your rights
Under the UK GDPR and the EU GDPR you have rights over your personal data, which are expected to include the following.
- Right of access — to obtain a copy of the personal data we hold about you.
- Right to rectification — to have inaccurate data corrected.
- Right to erasure — to ask us to delete your data in certain circumstances.
- Right to restrict processing.
- Right to data portability.
- Right to object to processing, including direct marketing.
- Right to withdraw consent at any time, where processing is based on consent.
[PLACEHOLDER — pending solicitor review]
Confirm the response timeframe (one calendar month under UK GDPR), the verification steps required before a request is actioned, and the address to which requests should be sent.
9. Cookies
This website uses cookies and similar technologies. A full description of the categories used, the third parties involved and how to change your choice is set out in our Cookie Policy.
[PLACEHOLDER — pending solicitor review]
Ensure the consent mechanism described in the Cookie Policy matches what is actually deployed on the site, including the Google Consent Mode v2 default state.
10. How to complain
[PLACEHOLDER — pending solicitor review]
State that a complaint may be made to the Information Commissioner’s Office (ICO), the UK supervisory authority, and confirm the correct contact route and address to publish. Invite the individual to contact us first so that we can try to resolve the matter.
11. Changes to this policy
[PLACEHOLDER — pending solicitor review]
Explain how changes are notified and how the “last updated” date should be maintained.
12. Contact
Questions about this policy or about how your personal data is handled can be sent to cflowedx@gmail.com, or by post to Mykhaylo Yuzak, ul. Jana Kazimierza 32B/55, 01-248 Warsaw, Poland.
Back to home