Privacy Policy

1. Introduction

This Privacy Policy explains what personal data Flat Rate Website collects, why, and what you can do about it. It covers three groups of people:

Visitors to our website, flatratewebsite.com (the "Site")
Business owners we email. We find businesses on their public websites and write to them one to one
Clients who buy a homepage from us

We process personal data in line with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), Spain's data protection law, the US CAN-SPAM Act and other laws that apply to us.

2. Data controller

For the purposes of GDPR, the data controller is:

Controller: Dmitrii Sharonov
Tax ID (NIF): Y9674448H
Registered as: autónomo in Spain
Address: Calle Floridablanca, 66-68, Local 9F, 08015 Barcelona, España
Email: kirill@flatratewebsite.com
Website: flatratewebsite.com

The research, the page design and the emails are done by Kirill, who works with the controller on this service. When you write to kirill@flatratewebsite.com, Kirill reads it.

3. Visitors to our Site

3.1 What the Site collects

Nothing. The Site has no contact forms, no sign-up, no analytics, no advertising pixels, no cookies and no other tracking. Its fonts are stored on the Site itself, so opening a page does not send your data to a font service.

The sample homepages on the Site show a made-up business. Some of them show a request form as part of the design. That form is a sample: nothing you type into it is sent to us or stored anywhere.

If you email us from a link on the Site, we get your email the same way we get any email. See Section 5.

3.2 Our hosting provider

The Site is hosted on GitHub Pages, run by GitHub, Inc. GitHub states: "When a GitHub Pages site is visited, the visitor's IP address is logged and stored for security purposes, regardless of whether the visitor has signed into GitHub or not." We do not receive these logs. GitHub's privacy statement: https://docs.github.com/en/site-policy/privacy-policies/github-general-privacy-statement

4. Business owners we email

4.1 Where the data comes from

We look for residential electricians (and later other trades) on their own public business websites.

4.2 What we collect

Business name
The owner's name, if the business publishes it
Business email address and business phone number
Business address and service area
License number, if published
The text and photos on your business website
Links to your public Google and Yelp reviews

4.3 What we use it for

To make sample versions of your homepage from what is already on your website
To send you one personal email about them, and up to two follow-ups if you do not reply. We send no more than three emails in all

The sample versions sit on a private page that is not listed in search engines. Only people who have the link can open it, and we send the link only to you.

We do not sell this data, and we do not add you to a mailing list.

4.4 Legal basis

Legitimate interests (GDPR Art. 6(1)(f)): offering a service to a business, using contact details the business itself has made public for that purpose. You can object at any time (Section 4.5).

4.5 How to stop our emails

Reply "stop" to any of our emails, or write to kirill@flatratewebsite.com. We will not email you again. We keep your email address on a do-not-contact list only so that we never write to you by mistake later. Every email we send includes our name and a way to opt out. We honour opt-out requests within 10 business days, as the CAN-SPAM Act requires, and in practice as soon as we read them.

4.6 How long we keep it

If you do not buy, we delete the sample versions and the data we collected about your business 30 days after our last email to you. We keep only the do-not-contact entry if you asked us to stop.

5. Clients

5.1 What we collect

Your name, business name, business email and phone number
The version you picked and our emails with you
The information and photos you send us for your homepage
The details needed to set up the account your homepage sits on, in your name
Payment information. Processed only by Stripe. We never receive or store your card number or bank details. From Stripe we receive the payment confirmation, the amount, the payment status and your country

5.2 What we use it for, and the legal basis

To make and hand over your homepage, take payment, and handle refunds. Legal basis: performance of our contract with you (GDPR Art. 6(1)(b))
To keep tax and accounting records. Legal basis: legal obligation (GDPR Art. 6(1)(c))
To answer your questions. Legal basis: contract, or our legitimate interests (GDPR Art. 6(1)(f))

We do not sell personal data. We share it with these service providers, each acting as a processor unless noted:

Stripe (payments). Processes payments and sends receipts for us. Stripe acts as an independent data controller for some payment data. Privacy policy: https://stripe.com/privacy
Namecheap, Inc. (our email). Hosts the mailbox kirill@flatratewebsite.com, so it holds the emails we send and receive. Privacy policy: https://www.namecheap.com/legal/general/privacy-policy/
GitHub, Inc. (hosts the Site). See Section 3.2
A web hosting provider (hosts the private sample versions)
The hosting provider of your account (the service your homepage is put on, in your name. Once it is handed over, your account there is between you and that provider)
Legal authorities, when the law or a court order requires it

7. International transfers

The controller is in Spain. Kirill, who does the work on the controller's behalf, works from Turkey. Some of our providers are in the United States. So your data may be processed outside the European Economic Area.

Turkey has no adequacy decision from the European Commission. The controller and Kirill are putting in place a written agreement for this work, based on the European Commission's Standard Contractual Clauses (Implementing Decision (EU) 2021/914). That agreement is not signed yet. Once it is signed, you can ask us for a copy at kirill@flatratewebsite.com.

For our providers in the United States, each provider's own privacy policy, linked in Sections 3.2 and 6, explains how it protects data it transfers. You can also write to us and ask.

8. How long we keep data

Outreach data: see Section 4.6
Do-not-contact list: for as long as we send outreach emails
Client correspondence and project files: 12 months after hand-over, then deleted, except what we must keep by law
Payment and invoice records: as long as Spanish tax and commercial law requires

9. Cookies

The Site sets no cookies and uses no similar technologies. If that ever changes, we will update this policy first.

10. Your rights

You have the right to:

Access: get a copy of the personal data we hold about you
Rectification: have wrong or incomplete data corrected
Erasure: have your data deleted
Restriction: ask us to limit how we use your data
Data portability: get your data in a structured, commonly used, machine-readable format
Object: object to processing based on legitimate interests, including our outreach emails
Withdraw consent: where we rely on consent, withdraw it at any time

We give these rights to everyone we hold data about, wherever you live. To use them, write to kirill@flatratewebsite.com. We will reply within 30 days. You also have the right to complain to a data protection authority. In Spain that is the Agencia Española de Protección de Datos (AEPD), https://www.aepd.es.

11. Children

Our Service is for businesses. We do not knowingly collect data from anyone under 18. If we learn that we have, we delete it.

12. Security

We protect personal data with reasonable technical and organisational measures: encrypted connections (TLS), accounts protected by passwords, and access limited to the people who do the work. No method of sending or storing data over the internet is completely secure, so we cannot guarantee absolute security.

13. Changes to this policy

We may update this policy. When we do, we will post the new version on the Site with a new "Last updated" date.

14. Contact

For questions, requests or complaints about this policy or your data, contact:

Controller: Dmitrii Sharonov
Tax ID (NIF): Y9674448H
Registered as: autónomo in Spain
Address: Calle Floridablanca, 66-68, Local 9F, 08015 Barcelona, España
Email: kirill@flatratewebsite.com
Website: flatratewebsite.com

You may also contact your local data protection authority. For Spain: Agencia Española de Protección de Datos (AEPD), https://www.aepd.es.