Privacy

Privacy Policy

We collect only what we need to answer you and to see how the site is used. We don’t sell your data or use it for advertising.

Last updated: .

Who we are

This site, www.emberborea.com, is run by Individual Entrepreneur Roman Shtykh, trading as Ember Borea (identification number 300459732), registered in Tbilisi, Republic of Georgia. We are the controller of the personal data described here. For anything about your data, email roman.s@emberborea.com.

What we collect and why

Updates form

Product inquiry and contact forms

Partner program form

WhatsApp, phone and email

If you message, call or email us, we use your number or address and what you tell us only to reply, on the same legal basis and for the same period as the contact form. WhatsApp is run by Meta, which processes the conversation under its own terms and privacy policy.

Analytics

With your consent, we use Google Analytics 4 to see how the site is used: pages viewed, the site that sent you, approximate country or city, and device and browser type. Google derives the location from your IP address; we never see the address, and we set no user IDs. Analytics runs only after you accept in the cookie banner. Analytics data is kept for 14 months.

Hosting

Cloudflare hosts the site and processes technical request data, such as your IP address, to deliver pages and protect the site from abuse. This rests on our legitimate interest in a secure, working site. We don’t receive or keep these logs.

Cookies and local storage

We set no cookies unless you accept analytics. Change your choice any time via “Cookie settings” in the footer — declining removes the analytics cookies.

Cookies and storage used on this site
NameWhat it doesDuration
eb:analytics-consentLocal storage, not a cookie. Remembers your analytics choice and when you made it — we ask again after 12 months.Until you clear it
eb:bg-video-pausedLocal storage, not a cookie. Remembers whether you paused the background video.Until you clear it
_gaGoogle Analytics: tells visits apart. Only after you accept.2 years
_ga_<ID>Google Analytics: keeps the state of a visit. Only after you accept.2 years

Who we share it with

We don’t sell personal data, and we don’t share it for cross-context behavioural advertising. It goes only to the providers that run the site for us:

If you message us on WhatsApp, Meta handles that conversation as an independent controller, under its own privacy policy.

We may also disclose data where the law requires it. Some providers are outside Georgia, the EU and the UK. Transfers rely on the providers’ Standard Contractual Clauses or, where they are certified, the EU–U.S. Data Privacy Framework.

Your rights

Depending on where you live, you can ask us to:

These cover rights under the GDPR and UK GDPR, the privacy laws of US states such as California, Canada’s PIPEDA and Georgia’s Law on Personal Data Protection. We won’t treat you differently for using them. Email roman.s@emberborea.com — you or an agent you authorise. We may ask you to confirm your identity, and we reply within 30 days.

You can also complain to a data protection authority: the one where you live or work, or Georgia’s Personal Data Protection Service.

Security

The site is served only over HTTPS, and the forms send data over encrypted connections. We limit who can access submissions and delete what we no longer need.

Children

The site is not meant for anyone under 16, and we don’t knowingly collect their data. If you think a child has sent us personal data, email us and we’ll delete it.

Changes to this policy

If this policy changes, we’ll update this page and the date at the top. We’ll tell anyone on the updates list about significant changes.