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
- Data: your email address.
- Purpose: to send the Ember Borea updates you asked for.
- Legal basis: your consent, which you can withdraw at any time.
- Kept: until you unsubscribe or ask us to remove it.
Product inquiry and contact forms
- Data: on a product inquiry, your name and WhatsApp number, plus email and message if you add them; on the contact form, your name, email and message, plus WhatsApp number if you add it.
- Purpose: to answer your question or prepare an order.
- Legal basis: steps you asked us to take before a possible contract, and our legitimate interest in answering the people who write to us.
- Kept: 24 months after our last exchange. If an inquiry becomes an order, order records are kept as long as Georgian tax and accounting law requires.
Partner program form
- Data: your name, company, country or region and email, plus WhatsApp number and message if you add them.
- Purpose: to discuss working together.
- Legal basis: steps before a possible contract, and our legitimate interest in building business partnerships.
- Kept: 24 months after our last exchange, or for the length of a partnership.
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.
| Name | What it does | Duration |
|---|---|---|
eb:analytics-consent | Local 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-paused | Local storage, not a cookie. Remembers whether you paused the background video. | Until you clear it |
_ga | Google 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:
- Formspree (USA) — receives and stores form submissions, along with technical data such as your IP address, used to deliver them and filter spam.
- Google (USA) — Google Analytics, and Google Workspace for our email.
- Cloudflare (USA) — hosting and security.
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:
- tell you what data we hold about you and give you a copy;
- correct it or delete it;
- restrict or object to how we use it;
- send it to you or another service in a portable format;
- stop using it where we rely on your consent — this doesn’t affect earlier use.
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.