Who is responsible
YURII MILKIN, trading as Initiaira, is responsible for the personal data described here. Address: 46015 Valencia, Spain.
For privacy questions or requests, email [email protected].
Information we receive
When you contact us, we receive your name, email address, message and any company information you choose to provide. The form requires a name, email and description so that we can understand and answer your enquiry. Company information is optional.
We may also receive a limited source label, such as the referring website or campaign, to understand how you found us. We do not need passwords, identity documents, payment-card details or sensitive personal information in an initial enquiry.
Our hosting and email providers process technical information needed to deliver and protect the service, such as IP addresses, request information and email delivery records.
Why we use it
We use enquiries to respond, discuss your requirements and, where requested, prepare a proposal. For a person requesting services, this is processing needed to take steps before entering a contract (GDPR Article 6(1)(b)). For business representatives and other business correspondence, we rely on our legitimate interest in answering relevant enquiries (Article 6(1)(f)).
We also rely on legitimate interests to keep the website and email service secure, prevent abuse and understand the sources of genuine enquiries. We limit this information to what is useful for those purposes. You can object to processing based on legitimate interests.
Submitting the form does not subscribe you to marketing emails. We do not sell enquiry data, use it to train AI models, or make automated decisions about you with legal or similarly significant effects.
Access and service providers
Within Initiaira, access to enquiries is limited to Yurii Milkin. Service providers process information as needed to operate the website and email:
- Cloudflare — website hosting, request handling and security.
- Resend (Plus Five Five, Inc.) — delivery of enquiry notifications and receipt emails.
- Namecheap Private Email — the business mailbox and correspondence.
These providers and their authorised subprocessors may process data outside the European Economic Area. Where such a transfer requires safeguards, these must be supported by an applicable adequacy decision or appropriate contractual safeguards, including the European Commission’s Standard Contractual Clauses. You can contact us for details of the safeguards applicable to your data.
Provider information: Cloudflare data processing terms, Resend data processing terms, and Namecheap data processing terms. We may also disclose information where required by law or necessary to establish, exercise or defend legal claims.
How long we keep it
If an enquiry does not lead to a contract, we retain the enquiry and related correspondence for 12 months after our last contact, then delete it. If a specific legal obligation or dispute requires continued retention, we restrict the information to that purpose.
Records relating to an agreed engagement, accounting or legal obligations follow the retention requirements applicable to those records. Technical delivery and security records are limited to their operational purpose and the retention controls of the relevant provider; they are not used as a separate marketing database.
Your rights
Depending on the circumstances, you can request access, correction, deletion, restriction or portability of your personal data, and object to processing based on legitimate interests. Contact [email protected]. We may need proportionate information to verify that a request concerns your own data.
We normally respond within one month. If an extension is permitted because a request is complex or there are several requests, we will explain the reason within that first month.
You can lodge a complaint with the Spanish Data Protection Agency (AEPD), or another competent supervisory authority. See the AEPD’s information about exercising your rights.
Cookies and changes
See our Cookie Policy for information about browser storage. If our services or handling of data change, we will update this policy and provide additional information where required.