This Privacy Policy explains how I, Martin Avramov, collect, use and protect your personal data when you visit martinavramov.com, book a call, or get in touch about a project. I only collect what I need to reply to you, work with you, and keep this site running. This policy follows the EU General Data Protection Regulation (GDPR).
Who is responsible for your data
I am the data controller for the personal data described here.
Martin Avramov
Email: [email protected]
If you have a question about this policy or your data, email me and I’ll reply within one month.
What data I collect
When you contact me. If you email me, I receive your email address, your name, and whatever you choose to tell me about your project.
When you book a call. The booking calendar is run by Cal.com. When you book, Cal.com collects your name, email address, the time you picked, and any notes you add, and passes them to me so the call can happen. If the call is by video, the meeting link is created by the calendar or video service connected to the booking.
When you work with me. If we start a project, I’ll also hold the information needed to run it and invoice for it: your contact and billing details, our messages, and any material you share for the build. If the project involves your customers’ data (for example in a store or internal tool), that is covered by a separate agreement between us, where you are the controller and I act on your instructions.
When you browse the site. Some technical data is processed automatically:
- Hosting and security. The site is hosted by Hetzner Online GmbH (Germany) and delivered and protected by Cloudflare. They process your IP address, browser details and request information in server logs to deliver the site and block abuse.
- Cloudflare Web Analytics. I use Cloudflare’s privacy-focused analytics to count page views and measure site performance. It does not use cookies, does not store your IP address, and does not track you across sites. This runs on every visit because it does not identify you.
- Umami. I use Umami, a privacy-focused analytics tool that I host myself at stats.martinavramov.com, to understand which pages are useful. It records the pages you visit, the site that referred you, your approximate country, browser and device type. It does not use cookies, does not store your IP address, and does not track you across sites. The data stays on my server and isn’t shared with anyone.
I don’t use contact forms, newsletters, ad tracking, or social media pixels on this site. Links to LinkedIn, X and Medium are plain links. Nothing is shared with those platforms unless you click through, and once you do, their own privacy policies apply.
Why I use your data, and the legal basis
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Replying to your enquiry and holding the call you booked | Steps taken at your request before entering a contract (6(1)(b)), and my legitimate interest in answering enquiries (6(1)(f)) |
| Delivering a project we’ve agreed on | Performance of our contract (6(1)(b)) |
| Invoicing, accounting and tax records | Legal obligation (6(1)(c)) |
| Keeping the site secure and working, and cookieless analytics | Legitimate interest in a safe, working site (6(1)(f)) |
I don’t make automated decisions about you, I don’t profile you, and I don’t send marketing emails unless you’ve asked for them.
Who I share your data with
I don’t sell your data or share it for advertising. I use a small number of service providers, and they get only what they need:
- Hetzner Online GmbH (Germany): website hosting
- Cloudflare, Inc.: website delivery, security, and cookieless analytics
- Cal.com, Inc.: call scheduling
If I bring in a designer for a project (as described on the site), I’ll tell you first. They’ll get only the project material they need and will be bound to keep it confidential.
I may also disclose data where the law requires it, for example to a tax authority or a court.
International transfers
Some of these providers are based in, or use servers in, the United States. Where data leaves the EU/EEA, it is protected by the EU-U.S. Data Privacy Framework (where the provider is certified) or by the European Commission’s Standard Contractual Clauses.
How long I keep your data
- Enquiries and booked calls that don’t lead to a project: up to 12 months, then deleted.
- Client project data: for the length of our work, then as long as needed for warranty or support questions we’ve agreed on.
- Invoices and accounting records: for the period Bulgarian accounting and tax law requires (currently up to 10 years for some records).
- Umami analytics data: [24] months on my own server, then deleted.
- Server and security logs: kept by Hetzner and Cloudflare for short periods under their own policies.
Your rights
Under the GDPR you have the right to:
- access the personal data I hold about you
- have inaccurate data corrected
- have your data deleted
- restrict or object to how I process it
- receive your data in a portable format
- withdraw consent at any time, where processing is based on consent (this doesn’t affect anything done before you withdrew)
To use any of these rights, email [email protected]. I may need to confirm your identity first.
You can also complain to the Bulgarian data protection authority, the Commission for Personal Data Protection (Комисия за защита на личните данни), at www.cpdp.bg, or to the authority in the EU country where you live.
Cookies
This site only uses essential cookies, which are needed for it to work and stay secure. It doesn’t use analytics or advertising cookies, so there’s no cookie banner. For details, see the Cookie Policy.
Children
This site and my services are for businesses and adults. I don’t knowingly collect data from anyone under 18.
Security
The site runs over HTTPS. Access to my accounts is protected with strong passwords and two-factor authentication where available, and I only keep what I need.
Changes to this policy
I may update this policy as the site or my services change. The “Last updated” date at the top shows the latest version. If a change significantly affects how I use your data, I’ll make that clear on the site.
Contact
Questions about this policy or your data: [email protected]