Privacy Policy
Who is responsible for your data
The data controller for all personal data collected through this website and its associated tools is:
Desislava Penkova
Execution Architecture
Email: desislava@penkova.outlook.com
If you have any questions about how your data is handled, contact the address above directly.
What data is collected and why
Data is collected only when you actively submit it through this site. The table below covers every collection point.
| Where collected | Data collected | Why |
|---|---|---|
| Assessment gate | Full name, work email, company, phone (optional), WhatsApp (optional) | To send results and follow up regarding the engagement |
| Pre-work intake form | Answers to 5 session preparation questions | To prepare for the booked session. Read before the call, not during it. |
| Payment page | No payment data is collected directly. Payment is processed by Stripe under their own privacy policy. | — |
No data is collected passively through tracking pixels, advertising cookies, or third-party analytics beyond what is described in Section 5.
Legal basis for processing (GDPR)
If you are located in the European Economic Area (EEA) or United Kingdom, data is processed on the following legal bases:
| Processing activity | Legal basis |
|---|---|
| Sending assessment results | Consent — given explicitly at the assessment gate before results are shown |
| Following up about services | Consent — given explicitly at the assessment gate |
| Preparing for a booked session | Legitimate interest — directly related to a service you have requested |
| Processing payment | Contract performance — necessary to complete the engagement you have agreed to |
Consent can be withdrawn at any time by contacting desislava@penkova.outlook.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
How long data is kept
Data is kept only as long as necessary for the purpose it was collected.
| Data type | Retention period |
|---|---|
| Assessment submissions (no booking) | 12 months from submission date |
| Pre-work intake answers | Duration of the engagement plus 6 months |
| Client engagement data | 5 years from end of engagement for legal and accounting purposes |
After the applicable retention period, data is permanently deleted from all systems.
Third parties and data sharing
Personal data is never sold, rented, or shared with third parties for marketing purposes. Data may be processed by the following service providers as part of operating this site:
| Service | Purpose | Location |
|---|---|---|
| GoHighLevel (GHL) | CRM. Stores contact records and session notes. | United States (SCCs in place) |
| Stripe | Payment processing. Operates under its own privacy policy. | United States (SCCs in place) |
| Calendly | Session booking. Processes name and email to confirm appointments. | United States (SCCs in place) |
SCCs refers to Standard Contractual Clauses — the EU-approved mechanism for lawful data transfers to countries outside the EEA. Each provider listed above operates under their own privacy policy and is contractually bound to handle data only as instructed.
Your rights
Under GDPR and equivalent regulations, you have the following rights regarding your personal data:
To exercise any of these rights, contact desislava@penkova.outlook.com. Requests are responded to within 30 days. If you believe your data has been mishandled, you have the right to lodge a complaint with your national data protection authority.
Cookies and tracking
This site does not use advertising cookies, tracking pixels, or third-party analytics. No cookie consent banner is required because no non-essential cookies are set.
Session functionality may use strictly necessary cookies to maintain state across pages. These cookies are not used to identify you across sites and do not require consent under GDPR.
Changes to this policy
This policy may be updated when services or data practices change. The date at the top of this page reflects the most recent revision. Material changes will be communicated directly to active clients by email.
Questions about this policy?
Contact: desislava@penkova.outlook.com
Response within 2 business days.