Privacy Policy

Last updated: October 3, 2025

1) Who We Are (Data Controller)

INDIVIDUAL ENTREPRENEUR
SUKHODOLOV YURII SVIATOSLAVOVYCH
Tax ID: 2979909896
Address: Kapitana Kuznetsova Street, Building 114, Apartment 15, Odesa, Odesa Region, 65069, Ukraine
Registration: February 6, 2008, 2 471 000 0000 064553
Phone: +380506242951

This Privacy Policy explains how we collect, use, store and disclose personal data of visitors and clients of https://imfree.school and our lead forms (e.g., Meta Lead Ads).

2) Data We Process

• Identification data: first and last name.
• Contact data: email, phone, country/time zone.
• Application/form data: who is signing up (child/adult), child’s age (if applicable), experience level, lesson duration preference (30/45 minutes), preferred days/times, lesson language, instrument availability, comments.
• Technical/analytical data: cookies, device/browser identifiers, site interaction data (via Google Analytics 4 and similar tools).

3) Sources of Data

• Information you provide directly (site forms, lead forms in social networks).
• Information collected automatically (cookies/analytics).

4) Purposes and Legal Bases

• Service provision & communication: contract performance/pre-contractual steps.
• Marketing communications: consent or legitimate interest.
• Analytics & service improvement: legitimate interest.
• Legal compliance: legal obligation.

5) Meta Lead Forms

Using Meta Lead Ads requires a privacy policy link. This page provides that disclosure.

6) Cookies & Analytics

We use Google Analytics 4 to analyze site usage. If advertising features (Google signals, remarketing) are enabled, we disclose this separately. You can manage cookies via the banner or your browser settings.

7) Data Disclosure

We may share data with:

• IT/cloud service providers (hosting, CRM, email/SMS).
• Analytics and marketing providers (Google, Meta), only as necessary.

8) International Transfers

Transfers outside the EEA/UK (e.g., to the USA) rely on Standard Contractual Clauses (SCCs) and supplementary safeguards where required.

9) Retention Periods

• Application/client data: up to 3 years after last interaction (longer if required by law).
• Marketing contacts: until unsubscribe or consent withdrawal.

10) Your Rights

You have rights to: access, rectification, erasure, restriction, portability, objection (including to marketing), and withdrawal of consent.

11) Children

We only process children’s data via their parents/guardians. The age of digital consent varies (13–16 depending on jurisdiction).

12) Security

We apply TLS encryption, access controls, and data minimization principles.

13) Applicable Law & Supervisory Authority

• In Ukraine: Law of Ukraine “On Personal Data Protection”.
• Supervisory authority: Ukrainian Parliament Commissioner for Human Rights (Ombudsman).
• For EEA/UK: GDPR/UK GDPR applies.

14) Contact

For privacy matters, contact us by phone +380506242951 or via the email provided on the website.

15) Marketing Opt-Out

You can unsubscribe from email/SMS marketing at any time via the “Unsubscribe” link or by request.

16) Updates

We may update this Privacy Policy. The new version will be published on the site with the effective date.

Short English Notice (for UK/EEA)

We (Sukhodolov Yurii, Individual Entrepreneur) act as the data controller for imfree.school. We process your data to provide online piano lessons (contract), perform analytics (legitimate interests), send marketing (consent/legitimate interests), and comply with legal obligations. You have GDPR/UK GDPR rights. Contact: +380506242951.