Privacy policy

 

Effective Date: 01.12.2025

1. Data Controller

This website is operated by Procreate Project CIC, located at (insert full address).
For any questions regarding this Privacy Policy or the processing of personal data, you may contact us at: (insert email) and/or (insert phone number).
If a Data Protection Officer (DPO) has been appointed, their contact details should be added here: (insert name and contact information).

 

2. Data We Collect

We may collect the following categories of personal data when you use this website:

  • Browsing data: IP address, browser type, operating system, referring URLs, pages visited, time spent on pages, and other technical information.
  • Data provided voluntarily: information you submit via contact forms, registration forms, or similar features (e.g., name, surname, email address, and any additional details requested).
  • Cookies and similar technologies: if used, these may collect technical, analytical, or functional data. See the Cookie Policy (if available).

Data is collected directly from you (via forms) or automatically (via browsing activity and cookies).

 

3. Purpose and Legal Basis of Processing

Your personal data may be processed for the following purposes:

  • To operate, maintain, and improve the website.
  • To respond to user inquiries submitted through forms or contact channels.
  • To perform technical and statistical analysis (e.g., website traffic, performance, and functionality).
  • To comply with legal or regulatory obligations.
  • (Add any additional, site-specific purposes.)

The legal bases for data processing include:

  • Your consent (for form submissions, cookies requiring consent).
  • Legitimate interests of the controller (e.g., ensuring website security, performing basic analytics).
  • Contractual necessity, if applicable.

 

4. Data Retention

Personal data will be retained only for as long as necessary to fulfill the purposes listed above.
Technical and browsing data may be stored for a period appropriate to security, maintenance, and analytics needs (e.g., “up to 24 months,” or another defined period).
After the retention period expires, data will be deleted or anonymized.

 

5. Data Sharing and Third Parties

We do not sell personal data to third parties.

Data may be shared with external service providers acting as data processors, such as:

  • hosting providers
  • analytics or performance monitoring services
  • content management tools or plugins

If the website uses third-party cookies, embedded content, or social media plugins, list each provider and link to their privacy policies.

 

6. International Data Transfers

If personal data is transferred outside the European Economic Area (EEA), such transfers will occur only when appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or other legally approved mechanisms.

 

7. User Rights

Under the GDPR, individuals have the right to:

  • access their personal data;
  • request rectification of inaccurate data;
  • request deletion of their data (“right to be forgotten”);
  • request restriction of processing;
  • object to processing based on legitimate interests;
  • withdraw consent at any time (where consent is the legal basis);
  • receive their data in a structured, commonly used, machine-readable format (“data portability”).

To exercise these rights, contact us using the details provided in Section 1.

 

8. Cookies

If cookies are used, include a link to a separate Cookie Policy or provide details here, specifying:

  • types of cookies used
  • purposes (e.g., functional, analytical, marketing)
  • whether third-party cookies are involved
  • how users can manage or disable cookies

 

9. Data Security

Appropriate technical and organizational measures are implemented to protect personal data from unauthorized access, alteration, disclosure, or destruction.

However, no method of transmission over the Internet is entirely secure, and absolute security cannot be guaranteed.

 

10. Changes to This Privacy Policy

We may update this Privacy Policy periodically.
Any changes will be posted on this page with an updated effective date.
Continued use of the website after such changes constitutes acceptance of the revised policy.

If you want, I can also:

  • tailor the policy specifically to the features of toolkit.procreateproject.com
  • generate a matching Cookie Policy
  • write a Terms & Conditions page