kvdd.eu

Privacy Policy

Version 2.2 · last updated 16 July 2026

Confidentiality is the substance of this practice, not a footnote to it. This policy explains exactly what happens to information you provide through this website or during an engagement — what is collected, why, on what legal basis, who else can see it, how long it is kept, and what you can require of me. It is written to be read, not to be survived.

At a glance

01Who is responsible

The controller of personal data processed through this website is Kanstantsin Vaitsakhouski, an independent consultant trading as kvdd.eu, providing technical due diligence and feasibility assessments for AI and computer-vision systems.

Contact for any privacy matter, including requests to exercise your rights: kanstantsin@kvdd.eu. I answer these personally. No data protection officer is appointed, as the scale and nature of the processing does not require one.

02Scope

This policy covers the website at kvdd.eu (including its subpages), the request and intake forms it hosts, and correspondence and materials exchanged during an engagement. It does not cover third-party websites that may be linked from here; if you follow a link elsewhere, that site's own policy applies.

03What is collected, why, and on what legal basis

There are only three situations in which any personal data is processed at all.

a. Simply visiting the website

The web server records a standard technical log entry for each request: your IP address, the time, the page requested, the HTTP status, and the browser's user-agent string. This is the ordinary operation of a web server, not analytics — it is not linked to you, not profiled, and not used to build any picture of your behaviour. It exists so that the site can be kept secure and working.

Legal basis — Art. 6(1)(f) GDPR, legitimate interests: operating and securing the service, diagnosing faults, and defending against abuse.

These logs are automatically rotated and deleted after 14 days. Beyond this, the website itself keeps nothing: no cookies, no local storage, no session identifiers, no analytics or advertising scripts, no social plugins, and no third-party fonts or embeds.

b. Sending a request or completing the intake questionnaire

If you use a form on this site, I receive what you chose to put in it — typically your name, email address, company, role, and your description of the decision, system or problem at hand, along with any reference links you add. The intake questionnaire additionally records your answers about the engagement, and your NDA and authorisation selections.

This information is used for one purpose: to understand and answer your request, and to scope the work if it proceeds. It is relayed to me by email and is not stored in any database, ranked, enriched, or used for marketing. You are also sent a copy of your own submission, for your records.

Legal basis — Art. 6(1)(b) GDPR, steps taken at your request prior to entering into a contract; and Art. 6(1)(f), legitimate interests in responding to business correspondence.

To keep the form from being abused, the service applies a rate limit per IP address and a hidden anti-bot field. The IP address used for rate limiting is held transiently in memory and is not written to any store or attached to your message.

Providing this information is entirely voluntary. It is not a statutory requirement and you are under no contractual obligation to supply it. The practical consequence is the only one: your name, a working email address and some description of what you need are necessary for me to reply at all, and to scope the work if it proceeds. Withhold them and I simply cannot respond — nothing else follows from it.

Please do not send confidential material through the form. It exists to scope the work; a short description is enough at that stage. If an NDA should be in place before you share anything meaningful, say so on the first step of the questionnaire and no details are transmitted.

c. During an engagement

If we work together, you may send me documents, data, code, model artefacts or other materials so that I can assess them. These may contain personal data, and in some fields may contain special categories of data. What is shared, and on what terms, is agreed between us in advance and governed by the NDA and the engagement terms.

Legal basis — Art. 6(1)(b) GDPR, performance of the contract with you. Where materials contain personal data belonging to third parties, you remain the controller of that data and I act as your processor, on your documented instructions.

Where I act as your processor, that relationship is put on a written footing: a data processing agreement satisfying Article 28(3) GDPR is concluded alongside the NDA, setting out the subject matter and duration of the processing, its nature and purpose, the categories of data and data subjects, and my obligations — to process only on your documented instructions, to keep the data confidential, to apply appropriate security, to engage no further processor without your authorisation, to assist you with data-subject requests and security obligations, and to delete the material at the end of the engagement. I am happy to sign yours or to provide one.

Some materials — medical images being the obvious case — may contain special categories of personal data within the meaning of Article 9 GDPR. Establishing a lawful basis for those categories, and for disclosing them to me, remains yours as controller; I process them solely for the purpose of the assessment you commissioned and for no other purpose. Where the material can be anonymised or pseudonymised without damaging the assessment, that is always the better course, and I will say so.

04Cookies and tracking

There are none. This site sets no cookies, uses no local or session storage, registers no service workers, runs no analytics package, embeds no social or video players, and loads no resources from any other domain. There is no consent banner here because there is nothing to consent to.

This is a deliberate design decision rather than an oversight: the fonts used on this site are hosted on this server precisely so that visiting a page about confidential work does not quietly disclose your IP address to a font provider.

05Who else is involved

The practice is deliberately small, and so is the list of companies that can technically touch your information. There are two, both bound by their own data processing terms:

ProviderRoleWhat it can see
DigitalOcean Server hosting for kvdd.eu The server and its logs. Located in Frankfurt, Germany (EU).
Zoho Corporation
(ZeptoMail)
Transactional email delivery and mailbox for kanstantsin@kvdd.eu The content of messages sent to and from the site, as any email provider necessarily does. Operated on EU data-residency infrastructure.

That is the complete list. There are no analytics vendors, no CRM, no marketing platform, no advertising networks, no chat widgets, and no AI service that receives your submissions. Your information is never sold, rented, or shared for anyone else's purposes.

Beyond these, information may be disclosed only where I am legally compelled to do so — for instance by a binding order from a competent authority — or where it is necessary to establish, exercise or defend a legal claim.

06Where your data is processed

All personal data processed in connection with this website and with engagements is stored and processed within the European Union.

The server is located in Frankfurt, Germany. Email for kvdd.eu is operated on EU data-residency infrastructure. The assessment work itself is carried out within the EU.

No personal data is transferred to a third country or to an international organisation outside the European Union or the EEA. As there is no such transfer, the Chapter V GDPR transfer mechanisms — adequacy decisions, standard contractual clauses, binding corporate rules — are not engaged.

Were this ever to change, this policy would be updated before the change took effect, and anyone with an active engagement would be told directly rather than left to notice.

07How long anything is kept

WhatKept for
Server access logs14 days, then deleted automatically.
Rate-limiting IP dataTransient, in memory only. Not persisted.
Enquiries that do not become engagementsOnly as long as needed to deal with the enquiry, then deleted.
Client materials from an engagementDeleted no later than one business week after final payment for that engagement.
My copy of the delivered reportKept as a professional record of the work performed, for no longer than the limitation period applicable to claims arising out of the engagement, after which it is deleted. Destroyed earlier on request.
Invoices and accounting recordsAs required by applicable tax and accounting law.
Legal basis for retaining the report copy — Art. 6(1)(f) GDPR, legitimate interests: maintaining a record of professional work and the ability to establish or defend legal claims. Legal basis for accounting records — Art. 6(1)(c), compliance with a legal obligation.

If you would prefer that my copy of the report be destroyed as well, ask, and it will be.

08Confidentiality

Everything about a client is treated as confidential: their identity, their contact details, their business, their projects, their technology and their direction. I do not name clients, do not publish case studies about identifiable engagements, and do not use anyone's work as a reference without their explicit permission. Where I write publicly about technical patterns, the material is general and is not drawn from any identifiable client's system.

An NDA is signed before any substantive materials change hands — yours, or a mutual one I provide. Confidentiality obligations survive the end of the engagement and are not time-limited by this policy.

09Security

The measures in place are proportionate to a practice of this size and to the sensitivity of what is handled:

No system is perfectly secure, and I would rather say so than imply otherwise. If you become aware of a vulnerability in this site, please tell me at kanstantsin@kvdd.eu — it will be taken seriously and fixed.

10Your rights

Under the GDPR you have the right to:

Your right to object (Article 21 GDPR). Separately from the rights above, and brought to your attention explicitly: where processing is based on my legitimate interests — which here means the server logs and the handling of business correspondence — you have the right to object at any time, on grounds relating to your particular situation. If you object, I must stop processing that data unless I can demonstrate compelling legitimate grounds which override your interests, rights and freedoms, or the processing is needed to establish, exercise or defend legal claims. To object, write to kanstantsin@kvdd.eu. No direct marketing is carried out from this site, so there is nothing here to object to on that ground.

To exercise any right, email kanstantsin@kvdd.eu. There is no charge. I will respond within one month of receiving the request; where a request is particularly complex, or where several have been made, that period may be extended by a further two months, in which case I will tell you about the extension and the reason for it within the first month. In practice, given how little is held, these are usually answered in a day or two.

Where I have reasonable doubts about who is making a request, I may ask for information needed to confirm your identity before acting on it. This is a protection for you, not an obstacle: it prevents someone else obtaining your data by asking for it.

11Complaints

If you believe your data has been handled improperly, please raise it with me first — it is usually the fastest route to a fix. You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU or EEA country where you live, where you work, or where the alleged infringement took place. Exercising that right does not depend on contacting me first.

12Automated decision-making

There is none. No automated decision-making or profiling with legal or similarly significant effects takes place. Engagements are assessed and written by a person — that is the entire point of the service.

13Changes to this policy

If this policy changes, the version number and date at the top of the page change with it. Material changes affecting an active engagement will be communicated to you directly rather than left for you to discover.

14Contact

Questions about this policy, your data, or anything above: kanstantsin@kvdd.eu.