Legal
Privacy Policy
This policy explains what personal data is collected through sbadalian.com, why it is collected, who it is shared with, and what you can do about it. It covers the contact form, the AI chat assistant and the tracking tags on this site.
1. Who is responsible for your data
The controller of your personal data is Sergei Badalian, an independent Google Ads and Meta Ads consultant.
- Address: Osiedle Władysława Jagiełły 22A, 60-694 Poznań, Poland
- Email: sbadalian@sbadalian.com
There is no data protection officer: the business is a sole proprietorship and is not required to appoint one. Write to the address above with any privacy question and it reaches the controller directly.
2. What is collected, why, and on what legal basis
| Data | Purpose | Legal basis (GDPR) | Kept for |
|---|---|---|---|
| Contact form: your name, monthly ad budget range, and the contact you give (phone, Telegram or WhatsApp) | To answer your enquiry and prepare a proposal | Art. 6(1)(b), steps taken at your request before a contract | 24 months from the last contact, then deleted |
| Chat messages you type into the assistant, and any contact details you share in the chat | To answer your questions and, if you ask for it, to pass your enquiry on | Art. 6(1)(b) and Art. 6(1)(f), legitimate interest in responding to enquiries | Conversation state expires with your browser session; the copy sent to the owner is kept for 24 months |
| IP address | Rate limiting, to stop automated abuse of the chat | Art. 6(1)(f), legitimate interest in keeping the service available | 70 seconds |
| Cookies and identifiers set by Meta, Google, TikTok tags, and the Facebook Conversions API event sent when you submit an enquiry (which contains a one-way hash of your contact detail and name, your IP and browser user agent) | Measuring which campaigns bring enquiries, and retargeting | Art. 6(1)(a), your consent, given through the cookie banner and withdrawable at any time | Per each provider's own retention, see their policies linked below |
Giving your data is entirely voluntary. You do not need to provide anything to read this site. If you do not fill in the form or the chat, there is simply no way to reply to you.
3. The AI chat assistant
The chat on this site is an AI assistant, not a human. A real person, Sergei, can join the conversation, and when that happens the chat says so on screen.
What you type is sent to Google (Gemini API) to generate the reply. The conversation, plus anything you volunteer, is forwarded to the owner's private Telegram account so your enquiry is not missed. Nothing you type is used to train AI models by us, and no decision with a legal or similarly significant effect on you is made automatically.
Please do not paste passwords, payment details, health information or anyone else's personal data into the chat. If you would rather not use it, email or message instead: the contact options are in the footer of the main page.
4. Who your data is shared with
Your data is never sold, rented, or pooled with other clients' data. It is shared only with the service providers needed to run this site and reply to you:
- Cloudflare, Inc.: hosting, the chat backend and abuse protection. Privacy policy
- Google LLC: the Gemini API that generates chat replies, and, with your consent, Google Analytics, Google Ads and Google Tag Manager. Privacy policy
- Telegram FZ-LLC: delivery of your enquiry to the owner. Privacy policy
- Meta Platforms, Inc.: with your consent, the Meta Pixel and the Conversions API. Privacy policy
- TikTok: with your consent, the TikTok Pixel, if enabled. Privacy policy
5. Transfers outside the European Economic Area
Cloudflare, Google, Meta and TikTok are based in the United States, and your data may be processed there. Those transfers rely on the European Commission's adequacy decision for the EU-US Data Privacy Framework where the provider is certified under it, and otherwise on the Commission's Standard Contractual Clauses. Telegram operates outside the EEA and transfers to it rely on Art. 49(1)(b) GDPR, because sending your enquiry there is what makes it possible to reply to you. You can always avoid that by using email instead of the chat.
6. Your rights
Under the GDPR you can ask to access your data, have it corrected or deleted, have its processing restricted, receive it in a portable format, and object to processing based on legitimate interest. Where processing rests on consent, you can withdraw it at any time, which does not affect what was done before you withdrew.
To exercise any of these, email sbadalian@sbadalian.com. You will get an answer within one month. You also have the right to complain to the Polish supervisory authority, the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl.
7. Cookies and similar technologies
Strictly necessary storage is used to keep the chat working and to remember your cookie choice; it is not used to profile you and does not require consent. Everything else, the Meta, Google, GA4, Tag Manager and TikTok tags, loads only after you press "Accept all" in the cookie banner. Choosing "Essential only" means none of them are ever loaded.
To change your mind, clear this site's data in your browser settings; the banner will appear again on your next visit and you can choose differently. You can also block or delete cookies in your browser at any time.
8. Do Not Track
Some browsers send a "Do Not Track" signal. There is no agreed industry standard for how sites should respond to it, and this site does not currently change its behaviour in response to it. Your cookie banner choice is what governs whether any tracking tag loads.
9. Notice for California residents
In the past twelve months this site has collected the categories of personal information described in section 2: identifiers (name, phone number, messenger handle, IP address), commercial information (the budget range you select), and internet activity (interaction with this site through the tags listed in section 4). It is collected for the business purposes in section 2 and shared with the providers in section 4.
Personal information is not sold. Advertising cookies are only ever set with your consent, and you can decline them without losing access to anything on this site. California residents may request access to or deletion of their personal information by emailing sbadalian@sbadalian.com; requests are handled the same way as the rights in section 6.
10. Security
Traffic to this site is encrypted with HTTPS. Access to enquiries is limited to the controller. API keys and other credentials are held as encrypted secrets and are never exposed to your browser.
11. Changes to this policy
If this policy changes, the new version is published on this page and the effective date at the top is updated. Material changes affecting how your data is used will be described in a short note at the top of this page for at least thirty days.