1. Who this policy covers

This Privacy Policy applies to yankagolemin.com (the “Site”), operated by Yanka Golemin, trading as an individual provider of private advisory services (“I”, “me”, “my”). I am the data controller for personal information processed in connection with the Site.

This policy explains what personal information is collected when you visit or interact with the Site, how it is used, and the rights you have over it. It applies regardless of where you are located, including visitors and prospective clients based in the United Kingdom, the European Union, the United States, and elsewhere.

2. What information is collected

The Site is intentionally minimal. It does not use contact forms, account creation, newsletter sign-ups, or e-commerce functionality. The categories of personal information that may be collected are limited to the following.

Information you provide directly

• Your name, email address, and any other information you choose to include when you contact me by email at counsel-inquiry@yankagolemin.com
• The contents of any message you send, including any details you choose to share about your situation

Information collected automatically

• Basic visit data, including approximate location (derived from IP address), device and browser type, pages visited, and time spent on the Site, collected through a privacy-conscious analytics tool
• I do not collect precise location data, and I do not use the Site to build advertising profiles

3. How information is collected

Information is collected in two ways: directly, when you send an email; and automatically, through analytics technology embedded in the Site, as described in Section 11 (Cookies and Analytics).

I do not purchase, rent, or otherwise acquire personal information about you from third parties for use in connection with the Site.

4. Legal basis for processing

Where UK GDPR or EU GDPR applies, personal information is processed on the following legal bases:

• Legitimate interests — for basic analytics that help me understand how the Site is used, and to respond to correspondence sent to me
• Consent — for any non-essential cookies, where applicable, as described in Section 11
• Contract or pre-contractual steps — where you contact me regarding a potential advisory engagement, to the extent information is used to assess and respond to that inquiry

If you are located outside the UK or EU, I apply the same standard of care to your information regardless of the specific local legal framework that may apply.

5. How information is used

Personal information is used only for the following purposes:

• To respond to inquiries sent by email
• To assess whether a potential advisory engagement is appropriate
• To maintain the confidential record of any ongoing client relationship
• To understand, in aggregate and non-identifying terms, how visitors use the Site
• To meet legal, regulatory, or professional obligations where applicable

I do not use information collected through the Site for marketing purposes, do not sell personal information, and do not share it for the marketing purposes of others.

6. Sharing and disclosure

Given the confidential nature of this practice, information is shared only in narrow circumstances:

• With service providers who support the technical operation of the Site (such as hosting and analytics providers), under obligations of confidentiality and data protection
• Where required by law, regulation, or a valid legal process
• To protect my rights, safety, or property, or that of others, where genuinely necessary

I do not disclose the existence or content of any client relationship to third parties, except as required by law or with the client’s explicit consent.

7. International transfers

Because the Site is accessed internationally and may use service providers located outside your home jurisdiction, your information may be transferred to and processed in countries other than your own, including the United Kingdom and the United States. Where such transfers occur from the UK or EU, I take reasonable steps to ensure an adequate level of protection, including reliance on recognised legal mechanisms such as standard contractual clauses where applicable.

8. Data retention

Correspondence and any related information are retained only for as long as necessary to respond to your inquiry, maintain an ongoing professional relationship, or meet legal and professional obligations — whichever is longer. Where information is no longer needed for these purposes, it is deleted or anonymised.

Analytics data is retained in accordance with the retention settings of the analytics provider used, and is not retained indefinitely.

9. Security

I take reasonable technical and organisational measures to protect personal information against unauthorised access, loss, or misuse, appropriate to the sensitivity of the information involved. No method of transmission or storage is entirely secure, and I cannot guarantee absolute security, but confidentiality is treated as a core operating principle of this practice, not merely a legal obligation.

10. Your rights

Depending on your location, you may have some or all of the following rights in relation to your personal information:

• The right to be informed about how your information is used
• The right to access the personal information held about you
• The right to request correction of inaccurate information
• The right to request deletion of your information, in certain circumstances
• The right to object to or restrict certain processing
• The right to request a copy of your information in a portable format
• The right to withdraw consent, where processing is based on consent

To exercise any of these rights, contact me using the details in Section 14. I will respond within the timeframe required by applicable law. If you are in the UK or EU and are not satisfied with my response, you have the right to lodge a complaint with your local data protection authority — in the UK, the Information Commissioner’s Office (ICO).

11. Cookies and analytics

The Site uses a limited set of cookies and similar technologies to support basic analytics — understanding, in aggregate, how many people visit the Site and which pages they read. This is used solely to inform decisions about the Site’s content and structure.

The Site does not use advertising cookies, retargeting pixels, or third-party tracking for marketing purposes. Further detail on the specific cookies used, their purpose, and how to manage your preferences is available in the Cookie Policy.

12. Children’s data

This Site and the services described on it are intended for use by adults in a professional capacity. I do not knowingly collect personal information from anyone under the age of 18. If you believe a child has provided personal information through the Site, please contact me so it can be removed.

13. Changes to this policy

This policy may be updated from time to time to reflect changes in practice, technology, or legal requirements. The “Last updated” date at the top of this page indicates when it was last revised. Material changes will be reflected here; continued use of the Site after changes are posted constitutes acceptance of the updated policy.

14. Contact

Questions about this Privacy Policy, or requests relating to your personal information, can be directed to:

counsel-inquiry@yankagolemin.com