# Privacy Policy (v3) **Last Updated:** May 2026 This Privacy Policy explains how personal data and technical data are handled when you visit euchresisdata.com (the "Site"). The Site is operated by Paolo Sebastianelli, with registered office in Wollongong, New South Wales, Australia ("we", "us", "our", or the "Company"). We aim to follow Privacy by Design and data minimisation principles. ## 1. Scope and Role This Privacy Policy applies to the Site and to any voluntary contact made through the channels listed on the Site. For privacy purposes, the Company acts as the data controller for information collected or received in connection with the Site, subject to any separate role that a third-party provider may hold for its own services. ## 2. Personal Data We Do Not Directly Collect We do not provide account creation, newsletter sign-up, or contact-form submission on the Site. We do not intentionally ask visitors to provide personal data through interactive forms on the Site. Browsing the Site does not require you to identify yourself. ## 3. Technical Data and Infrastructure Like most websites, the Site may involve limited technical processing necessary for hosting, delivery, security, and performance. This may include data such as IP address, device and browser information, approximate location derived from network data, access time, request logs, and security-related telemetry. We rely on third-party infrastructure providers such as GitHub and Cloudflare. Those providers may process technical data on our behalf or for their own operational and security purposes, according to their respective terms and privacy notices. ## 4. Purposes and Lawful Bases We use or receive information for the following purposes: - to host and deliver the Site, - to keep the Site secure and resilient, - to diagnose technical issues, - to respond to voluntary contact, - to comply with legal obligations, and - to establish, exercise, or defend legal claims where necessary. Where applicable, our lawful bases include: - legitimate interests in operating a secure and reliable website, - performance of a contract or steps taken at your request before entering into a contract, - compliance with legal obligations, - consent, where consent is required and separately requested, - and, where relevant under local law, other lawful bases recognized by the applicable jurisdiction. ## 5. Voluntary Contact If you contact us by email or phone using details listed on the Site, we may receive your name, email address, phone number, organization name, and any information you choose to provide. We use that information only to review, process, and respond to your inquiry, and where appropriate to keep a record of the communication for business, compliance, or legal purposes. ## 6. Cookies and Similar Technologies The Site is intended to operate without marketing, profiling, or advertising cookies. Depending on the infrastructure in use, limited technical cookies or similar technologies may be used by hosting, security, or delivery providers for essential functionality, abuse prevention, or performance purposes. If we introduce analytics or other non-essential tracking in the future, we will update this Privacy Policy and, where required, provide the appropriate notice or obtain consent before those tools are activated. ## 7. Data Sharing and Disclosures We may share information with: - hosting and security providers, - email or communications providers, - professional advisers, - authorities where required by law, - and third parties involved in a legal dispute or compliance review. We do not sell personal data. ## 8. International Transfers Because the Site uses global infrastructure and may be accessed from multiple jurisdictions, your information may be processed or stored outside your country of residence, including in Australia, the United States, the European Economic Area, or other countries where our providers operate. Where required by law, we will take reasonable steps to ensure appropriate safeguards are in place for cross-border transfers. ## 9. Retention We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to comply with legal, tax, accounting, recordkeeping, or dispute-resolution obligations. Retention periods vary depending on the type of information and the reason it was received. ## 10. Security We use reasonable technical and organizational measures designed to protect information against unauthorized access, loss, misuse, or disclosure. No internet-based service can be guaranteed to be completely secure, and you use the Site at your own risk. ## 11. Your Rights Depending on where you live, you may have rights to access, correct, delete, restrict, object to, or port certain personal data, and to withdraw consent where consent was used as the lawful basis. If you are in the EU/EEA, UK, Australia, or certain LATAM jurisdictions, additional mandatory rights may apply under local law. If you want to exercise a right, contact us using the details in the Site footer or the contact channel listed on the Site. We may need to verify your identity before acting on your request. ## 12. Children The Site is intended for business and professional audiences and is not directed to children. We do not knowingly collect personal data from children. ## 13. Third-Party Links and Services The Site may contain links to third-party websites or embedded services. We are not responsible for the privacy practices, security, or content of those third parties. You should review their own notices before using their services. ## 14. Changes to This Policy We may update this Privacy Policy from time to time by posting a revised version on the Site and updating the "Last Updated" date. ## 15. Contact For privacy-related inquiries, contact the Company.