Privacy Policy

This Privacy Policy explains how Victor Lavrentyev (“we”, “us”, or “our”), operating as Salent (“Salent”, “the Service”), collects, uses, discloses, and protects your personal data when you visit salent.sale or use our services.

1. Data Controller

The data controller responsible for your personal data is:

• Name: Victor Lavrentyev
• Address: Georgia, 0101, Tbilisi, Chughureti district, c. Dadiani Street, 7
• Email: hello@salent.sale

2. Data We Collect

2.1 Data You Provide

When you use our contact form, we collect the following information:

• Name
• Company name
• Email address
• Message content

2.2 Data Collected Automatically

We automatically collect certain data when you visit our website:

• Analytics data via Google Analytics: pages visited, session duration, referral source, device type, approximate location (country/city level)
• reCAPTCHA data via Google reCAPTCHA v3: interaction patterns and risk scores used to protect our forms from spam and abuse
• Technical data: IP address, browser type and version, operating system, screen resolution

3. Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation (GDPR), we process your personal data on the following legal bases:

• Consent (Art. 6(1)(a)): For analytics cookies and marketing communications, where applicable
• Legitimate interest (Art. 6(1)(f)): For processing contact form submissions to respond to your inquiries, and for operating reCAPTCHA to protect our website from abuse
• Contract performance (Art. 6(1)(b)): For processing data necessary to provide our services to you

4. How We Use Your Data

We use the data we collect to:

• Respond to your inquiries submitted through the contact form
• Provide and improve our AI lead generation services
• Analyze website usage to improve user experience
• Protect our website from spam and abuse
• Comply with legal obligations

5. Third-Party Processors

We share your data with the following third-party service providers who process data on our behalf:

• Google Analytics (Google LLC) — website analytics. Google may transfer data to the United States. Google's privacy policy: policies.google.com/privacy
• Google reCAPTCHA v3 (Google LLC) — spam protection. Google's privacy policy: policies.google.com/privacy
• Google Apps Script (Google LLC) — contact form processing and email delivery
• AWS Amplify (Amazon Web Services) — website hosting

6. Data Retention

We retain your personal data as follows:

• Contact form submissions: Up to 24 months, or until you request deletion
• Analytics data: 14 months (Google Analytics default retention period)
• Cookies: See our Cookie Policy for specific retention periods

7. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States, where our third-party processors operate. We rely on the following safeguards:

• EU–US Data Privacy Framework for transfers to certified US organizations
• Standard Contractual Clauses (SCCs) approved by the European Commission

8. Your Rights

Under the GDPR and UK Data Protection Act 2018, you have the following rights:

• Right of access: Request a copy of the personal data we hold about you
• Right to rectification: Request correction of inaccurate data
• Right to erasure: Request deletion of your personal data
• Right to restriction: Request limitation of processing in certain circumstances
• Right to data portability: Receive your data in a structured, commonly used format
• Right to object: Object to processing based on legitimate interest
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time

To exercise any of these rights, contact us at hello@salent.sale. We will respond to your request within 30 days.

You also have the right to lodge a complaint with a supervisory authority, such as the UK Information Commissioner's Office (ICO) or your local data protection authority.

9. California Residents (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

Categories of Personal Information Collected

• Identifiers: name, email address, IP address
• Commercial information: company name, inquiry details
• Internet activity: browsing history, interaction data from Google Analytics

Your CCPA Rights

• Right to know: Request disclosure of personal information collected, used, and shared
• Right to delete: Request deletion of your personal information
• Right to opt-out: Opt out of the sale of personal information
• Right to non-discrimination: We will not discriminate against you for exercising your rights

Do Not Sell My Personal Information

We do not sell your personal information. We do not exchange personal data for monetary consideration.

10. Children's Privacy

Our Service is not directed to individuals under the age of 18. We do not knowingly collect personal data from anyone under 18. If you believe we have collected data from a minor, please contact us at hello@salent.sale, and we will promptly delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy on this page and updating the “Effective date” at the top. We encourage you to review this policy periodically.

12. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

• Email: hello@salent.sale
• Address: Georgia, 0101, Tbilisi, Chughureti district, c. Dadiani Street, 7