Privacy Policy

Last updated: June 28, 2026

1. Who We Are

We are a team of freelance specialists offering AI SEO, workflow automation, AI agents, and data-driven marketing solutions. We engage clients via the Upwork marketplace at upwork.com. This Privacy Policy applies to personal data collected through this informational website only. For services contracted through Upwork, Upwork's own Privacy Policy also applies.

You may contact us at: info@retarga.org

2. What Data We Collect

2.1 Information You Provide Directly

• Name
• Email address
• Website URL (optional)
• Service interest and any message or comments submitted via the contact form

2.2 Automatically Collected Data

• IP address and approximate geolocation (country/city level) — processed by Cloudflare as part of infrastructure delivery and security
• Browser type and version
• Pages visited and time spent
• Referral source
• Cookie consent status, stored and managed by Cookiebot

2.3 Data We Do NOT Collect

• Payment or financial information (all payments are processed by Upwork)
• Sensitive personal data categories (health, religion, ethnicity, etc.)
• Data from children under 16 years of age — we do not knowingly collect such data

3. Legal Basis for Processing (GDPR — Art. 6)

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

• Consent (Art. 6(1)(a)) — when you voluntarily submit our contact form or accept non-essential cookies via the Cookiebot banner
• Legitimate interests (Art. 6(1)(f)) — for security purposes (Cloudflare DDoS protection), basic website functionality, and abuse prevention
• Contract performance (Art. 6(1)(b)) — when you engage with us for services through Upwork

4. How We Use Your Data

• To respond to your enquiries submitted via the contact form
• To route qualified leads to our Upwork profile for formal service engagement
• To send email replies via Zoho Mail (our email service provider)
• To maintain website security and performance via Cloudflare
• To manage cookie consent via Cookiebot
• To comply with applicable legal obligations

We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects.

5. Third-Party Service Providers & Data Sharing

We do not sell your personal data. We engage the following third-party processors, each operating under their own privacy policies:

• Upwork Inc. (USA) — contract management, payments, and project communications. Upwork Privacy Policy
• Zoho Mail / Zoho Corporation — email delivery of contact form responses. Zoho Privacy Policy
• Cloudflare, Inc. (USA) — website hosting, CDN, and security (DDoS protection). Your IP address may be processed by Cloudflare. Cloudflare Privacy Policy
• Cookiebot / Usercentrics A/S (Denmark) — consent management platform for cookie compliance. Cookiebot Privacy Policy
• Legal authorities — only when required by applicable law or court order

6. Data Retention

• Contact form submissions are retained in Zoho Mail for a maximum of 12 months, unless a business relationship is established
• If a client relationship begins via Upwork, data is retained for the duration of the relationship plus 3 years for legitimate business records
• Cookie consent records (Cookiebot) are retained for 12 months per consent event
• Cloudflare access logs are retained per Cloudflare's retention schedule

7. Your Rights Under GDPR (EEA & UK Residents)

If you are located in the European Economic Area (EEA) or United Kingdom, you have the following rights under GDPR (Regulation 2016/679):

• Right of access (Art. 15) — request a copy of the data we hold about you
• Right to rectification (Art. 16) — ask us to correct inaccurate data
• Right to erasure (Art. 17) — request deletion of your data ("right to be forgotten")
• Right to restriction (Art. 18) — ask us to limit how we process your data
• Right to data portability (Art. 20) — receive your data in a machine-readable format
• Right to object (Art. 21) — object to processing based on legitimate interests
• Right to withdraw consent (Art. 7(3)) — at any time, without affecting prior lawful processing

To exercise these rights, contact us via our contact form or at info@retarga.org. We will respond within 30 calendar days.

8. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know, delete, and opt out of the sale of personal information. We do not sell personal information. To exercise your rights, contact us at info@retarga.org.

9. International Data Transfers

Some of our third-party providers (Upwork, Cloudflare, Zoho) are based in or process data in the United States. Such transfers are carried out under appropriate safeguards, including:

• EU Standard Contractual Clauses (SCCs) per Commission Decision 2021/914/EU
• Upwork's participation in the EU-U.S. Data Privacy Framework
• Cloudflare's data processing addendum with GDPR safeguards

10. Security

We implement appropriate technical and organisational measures to protect your personal data, including HTTPS encryption (via Cloudflare), restricted access to contact form data, and use of reputable third-party processors with their own security certifications. However, no internet transmission is 100% secure.

11. Cookies & Consent Management

We use Cookiebot to manage cookie consent in compliance with the EU ePrivacy Directive and GDPR. Non-essential cookies are only placed after you provide explicit consent via the cookie banner. See our Cookie Policy for full details.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top reflects the most recent revision. Continued use of the website after changes constitutes acceptance of the updated policy.

13. Contact & Supervisory Authority

For any privacy-related questions or to exercise your rights, please reach us via our contact form or at info@retarga.org. You may also contact our team through our Upwork profile.

You have the right to lodge a complaint with your local supervisory authority. A list of EU data protection authorities is available at edpb.europa.eu.