PRIVACY POLICY

Privacy.

How Eywa Solutions handles personal data on this site and across the services we build. A self-employed undertaking registered in Malta. GDPR-aware by default.

1. Who we are

This site (eywasolutions.net) is operated by Svitlana Lytvyniuk, trading as Eywa Solutions, a self-employed undertaking registered in Malta, VAT registration number 3291-8006 (Article 11 — small undertaking, exempt), with business address at Manor Heights, Triq Charles Sciberras, St. Julian's, STJ 1143, Malta.

We act as data controller for personal data collected through this website. For client engagements, the data-controller / data-processor relationship is documented separately in each engagement contract.

2. What we collect on this website

This site keeps a consent banner in front of anything beyond what's strictly necessary to run it. Nothing in the "with your permission" bullet below runs, and no cookie it would set is placed, until you actively choose to allow it — declining is exactly as easy as accepting, and you can change your mind at any time via the "Cookie preferences" link in the footer.

We will update this section the first time we add any further tool that processes personal data on the marketing site.

3. Why we collect it

The only personal data we collect via this website is what you actively send us — an enquiry form, an email, or a booked discovery call. We use it to:

Lawful basis: Article 6(1)(b) GDPR (steps taken at the request of the data subject prior to entering into a contract) or Article 6(1)(f) GDPR (legitimate interest in responding to inbound enquiries), as applicable.

The analytics and marketing cookies described in section 2 are processed on a different basis entirely: Article 6(1)(a) GDPR (your explicit, granular consent, given or withheld per category through the cookie banner). We use them to understand which pages and services on this site are actually useful, and to measure whether Google/Meta ad spend converts into booked calls. Withdrawing consent at any time stops that processing going forward.

4. Who else processes your data

When you interact with the site or the services it links to, the following data processors may receive your data:

VERCEL
Hosting (static HTML). EU regions configured (Frankfurt).
CLOUDFLARE
DNS, CDN, edge security. Global, with EU edge presence.
CLOUDFLARE TURNSTILE
Bot-verification widget on the /vr, /automation, and /concierge forms. Runs without setting cookies.
CAL.COM
Booking infrastructure behind the calendar embedded at /book. Cal.com's own privacy terms apply to the booking data (name, email, notes) they process.
GOOGLE WORKSPACE
Email infrastructure for [email protected].
SUPABASE
Database infrastructure. Enquiry and quote-request records are stored here.
MAKE.COM
Workflow automation (EU zone). Routes each enquiry to our client-relationship records and triggers the emails you request.
AIRTABLE
Client-relationship records for enquiries and quotes.
ANTHROPIC
When you book a discovery call, your booking answers are processed via the Anthropic API to prepare an internal call brief. This may include a small number of web searches, run by Anthropic on our behalf, to research your publicly listed company details. API inputs are not used to train models.
GOOGLE ANALYTICS (GA4)
Traffic and conversion analytics — only if you accept the Analytics cookie category. Categories of data: pages viewed, approximate location (IP-derived, not stored precisely), device/browser type, and the enquiry/booking events described in section 2. Legal basis: consent. See Google's privacy policy.
META PIXEL
Ad performance measurement and retargeting audiences for Meta (Facebook/Instagram) ads — only if you accept the Marketing cookie category. Categories of data: pages viewed and the enquiry/booking events described in section 2. Legal basis: consent. See Meta's privacy policy.

Each of these processors operates under its own privacy terms. We do not sell or share your data with marketing networks, ad networks, or any third party not listed here.

5. International transfers

Where a processor (e.g. Google Workspace, Airtable, Anthropic) involves transfer of personal data to a third country, we rely on the relevant adequacy decisions or standard contractual clauses published by the European Commission.

6. How long we keep it

Email correspondence and enquiry records are retained for 24 months following the last contact, for tax, accounting, and contract-history purposes. Records relating to a concluded engagement are retained for the period required by Maltese tax and accounting law. Booked call records on cal.com are subject to cal.com's retention terms. Your cookie consent choice is remembered for up to 6 months, after which the banner will ask again; Google Analytics and Meta Pixel cookies follow each provider's own default retention (typically up to 13 months for GA4, up to 90 days for the Meta Pixel's _fbp), and stop being set entirely the moment you withdraw consent.

7. Your rights

Under the GDPR, you have the right to:

To exercise any of these rights, email [email protected]. We respond within one calendar month, extendable by two further months for complex requests (we will tell you if that applies).

8. Supervisory authority

The supervisory authority for data protection in Malta is the Information and Data Protection Commissioner (IDPC). You have the right to lodge a complaint with the IDPC if you believe we have not handled your personal data correctly.

9. Updates

We update this policy when our data processing changes — for example, when we add a new processor. Version 1.3 · Last updated: 2026-08-22.

10. Contact

For any privacy-related question: [email protected].