Privacy Policy

Effective date: 18 December 2025 | Last updated: 18 December 2025

1. Who we are

PHPP ("we", "us", "our") is a structure-and-governance engineering firm that provides website architecture, SEO governance, and operational software services.

Data Controller: PHPP
Contact: privacy@phpp.eu
Website: https://phpp.eu

2. What data we collect

2.1 Data you provide directly

• Contact form submissions: name, email address, company name, message content
• Email correspondence: email address, name, content of communications
• Client engagements: business information necessary to deliver our services

2.2 Data collected automatically

• Server logs: IP address, browser type, pages visited, timestamps (retained for security purposes)
• Cookies: Essential cookies only — see our Cookie Policy

2.3 Data we don't collect

• We don't use advertising or marketing tracking pixels
• We don't use social media tracking widgets
• We don't sell or share data with third-party advertisers
• We don't build profiles for targeted advertising

3. How we use your data

We use your personal data for the following purposes:

• To respond to enquiries: When you contact us, we use your details to reply
• To deliver services: If you become a client, we use necessary data to fulfil our engagement
• To improve our website: Anonymous, aggregated analytics to understand site usage
• To comply with legal obligations: Where required by law

4. Legal basis for processing (GDPR)

Under the General Data Protection Regulation (GDPR), we process your data based on:

• Consent: When you submit a contact form or opt in to communications
• Contractual necessity: When processing is required to deliver services you've engaged
• Legitimate interests: For security, fraud prevention, and improving our services (balanced against your rights)
• Legal obligation: Where we're required to retain data by law

5. Data sharing

We don't sell your data. We may share data with:

• Service providers: Hosting, email delivery, and essential business tools (under data processing agreements)
• Professional advisors: Legal, accounting, where necessary
• Legal authorities: If required by law or to protect our rights

Any third parties we work with are required to handle your data in accordance with GDPR.

6. International transfers

Your data may be processed outside the European Economic Area (EEA). Where this occurs, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or adequacy decisions.

7. Data retention

• Contact form submissions: Retained for 2 years unless you become a client
• Client data: Retained for 7 years after engagement ends (legal/accounting requirements)
• Server logs: Retained for 90 days

You can request earlier deletion where no legal retention requirement applies.

8. Your rights

Under GDPR, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Request we limit processing of your data
• Portability: Request your data in a portable format
• Object: Object to processing based on legitimate interests
• Withdraw consent: Where processing is based on consent

To exercise any of these rights, contact us at privacy@phpp.eu. We will respond within 30 days.

9. Security

We implement appropriate technical and organisational measures to protect your data, including:

• HTTPS encryption on all pages
• Secure hosting with reputable providers
• Access controls and authentication
• Regular security reviews

10. Complaints

If you're unhappy with how we've handled your data, please contact us first at privacy@phpp.eu.

You also have the right to lodge a complaint with a supervisory authority. For Cyprus, this is the Commissioner for Personal Data Protection: www.dataprotection.gov.cy

11. Changes to this policy

We may update this policy from time to time. Significant changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically.

12. Contact

For privacy-related questions or to exercise your rights:

Email: privacy@phpp.eu
Website: Contact form