Privacy Policy

This policy explains what personal data The Sniukas Company Sàrl collects when you visit www.sniukas.com or contact us, why we use it, and the rights you have over it.

The site has no forms, user accounts, or payments. We collect personal data in only two situations: when you email us, and when you browse the site with analytics cookies enabled.

Who is responsible for your data

The Sniukas Company Sàrl is the controller of your personal data under the EU General Data Protection Regulation (GDPR).

What we collect

When you email us

If you write to hello@sniukas.com, we receive your name, your email address, and whatever you include in your message.

When you browse the site

If you accept analytics cookies in the cookie banner, HubSpot and Google Analytics record how you use the site. This includes your IP address, browser and device type, the pages you view, how long you stay, the page that referred you, and an approximate location derived from your IP address. If you decline, these cookies are not set.

Fonts

The site loads its fonts from Google Fonts. To deliver them, your browser connects to Google's servers, which receive your IP address. Google states that it does not use this data to build profiles or target ads.

Why we use it and on what legal basis

• Replying to your email and discussing a possible engagement: to take steps at your request before entering a contract (Art. 6(1)(b) GDPR), or our legitimate interest in answering inquiries (Art. 6(1)(f)).
• Analytics, to understand how visitors use the site and improve it: your consent (Art. 6(1)(a)). You can withdraw consent at any time.
• Delivering the site, including fonts and security: our legitimate interest in running a working, secure website (Art. 6(1)(f)).
• Legal obligations, such as keeping business records if we work together: Art. 6(1)(c).

We do not sell your data, and we do not make automated decisions about you that have legal or similarly significant effects.

Cookies

The site uses the following cookies:

Cookie	Provider	Purpose
__hs_cookie_cat_pref	HubSpot	Remembers your cookie choice. Always set, because it is needed to respect that choice.
hubspotutk, __hstc, __hssc, __hssrc	HubSpot	Analytics: recognize returning visitors and count sessions. Set only with your consent.
_ga, _ga_*	Google	Analytics: distinguish visitors and measure site usage. Set only with your consent.

Analytics cookies last up to two years. To change your choice, clear the cookies for sniukas.com in your browser and the banner will ask you again. You can also block cookies in your browser settings.

Who we share it with

We use service providers who process data on our behalf and under our instructions:

• HubSpot, Inc.: website hosting, analytics, and cookie consent.
• Google: Google Analytics and Google Fonts.
• Our email provider: to receive and store the emails you send us.

We may also disclose data to professional advisors, or to authorities and courts where the law requires it.

Transfers outside the EU

HubSpot and Google may process data in the United States. Both are certified under the EU-U.S. Data Privacy Framework, and transfers are also covered by the European Commission's Standard Contractual Clauses.

How long we keep it

We keep emails for as long as we need them to handle your inquiry and any working relationship that follows. If we work together, Luxembourg law requires us to keep business records for ten years. Analytics data is kept according to the retention settings of HubSpot and Google Analytics, and cookies expire as described above.

Your rights

Under the GDPR you can ask us to:

• give you a copy of the personal data we hold about you;
• correct data that is inaccurate or incomplete;
• delete your data;
• restrict how we use it;
• send it to you or to another organization in a machine-readable format.

You can also object to processing based on our legitimate interests, and withdraw your consent to analytics at any time. Withdrawing consent does not affect processing that took place before.

To use any of these rights, email hello@sniukas.com. We will reply within one month. If you believe we have mishandled your data, you can complain to the Luxembourg data protection authority, the Commission nationale pour la protection des données (CNPD), or to the authority in the EU country where you live.

Security

We take reasonable technical and organizational measures to protect your data. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

Links to other sites

The site links to LinkedIn, Substack, YouTube, and Make Better Strategy. These sites have their own privacy policies, and this policy does not cover them.

Children

The site is not directed at children under 16, and we do not knowingly collect their data.

Changes to this policy

We may update this policy when our practices or the law change. The date at the top shows when it was last revised.

Contact

For any question about this policy or your data, write to hello@sniukas.com or to the postal address above.