Privacy Policy
1. Who is responsible for your data
A Calmer Start (private seller, Slovenia)
Email: puppyplanai@gmail.com
The operator of A Calmer Start (a private individual based in Slovenia) is the controller of your personal data under the EU General Data Protection Regulation (GDPR) and the Slovenian Personal Data Protection Act (ZVOP-2). For any privacy question or request, email puppyplanai@gmail.com.
2. What we collect, why, and on what legal basis
- When you buy a guide: your name (if you enter it), email address, billing country and, where required, address; the products bought, price, order number, date, and technical data used for tax and fraud checks (such as IP address and country). We use this to take your order, deliver your download link, send the confirmation, handle support, complaints and refunds, and meet tax and accounting duties. Legal basis: performance of the contract (Art. 6(1)(b) GDPR) and legal obligations (Art. 6(1)(c) GDPR).
- Payment data: card or other payment details are entered on the checkout and processed by Stripe. We never receive your full card number; we only see limited information such as the card type, last four digits and payment status. Legal basis: contract (Art. 6(1)(b)) and, for Stripe’s fraud prevention, legitimate interests (Art. 6(1)(f)).
- When you email us: your email address, name and whatever you write, to answer you. Legal basis: contract or steps before a contract (Art. 6(1)(b)) or our legitimate interest in answering enquiries (Art. 6(1)(f)).
- When you visit the website: our host processes technical data (IP address, browser, pages requested, time) in short-lived server logs to deliver the site and keep it secure. Legal basis: legitimate interests (Art. 6(1)(f)). This website sets no advertising or analytics cookies and has no tracking pixels. The checkout pages of SendOwl and Stripe may use cookies that are necessary for the checkout to work and to prevent fraud.
We do not sell your data, and we only send marketing emails if you have separately agreed to receive them; you can unsubscribe at any time.
3. Who processes your data for us
- SendOwl (SendOwl Ltd, United Kingdom): checkout, order records and delivery of download links and emails, acting as our processor.
- Stripe (Stripe Payments Europe Ltd, Ireland, and its group companies): payment processing. For some purposes, such as fraud prevention and its own legal duties, Stripe acts as an independent controller under its own privacy policy.
- Vercel (Vercel Inc., USA): website hosting and content delivery, acting as our processor.
- Our email provider (Google, for the Gmail address above), to send and receive support emails, and, where needed, a tax adviser and the tax authorities.
Some of these providers process data outside the European Economic Area, for example in the United Kingdom or the USA. Such transfers rely on an EU adequacy decision (for example for the UK, or for US companies certified under the EU-US Data Privacy Framework) or on the European Commission’s Standard Contractual Clauses.
4. How long we keep your data
- Order and payment records: for as long as Slovenian tax law requires, generally up to 10 years after the end of the year of purchase.
- Support emails: up to 2 years after your matter is resolved, unless we need them longer to deal with a legal claim.
- Hosting logs: a short period set by our host, normally a few days to a few weeks.
5. Your rights
You have the right to access your data, have it corrected or deleted, restrict its processing, receive it in a portable format, and object to processing based on legitimate interests. Where processing is based on your consent, you can withdraw it at any time without affecting earlier processing. To use any of these rights, email puppyplanai@gmail.com. We will answer within one month. Some data (such as order and payment records) must be kept by law even if you ask us to delete it.
6. Complaints
If you think we handle your data unlawfully, please tell us first. You also have the right to complain to a data protection supervisory authority. In Slovenia this is the Information Commissioner of the Republic of Slovenia (Informacijski pooblaščenec), Dunajska cesta 22, 1000 Ljubljana, email gp.ip@ip-rs.si, website www.ip-rs.si. You can also complain to the authority in the EU country where you live or work.
7. Do you have to give us your data?
You need to give an email address and payment details to buy a guide, because otherwise we can’t deliver the download or take payment. We don’t use automated decision-making or profiling that has legal effects on you; Stripe may run automated fraud checks on payments.
8. Changes
We will update this policy if our services or providers change. The date at the top shows the latest version.