Privacy Policy

Last updated: 28 July 2026

1. Who we are (data controller)

Pirogov Marketing (“we”, “us”, “our”) operates the website pirogov.marketing and provides digital marketing
services — Google Ads, GA4 analytics, SEO, YouTube, and Meta Ads — to business and e-commerce clients. We are the
data controller responsible for the personal data described in this policy.

Contact for data protection questions: info@pirogov.marketing

2. What personal data we collect

(a) Contact and job application forms. Name, email address, phone number, and any message
content you submit through our contact form or job application (vacancy) form, plus an attached CV or cover letter
where relevant.

(b) Analytics data (Google Analytics 4). Cookies and similar identifiers, IP address (truncated
where the platform allows), device and browser information, pages visited, time on site, referral source, and
general behavioral/interaction data.

(c) Advertising and remarketing data. Where enabled, tracking pixels from Google Ads, Meta
(Facebook/Instagram), and/or TikTok may collect a browser or device identifier and page-visit events to build
remarketing audiences and measure ad performance.

3. Legal basis for processing

• Contact/vacancy forms: your consent (Art. 6(1)(a) GDPR) when you submit the form, and, where
  a form leads towards a service agreement, performance of a contract or pre-contractual steps (Art. 6(1)(b) GDPR).
• GA4 analytics: your consent (Art. 6(1)(a) GDPR), collected only after you accept analytics
  cookies in our cookie banner.
• Advertising/remarketing pixels: your consent (Art. 6(1)(a) GDPR), collected only after you
  accept advertising cookies in our cookie banner.

4. Who receives your data

We share personal data with the following processors, strictly to operate the services described above:

• Google LLC — Google Analytics 4, Google Ads (United States)
• Meta Platforms Ireland Ltd / Meta Platforms, Inc. — Meta Ads pixel (Ireland / United States)
• TikTok Technology Limited / TikTok Inc. — TikTok pixel (Ireland / United States)

Where these processors transfer personal data outside the European Economic Area, the transfer relies on the
European Commission’s Standard Contractual Clauses (SCCs) or another valid transfer mechanism recognized under
GDPR, as implemented by each respective provider. We do not sell your personal data.

5. How long we keep your data

• Contact form and job application submissions: up to 24 months after the last contact, or
  until the recruitment process concludes (for job applications), unless you ask us to delete it sooner or a
  longer period is required to establish, exercise, or defend legal claims.
• GA4 analytics data: retained according to our GA4 configuration (currently 14 months), after
  which it is automatically deleted by Google.
• Advertising/remarketing pixel data: retained according to each platform’s own default
  retention settings (typically up to 180 days for remarketing audiences).

6. Your rights under GDPR

Subject to the conditions set out in the GDPR, you have the right to:

• access the personal data we hold about you;
• rectify inaccurate or incomplete data;
• request erasure of your data (“right to be forgotten”);
• restrict processing in certain circumstances;
• receive your data in a portable, machine-readable format;
• object to processing based on legitimate interest, including profiling and direct marketing;
• withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal;
• lodge a complaint with a supervisory authority — either the data protection authority of your own EU/EEA
  country of residence, or, if you are located in Ukraine, the Ukrainian Parliament Commissioner for Human Rights
  (Ombudsman), who performs the national personal data protection authority function.

To exercise any of these rights, contact us at info@pirogov.marketing.

7. Cookies

• Necessary cookies — required for the website to function (e.g. session/security cookies).
  These cannot be disabled and do not require consent.
• Analytics cookies (Google Analytics 4) — help us understand how visitors use the site. Set
  only after you accept them in our cookie banner.
• Advertising/remarketing cookies (Google Ads, Meta, TikTok pixels) — used to show you relevant
  ads on other sites and measure campaign performance. Set only after you accept them in our cookie banner.

You can withdraw or change your cookie consent at any time via the cookie settings link in the website footer,
or by clearing cookies and adjusting the settings in your browser.

8. Children

Our services are intended for business audiences and are not directed at, and must not be used by, individuals
under the age of 16. We do not knowingly collect personal data from children.

9. Changes to this policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top reflects the latest
revision. Material changes will be highlighted on this page.

10. Contact

Questions about this policy or your personal data: info@pirogov.marketing