1. Introduction
After Comma (hereinafter referred to as «the Agency,» «We,» «Us,» «Our») respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website After Comma (hereinafter — «the Site»), as well as when you interact with us in other ways.
By using our Site, you consent to the collection and use of information in accordance with this Policy.
2. Interpretation and Definitions
2.1. Interpretation
The words with initial capital letters have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
2.2. Definitions
- «Agency» (also «We,» «Us,» «Our,» «After Comma») refers to the legal entity that owns and operates the website https://www.aftercomma.agency/.
- «Site» refers to the website https://www.aftercomma.agency/, operated by the Agency.
- «You» (also «User,» «Data Subject») means the individual or legal entity accessing or using the Site.
- «Personal Data» (or «Data») means any information relating to an identified or identifiable natural person.
- «Data Processing» means any operation or set of operations performed on Personal Data, including collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, anonymization, blocking, deletion, and destruction.
- «Cookies» are small text files that a website stores on your Device to record your preferences and actions. [Link to Cookie Policy]
- «Device» means any device that can access the Site, such as a computer, mobile phone, digital tablet, or smart TV.
- «Service Provider» (or «Processor») means any natural or legal person who processes data on behalf of the Agency. These are third parties that provide us with services, such as hosting, analytics, and mailing list management.
- «Terms of Use» means the primary document governing your use of our Site. [Link to Terms of Use]
- «EEA» means the European Economic Area.
- «GDPR» means the General Data Protection Regulation of the European Union.
3. What Data Do We Collect?
We may collect the following categories of personal data:
Data you voluntarily provide to us:
- Contact Information: First name, last name, email address, phone number when you fill out forms on the Site (e.g., «Submit a request» form).
- Project Information: Details about your business, project, or tasks that you provide when inquiring about our services.
- Correspondence: Any other information you send us directly via email or through messengers.
3.1. Sources of Personal Information:
- Directly from you (website forms, correspondence)
- Automatically when interacting with the Site (cookies, server logs)
- From third parties that provide analytics and marketing services
3.2. Data Collected Automatically:
- Technical Data: IP address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, and other diagnostic data.
- Data Collected Using Cookies and Similar Technologies: For more details, see Section 4.
4. How Do We Use Your Data?
- Providing and Improving Our Services: To contact you regarding your inquiry, discussing your project.
- Communication: To respond to your questions, send you information related to our services (including administrative notices, security updates), and, with your consent, marketing materials.
- Analytics: To analyze trends, administer the Site, track users’ movements around the Site, and gather demographic information for aggregate analysis. This helps us understand how users interact with our Site and improve its functionality and user experience (UX).
- Security: To ensure the security of our Site and business, including detecting and preventing fraud and cyberattacks.
6. Legal Basis for Data Processing (in accordance with GDPR)
- Performance of a Contract: When processing is necessary to provide you with our services at your request.
- Legitimate Interests: For conducting website analytics, ensuring security, and promoting our services, provided that such interests are not overridden by your rights and freedoms.
7. Disclosure of Your Data
We may disclose your personal information to the following categories of third parties:
7.1. Service Providers (Data Processors)
- Hosting Providers: Companies that host our Site and data.
- Analytics Services: Such as Google Analytics 4, which help us analyze Site traffic and usage. These services may collect data about your actions on the Site using cookies and similar technologies.
- Marketing and Automation Platforms: Such as Mailchimp, SendGrid, or similar, for managing communication and mailing lists (if you are subscribed).
- Customer Relationship Management (CRM) Platforms: For managing your inquiries and potential projects.
7.2. Advertising and Marketing Partners
We may use tracking technologies, such as social media pixels (e.g., Meta Pixel), to measure the effectiveness of our advertising and target audiences. The use of these technologies may constitute «sharing» of data under the laws of some states (e.g., CCPA). You can manage your preferences through cookie settings.
7.3. As Required by Law
If we are required to disclose your data in response to a lawful request by public authorities (e.g., a court or law enforcement), to enforce our legal rights, or when we believe disclosure is necessary to protect our rights, your safety or the safety of others, to investigate fraud, or to respond to a government request.
8. International Data Transfers
Your data may be processed outside your country, including in the United States. We ensure that such transfers are carried out with appropriate legal safeguards and in accordance with applicable data protection laws.
9. Data Security
We have implemented appropriate technical and organizational security measures designed to protect your personal data from unauthorized access, use, alteration, or destruction. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee its absolute security.
10. Your Data Protection Rights
Depending on your location, you may have the following rights:
- Right of Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete information.
- Right to Erasure («Right to be Forgotten»): Request deletion of your personal data.
- Right to Restrict Processing: Request suspension of processing of your data.
- Right to Data Portability: Request to receive your data in a structured, machine-readable format.
- Right to Object: Object to the processing of your data based on our legitimate interests.
- Right to Withdraw Consent: At any time, if processing is based on your consent.
To exercise these rights, please contact us at the address provided below.
| Category of Data | Collected | Disclosed to Third Parties | «Sold» or «Shared» |
|---|---|---|---|
| Identifiers (name, email, IP) | Yes | Yes (to service providers) | No |
| Internet Activity (browsing history, cookie data) | Yes | Yes (to service providers) | May be considered «sharing» under CPRA if third-party advertising/analytics features are enabled |
| Professional Information (business/project details) | Yes | Yes (to service providers) | No |
11. Your Privacy Rights in the USA
Depending on your state of residence, you may have certain rights regarding your personal data under state laws such as the California Consumer Privacy Act (CCPA/CPRA), Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), and others.
11.1. Categories of Data Collected and Disclosed
Over the past 12 months, we have collected, used, and disclosed to third parties (e.g., service providers) the categories of personal data listed below. This information is disclosed in accordance with CCPA/CPRA.