This policy covers the website vinulu.com (the "site"). Our apps have their own policies: VINULU: Baby Sleep Tracker and GRNT • EU Warranty & GARAN.
1. Who is responsible
The data controller is Ivan Goriachev.
- Self-employed sole trader registered in Portugal
- Address: Avenida Conde S. Januário, n.º 28, House D, 2770-040 Paço de Arcos (Oeiras), Portugal
- Tax number (NIF): 311595154
- Email for data and privacy questions: hello@vinulu.com
2. What we process, why, and on what legal basis
| Data | Why | Legal basis (GDPR Art. 6) |
|---|---|---|
| Technical request data: IP address, browser, requested page, time | Deliver the site and keep it secure. Processed by our host, Firebase Hosting (Google) | Legitimate interest (Art. 6(1)(f)) |
| Your cookie choice, stored in your browser | Remember your choice | Legal obligation to ask for consent (Art. 6(1)(c)) |
| Pages viewed, visit duration, approximate location, device type (Google Analytics 4) | Understand how the site is used | Your consent (Art. 6(1)(a)) |
| Ad interactions, App Store button clicks (Meta Pixel, Google ads signals) | Measure whether our ads lead to app downloads | Your consent (Art. 6(1)(a)) |
| Your email address and message, if you write to us | Answer you | Legitimate interest, or steps before a contract (Art. 6(1)(b), (f)) |
The site has no accounts, forms or comments. We do not sell your data.
3. Cookies and similar technologies
Optional cookies are off until you allow them in the banner. You can change or withdraw your choice at any time with Cookie settings at the bottom of every page; when you withdraw, we remove these cookies and reload the page.
| Name | Provider | Category | Purpose | Duration |
|---|---|---|---|---|
vinulu_consent (local storage) |
vinulu.com | Necessary | Remembers your cookie choice | 12 months, then we ask again |
_ga, _ga_<ID> |
Analytics | Distinguishes visitors for Google Analytics 4 | up to 2 years | |
_fbp, _fbc |
Meta | Marketing | Measures ad results for the Meta Pixel | up to 3 months |
Google may set additional cookies for ads measurement when you allow marketing together with analytics. Details: Google, Meta.
4. Who receives your data
| Provider | Purpose |
|---|---|
| Google (Firebase Hosting) | hosting the site |
| Google (Google Analytics 4, ads signals) | statistics and ad measurement — only with your consent |
| Meta Platforms (Meta Pixel) | ad measurement — only with your consent |
Fonts are served from vinulu.com itself, not from Google Fonts.
5. Transfers outside the EEA
Google and Meta may process data in the United States. Such transfers rely on the EU-U.S. Data Privacy Framework, in which both take part, or on the standard contractual clauses approved by the European Commission.
6. How long we keep data
- Hosting request data: kept by Firebase Hosting for its own logging period.
- Google Analytics data: up to 14 months.
- Meta Pixel data: as set by Meta for ad measurement.
- Emails: as long as needed to answer you and follow up, then deleted.
7. Your rights
Under the GDPR you can ask to access, correct, delete, restrict or port your data, object to processing based on legitimate interest, and withdraw your consent at any time (Cookie settings). Write to hello@vinulu.com — we reply within one month.
You can complain to a data protection authority: in Portugal this is the CNPD (www.cnpd.pt); authorities in all EEA countries are listed at edpb.europa.eu.
8. Changes to this policy
If we change this policy, the new version will appear on this page with a new date. If we add new optional cookies or providers, we will ask for your consent again.