1) Who we are (Data Controller)

This website is operated by Papaia Communications Sàrl-S (“we”, “us”, “our”).
Contact: hello@papaia-marketing.com, 33 Boulevard Prince Henri, L-1724, Luxembourg

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2) What personal data we collect

We only collect the information you choose to submit via our contact form, which may include:

• Name

• Email address

• Phone number (if provided)

• The content of your message and any attachments

We do not use analytics, advertising trackers, social media plug-ins, or other apps.

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3) Why we use your personal data (Purposes)

• To read and respond to your inquiry

• To follow up on your request or provide information you asked for

• To maintain basic records of communications

 

4) Legal bases for processing (GDPR)

• Legitimate interests (Art. 6(1)(f) GDPR): to handle and respond to your inquiry efficiently.

• Legal obligation (Art. 6(1)(c) GDPR): where we must retain information to comply with applicable laws (e.g., accounting or regulatory requirements).
   

5) How long we keep your data (Retention)

We keep contact-form inquiries for up to 12 months after our last interaction, unless a longer period is required by law or is necessary to establish, exercise, or defend legal claims. After that, we delete or anonymize the messages.
 

6) Sharing your data

We do not sell or rent your personal data and we do not disclose it to third parties for their own marketing.
We use service providers that act as our processors (e.g., website hosting and email). They are only allowed to process your data on our instructions and must protect it appropriately.

• Website hosting (Wix): Our site is hosted on Wix. Your inquiry may be stored in our Wix account and/or sent to our email system to allow us to respond.
   

7) International transfers

Our service providers may process data in countries outside the EEA. Where such transfers occur, we rely on appropriate safeguards under the GDPR (e.g., adequacy decisions or Standard Contractual Clauses) to protect your information.
 

8) Security

We use appropriate technical and organizational measures to protect your information against unauthorized access, disclosure, alteration, or destruction. No method of transmission or storage is completely secure, but we strive to protect your data to industry standards.
 

9) Cookies and similar technologies

We do not use non-essential cookies or analytics. The site may use strictly necessary cookies set by Wix to ensure basic site functionality and security. These cookies are essential and cannot be switched off in our systems.
 

10) Your rights (EU/EEA)

You have the right to:

• Access your personal data and obtain a copy

• Rectify inaccurate or incomplete data

• Erase your data in certain circumstances

• Restrict processing in certain circumstances

• Object to processing based on our legitimate interests

• Data portability (where applicable)

• Lodge a complaint with your supervisory authority

To exercise your rights, contact us at [company email]. We may need to verify your identity before completing your request.
 

11) Supervisory authority

You can lodge a complaint with the Commission nationale pour la protection des données (CNPD) in Luxembourg: https://cnpd.public.lu/
 

12) Changes to this notice

We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated effective date.