Privacy Policy

This Privacy Policy is provided in multiple languages for user convenience. In the event of any discrepancy or inconsistency between the English version and any translated version, the English version shall prevail.

1. Controller Information

This Privacy Policy describes how personal data is processed when you use AskHedgy.

The data controller is:

AskHedgy is operated by Andrey Pogorelov, an individual conducting registered individual activity in Lithuania under an Individual Activity Certificate (Individualios veiklos pažymos Nr. 335363).

Contact: info@askhedgy.com

2. Scope of This Policy

This Privacy Policy applies to:

  • Customers: business users who create accounts and manage surveys
  • Respondents: end-users who access and complete surveys via QR codes

It explains how personal data is collected and processed in connection with the AskHedgy Service.

3. Roles Under Data Protection Law

Depending on the context:

  • For Customer account data, AskHedgy acts as the Data Controller
  • For survey responses, the Customer is the Data Controller, and AskHedgy acts as the Data Processor only in relation to survey data processing, under applicable data protection law, including the GDPR

We process survey data only on the Customer’s documented instructions, except where required by law.

4. Types of Data We Process

4.1 Customer Account Data

We process data necessary to provide the Service, including:

  • email address
  • name (if provided)
  • account credentials
  • billing information (processed via third-party providers)

4.2 Technical Data

We may process technical information for security and system operation, including:

  • IP address
  • device and browser information
  • timestamps
  • usage logs

This data may include personal data as defined under the GDPR and is used for security, abuse prevention, and service stability.

4.3 Survey Data

We process survey responses on behalf of Customers, which may include:

  • ratings
  • text responses
  • optional feedback provided by respondents

AskHedgy does not require respondents to provide directly identifying information.

We do not provide Customers with access to raw technical identifiers such as IP addresses unless required for security, legal compliance, or abuse prevention purposes.

5. Purpose and Legal Basis

We process personal data for the following purposes:

  • providing and operating the Service
  • managing user accounts
  • processing survey responses
  • analytics and service improvement
  • security and fraud prevention
  • billing and legal compliance

Legal bases include:

  • performance of a contract
  • legitimate interest
  • legal obligation
  • consent (where applicable)

6. Data Sharing and Subprocessors

We may use third-party service providers to operate the Service, including:

  • hosting and infrastructure providers
  • payment processors
  • email delivery providers
  • analytics and monitoring tools

All subprocessors are contractually required to protect personal data.

We do not sell personal data.

7. Data Retention

  • Customer account data: retained for the duration of the account and as required by applicable accounting and tax laws
  • Survey data: retained while the Customer account is active

Upon termination, data is deleted or anonymized within a reasonable period (typically up to 30 days), unless longer retention is required by law.

Data processing and retention practices are further described in our Terms of Use.

8. International Data Transfers

Your data may be processed outside the European Economic Area.

Where such transfers occur, we apply appropriate safeguards in accordance with applicable data protection law, including Standard Contractual Clauses where required.

9. Your Rights

Under applicable data protection law, including the General Data Protection Regulation, you may have the right to:

  • access your personal data
  • request correction
  • request deletion
  • restrict processing
  • object to processing
  • data portability

Respondents

If you are a respondent completing a survey, please contact the business that created the survey (the Customer) to exercise your rights, as they act as the Data Controller.

Complaints

You also have the right to lodge a complaint with the Lithuanian State Data Protection Inspectorate (VDAI).

10. Cookies and Tracking

We use cookies and similar technologies for:

  • essential website functionality (authentication, security)
  • system performance monitoring
  • basic analytics

We do not use advertising or cross-site tracking cookies.

You may control cookies through your browser settings.

11. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, or misuse.

12. Communications

We may send you service-related messages as described in our Terms of Use, including:

  • service notifications (account, security, billing)
  • operational messages necessary for Service functionality
  • optional product updates or educational content (if permitted or consented)

These communications are based on the legal grounds described in this Privacy Policy.

You may opt out of optional communications at any time without affecting essential service communications.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Continued use of the Service constitutes acceptance of the updated version.

14. Contact

If you have any questions about this Privacy Policy, contact:

info@askhedgy.com