Privacy Policy

1. Who we are

Accompa.me provides one-to-one travel companionship and practical support for independent travellers. Our services are non-medical and do not include healthcare, personal care, or regulated travel agency services.

For the purposes of applicable data protection law, the data controller is:

Sole proprietor Igor Starzhynsky
Contact address: Carrer de Neptú 33, Barcelona, Spain
Legal address: Pl. Obolon, 5, Kyiv, Ukraine
Email: connect@accompa.me
Telephone: +34610534579

2. Personal data we collect

Information you provide

When you contact us or submit an enquiry through our website, we may collect:

• Your name;
• Your email address;
• Your telephone number;
• Your preferred messaging service and username;
• Your preferred language;
• Information about your proposed journey, such as the destination, possible dates, and the type of support you are looking for;
• The contents of your message;
• Any other information you choose to provide;
• Your communication preferences and consent choices.

You must provide the information marked as required on the form. If several contact methods are offered, you only need to provide the method or methods through which you would like us to contact you.

Please do not submit passport numbers, payment card details, medical records, health information, or other sensitive personal data through the website enquiry form. If information of this kind becomes necessary at a later stage, we will explain why it is needed and agree on an appropriate way to provide it.

Information collected automatically

When you visit the website, certain technical information may be collected automatically, including:

• Your IP address;
• Browser and device type;
• Operating system;
• Approximate location derived from your IP address;
• Pages visited and actions taken on the website;
• Date, time, and duration of your visit;
• Referring website or source;
• Cookie identifiers and consent preferences.

Some of this information is required for the website to function securely. Analytics information is collected only where permitted by law and, where required, after you have provided your consent.

3. How we use your personal data

We may use your personal data to:

• Receive, review, and respond to your enquiry;
• Contact you using your chosen communication method;
• Understand your proposed journey and the support you may require;
• Arrange an introductory conversation or video call;
• Prepare a personalised proposal;
• Provide and administer our services;
• Maintain necessary records of our communications;
• Operate, protect, and improve the website;
• Understand how visitors use the website;
• Prevent fraud, misuse, and security incidents;
• Comply with applicable legal and regulatory obligations;
• Establish, exercise, or defend legal claims.

We do not sell or rent your personal data.

We do not use personal data submitted through the enquiry form for automated decision-making or profiling that produces legal or similarly significant effects.

We will not use your contact details for promotional emails or other direct marketing unless you have separately agreed to receive such communications. You may withdraw that consent at any time.

4. Legal bases for processing

Where the General Data Protection Regulation (“GDPR”) applies, we process personal data on one or more of the following legal bases:

• Steps taken at your request before entering into a contract: when we review your enquiry, discuss your journey, arrange an introductory call, or prepare a proposal;
• Performance of a contract: when processing is necessary to provide services you have requested;
• Legitimate interests: when we respond to general enquiries, maintain appropriate business records, protect the website, prevent misuse, and improve our services, provided that these interests are not overridden by your rights and interests;
• Consent: when we use optional analytics cookies or send marketing communications;
• Legal obligation: when processing is necessary to comply with tax, accounting, regulatory, or other legal requirements;
• Legal claims: when information must be retained or used to establish, exercise, or defend a legal claim.

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

5. How long we retain personal data

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Our usual retention periods are:

• Enquiries that do not result in a service agreement: up to 12 months after our last communication;
• Information connected with services provided to you: for the duration of our working relationship and afterwards for as long as required by applicable tax, accounting, contractual, or legal requirements;
• Consent records and privacy requests: for as long as necessary to demonstrate compliance with our legal obligations;
• Security and technical logs: for a limited period appropriate to their security and operational purpose;
• Google Analytics user-level and event-level data: up to 14 months, subject to the configuration of our Google Analytics account;
• Analytics cookies stored on your device: for up to two years, unless you delete them or withdraw your consent earlier.

We may retain limited information for longer where this is required by law or necessary to establish, exercise, or defend legal claims.

When personal data is no longer required, we delete it, anonymise it, or securely isolate it until deletion is possible.

6. How we share personal data

We may share personal data with carefully selected service providers that help us operate the website and communicate with you. These providers may include:

• Cloudflare: website infrastructure, security, and Cloudflare D1 database services;
• Resend: delivery of email notifications and website-related emails;
• Google Analytics: website audience measurement and usage analytics, where you have consented;
• Professional advisers, accountants, insurers, or legal advisers where reasonably necessary;
• Public authorities, courts, regulators, or law-enforcement bodies where disclosure is required by law.

Service providers may access personal data only to the extent necessary to perform their services or meet applicable legal obligations. Where required, we use contractual and organisational safeguards governing their processing of personal data.

We may also disclose personal data where this is necessary to protect our rights, prevent fraud or misuse, respond to an emergency, or protect the safety and rights of another person.

7. International data transfers

Some of our service providers may process personal data outside the European Economic Area (“EEA”), including in the United States.

Where the GDPR applies and personal data is transferred outside the EEA, we rely on an appropriate legal transfer mechanism. Depending on the provider and destination, this may include:

• A European Commission adequacy decision;
• The EU–US Data Privacy Framework;
• European Commission Standard Contractual Clauses;
• Other safeguards permitted by applicable data protection law.

You may contact us if you would like further information about the safeguards used for a particular transfer.

8. Data security

We use reasonable technical and organisational measures designed to protect personal data from accidental or unlawful loss, alteration, disclosure, misuse, or unauthorised access.

These measures may include:

• Encryption of data in transit;
• Encryption of data stored in the Cloudflare D1 database;
• Access controls and authentication;
• Restricted access to personal data;
• Security monitoring;
• Regular review of the information we retain;
• Use of reputable infrastructure and communication providers.

No website, database, or method of electronic communication can be guaranteed to be completely secure. You should therefore avoid sending highly sensitive or confidential information through the website enquiry form.

9. Cookies and analytics

The website may use cookies and similar technologies.

Necessary technologies

Some technologies may be required for the website to operate securely, remember your privacy preferences, or provide features you request. Where these technologies are strictly necessary, they do not require consent under applicable law.

Google Analytics

We use Google Analytics to understand how visitors interact with our website, measure website traffic and performance, identify technical problems, and improve the user experience.

Depending on your consent and our configuration, Google Analytics may process information such as:

• Pages visited;
• Approximate geographical location;
• Browser, operating system, and device information;
• Session statistics;
• Referring source;
• Interactions with website features;
• Analytics cookie identifiers.

Google Analytics commonly uses cookies such as _ga and _ga_<container-id> to distinguish users and maintain session information.

Where required by law, Google Analytics is activated only after you provide consent through the website’s cookie notice. You may refuse analytics cookies without losing access to the main functions of the website.

You may withdraw or change your consent at any time using the website’s cookie settings. You may also delete or block cookies through your browser settings. Blocking certain necessary technologies may affect how parts of the website function.

We do not use Google Analytics data for targeted advertising unless this Privacy Policy and the cookie notice are updated to explain that use and the necessary consent has been obtained.

10. Your data protection rights

Depending on where you live and the law that applies, you may have the right to:

• Receive information about how your personal data is processed;
• Request access to your personal data;
• Request correction of inaccurate or incomplete personal data;
• Request deletion of your personal data;
• Request restriction of processing;
• Receive certain personal data in a structured, commonly used, machine-readable format;
• Request that certain personal data be transferred to another controller;
• Object to processing based on legitimate interests;
• Object to direct marketing at any time;
• Withdraw your consent at any time;
• Lodge a complaint with a competent data protection authority.

These rights are not absolute and may be subject to legal conditions or exemptions.

To exercise any of these rights, contact us at connect@accompa.me. We may ask you for information necessary to verify your identity before responding.

Where the GDPR applies, we will normally respond within one month. If a request is particularly complex or if you submit several requests, this period may be extended by up to two additional months. We will inform you if an extension is necessary.

You may also lodge a complaint with the data protection authority in the country where you live or work, or where you believe an infringement took place. If you are in Spain, the competent authority is generally the Agencia Española de Protección de Datos (AEPD).

11. Third-party websites and services

Our website may contain links to third-party websites or services, including airlines, hotels, transport providers, communication platforms, and other travel-related resources.

We do not control these third parties and are not responsible for their privacy practices. You should review the privacy policy of each third-party website or service before providing personal data to it.

12. Changes to this Privacy Policy

We may update this Privacy Policy when our services, website functionality, providers, or legal obligations change.

The current version will always be published on this page. The “Last updated” date at the top of the policy indicates when it was most recently revised.

If a change materially affects how we use personal data, we will provide an appropriate notice and, where legally required, request your consent again.

13. Contact us

If you have questions about this Privacy Policy, the way we process personal data, or your data protection rights, contact us at:

Accompa.me
Sole proprietor Ian (Igor) Starzhynsky
Contact address: Carrer de Neptú 33, Barcelona, Spain
Email: connect@accompa.me
Telephone: +34610534579