Privacy Policy

Last updated: January 2026

vocalharmony.eu, vocalharmony.ru, club.vocalharmony.eu, lp.vocalharmony.eu, praktikum.vocalharmony.eu (and related subdomains such as rf.vocalharmony.eu, sing.vocalharmony.eu) (collectively, the “Website”).

1. Data Controller

The controller responsible for processing your personal data is:
Anna Papina (or your current legal entity name)
Address: Praceta Júlio Dinis 5 2esq, Massama, Queluz, Portugal
Email: info@vocalharmony.eu

2. Personal Data Collected

We may collect:
Identification data: full name, email address, phone number (provided voluntarily via forms).
Technical/usage data: IP address, browser type, pages visited, time/date of visit, cookies and similar technologies (collected automatically).
We use analytics services such as Google Analytics and Yandex Metrika to collect anonymized statistical data about site usage.

3. Purposes and Legal Basis

Providing access to services, information, materials on the Website (legal basis: performance of a contract or steps prior to contract, Art. 6(1)(b) GDPR; or your consent, Art. 6(1)(a)).
Sending informational emails, newsletters, updates about products/services/events (legal basis: your consent, Art. 6(1)(a); you can withdraw consent anytime).
Improving the Website and analyzing usage (legal basis: legitimate interests, Art. 6(1)(f) GDPR – our interest in site optimization, balanced against your rights).
Complying with legal obligations (Art. 6(1)(c) GDPR).

4. Cookies and Analytics

The Website uses cookies and similar technologies. Essential cookies are necessary for functionality. Analytics cookies (e.g., Google Analytics, Yandex Metrika) help understand user behavior anonymously. You can manage cookies via browser settings or our cookie banner (if implemented). For details, see our Cookie Policy (if separate) or browser help.

5. Data Sharing

We do not share your personal data with third parties except:
Service providers (e.g., email service, hosting, analytics) acting as processors under strict contracts.
When required by law or to protect rights.
No sales of data occur.

6. International Transfers

Data may be processed outside the EEA (e.g., by Google/Yandex servers). We use safeguards such as Standard Contractual Clauses or rely on adequacy decisions where applicable.

7. Retention Period

Data is kept only as long as necessary:
Contact data: until consent withdrawal or purpose achieved.
Analytics data: typically 14–26 months (configurable in tools).
Afterwards, data is deleted or anonymized.

8. Your Rights

Access, rectify, erase, restrict processing, object to processing, data portability.
Withdraw consent at any time (without affecting prior lawfulness).
Lodge a complaint with the supervisory authority: Comissão Nacional de Proteção de Dados (CNPD), Rua de São Bento, n.º 148-3.º, 1200-821 Lisboa, Portugal; www.cnpd.pt.
To exercise rights, email info@vocalharmony.eu.

9. Security

We implement appropriate technical and organizational measures to protect your data.

10. Changes

We may update this policy. Changes will be posted here with the updated date.

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