Privacy Policy
1. Who we are and how to reach us
This Privacy Policy explains how GR Enterprises SRL ("we," "us," "our"), operating under the trade name Built to Convert, collects, uses and protects your personal information when you visit our website at glebbuilds.com, subscribe to our emails, book a call, purchase a service, or otherwise interact with us.
We are the data controller for the information described in Section 3, except where Section 2 applies. Registration number 1026609000529. Registered address: MD-3601, str. Bogdan Petriceicu Hașdeu 8, ap. 35, mun. Ungheni, Republic of Moldova. For any privacy question or request, contact ratagleb1@gmail.com.
"Business day" in this policy means Monday to Friday, excluding public holidays observed at our registered address.
We offer our services to people in the European Union, the United Kingdom and elsewhere. Where the EU General Data Protection Regulation (GDPR) or United Kingdom data protection law applies to our processing of your personal data, we comply with it. Where the data protection law of another country applies to our processing, we comply with that law. Your local law may give you rights in addition to those described in Section 8.
2. When we are a processor rather than a controller
Where a client gives us personal data belonging to their own audience, subscribers, leads or customers so that we can deliver the engagement, the client is the data controller and we act as their processor. We process that data only on the client's documented instructions. The terms governing that relationship are set out in Schedule B of the Client Services Agreement, not in this policy. This policy covers only the data for which we are the controller.
3. What information we collect
Depending on how you interact with us:
- Identity and contact data: name, email address, social media handle, and any details you provide when booking a call or purchasing.
- Email subscription data: your first name and email address when you subscribe to our emails, and whether you open or click them, as reported by our email provider.
- Website usage data: anonymous, aggregated statistics about visits to our website, such as page views and the country and site a visit came from. See Section 10.
- Booking and intake information: your answers on our scheduling form and any information you share during our conversations.
- Direct message content: where you contact us on Instagram or WhatsApp, the content of that conversation and your profile handle.
- Session notes: written notes we take during delivery sessions. See Section 5.
- Payment information: processed by our payment provider, Whop. We do not store your full card details. We receive confirmation of payment, billing name and transaction records.
- Business information you share: your own offers, funnels, metrics and materials provided so we can deliver the service. Where those materials contain other people's personal data, Section 2 applies instead.
Whether you have to give us this data. Giving us your name, email and payment details is a requirement of entering into a contract with us. Without them we cannot book your call, invoice you or deliver the service, and we will not be able to work together. Everything else, including subscribing to our emails and any marketing consent, is optional and refusing it has no effect on the service you receive.
4. How we use your information and our legal bases
| What we use it for | Legal basis under the GDPR |
|---|---|
| Scheduling, preparing for and conducting your call | Performance of a contract, or steps taken at your request before entering one |
| Diagnosing your conversion issues and delivering the engagement | Performance of a contract |
| Processing payment and managing a payment plan | Performance of a contract |
| Communicating with you about your booking, purchase and delivery | Performance of a contract |
| Keeping records for accounting, tax and legal compliance | Compliance with a legal obligation |
| Keeping written notes of our sessions as the record of what we delivered | Performance of a contract, and the establishment, exercise or defence of legal claims |
| Sending you our emails, including funnel teardowns, updates or marketing about our services | Your consent |
| Running and improving the business, including reviewing our own delivery and anonymous website statistics | Our legitimate interests |
Withdrawing consent. Where we rely on your consent, you can withdraw it at any time by clicking the unsubscribe link in any email, replying to any message from us or emailing ratagleb1@gmail.com, and we stop within 2 business days. Withdrawing consent does not affect the lawfulness of any processing we carried out before you withdrew it.
Automated decisions. We do not use automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you.
5. Calls and session notes
We do not record our calls. Calls are held on Google Meet and no recording or transcript is made or stored.
- Where we ever want to record a call, we ask you first and we do not record without your written agreement. If we start doing this as a matter of course, we update this policy before we do.
- During delivery sessions we take written notes of what was covered and what was agreed, and we send them to you when you ask for them. These are our record of what we delivered.
- Notes are stored in Notion. Access is limited to Gleb Rata, and to a subcontractor only for the duration of the work that requires it, matching Section 9.
- Retention is set out in Section 7.
6. Who we share your information with
We do not sell your personal data. We share it only with:
- Whop: payment and checkout provider. Whop acts as merchant of record for card network rules and payment settlement only. We remain the supplier of the service and we handle our own taxes, refunds and disputes.
- Cal.com: manages your booking.
- Google (Gmail, Meet): where we correspond with you and where calls are held.
- Notion: where we keep session notes, delivery materials and engagement records.
- Meta (Instagram and WhatsApp): where you contact us by direct message or where we message you during the engagement.
- Kit: sends our emails and stores the list of people who have subscribed.
- Cloudflare: hosts our website and provides anonymous visit statistics.
- Service providers and subcontractors who help us deliver, under written confidentiality obligations and only with the data they need for that work. The providers named above are the complete current list of service providers, and where we add or replace one we update this Section before the change takes effect. Where we engage an individual subcontractor, that person works under a written confidentiality obligation and has access only for the duration of the work that requires it.
- Professional advisors (for example our accountant) and public authorities, where required by law.
Some of these providers process data outside your country. Where that happens, we rely on the transfer safeguards required by the data protection law that applies, including standard contractual clauses where relevant, or on a derogation where the transfer is necessary to perform our contract with you.
7. How long we keep your information
Email subscription data: kept while you are subscribed. When you unsubscribe, we delete it within 30 calendar days, except the record of your consent and its withdrawal, which we keep as set out below.
Where you have a call with us but no engagement follows:
- Booking, intake, direct message and business information: deleted within 12 months of the call.
Where an engagement follows:
- Session notes: kept for the duration of the engagement plus 36 months, then deleted or anonymized within 30 calendar days. We keep them this long because they are the record of what was delivered, and because a claim about the engagement can be brought for up to three years after it ends under the limitation period that applies to us.
- Booking, intake, direct message and business information: kept for the duration of the engagement plus 36 months, then deleted or anonymized within 30 calendar days.
In every case:
- Payment and tax records: kept for 5 years from the end of the financial year in which the transaction occurred. Where the accounting or tax law that applies to us requires a longer period, we keep them for that longer period instead.
- Marketing consent records: kept for 24 months after consent is withdrawn, so we can evidence the withdrawal.
Where the same data falls into more than one category above, the longest applicable period governs.
Where you ask us to delete data sooner and we are not required to keep it, we delete it within 30 calendar days of your request.
8. Your rights
Depending on your location, you have the right to: access the personal data we hold about you; correct it; request its deletion; object to or restrict certain processing; object to direct marketing; withdraw consent; and receive a copy of your data in a portable format.
To exercise any of these, email ratagleb1@gmail.com. We respond within one month of receiving your request. Where a request is complex or where we receive a number of requests, we may extend that period by up to two further months, and we tell you within the first month if we do and why.
Where the GDPR or United Kingdom data protection law applies to our processing, you have the right to complain to the supervisory authority in the country where you live or work, or where the issue arose. Where another data protection law applies to you, you may complain to the authority under that law.
9. How we protect your information
We protect your personal data by:
- limiting access to the accounts holding your data to Gleb Rata, and to a subcontractor only for the duration of the work that requires it;
- using providers that maintain their own security programs, listed in Section 6;
- protecting every account holding your data with a unique password stored in a password manager and with two-factor authentication where the provider supports it;
- removing a subcontractor's access within 2 business days of the end of their work.
No system is completely secure, but we work to safeguard your information.
10. Cookies and tracking
Our website is hosted by Cloudflare and uses Cloudflare Web Analytics, which counts visits without cookies and without any identifier that follows you from one visit to the next. Our fonts are served from our own website, not from a third party.
Our booking and checkout are handled by third-party providers, Cal.com and Whop, each of which has its own cookie and privacy practices. Our emails are sent by Kit, which reports whether an email was opened or a link was clicked. We do not set our own tracking cookies.
11. Legal capacity and minors
Our services are directed at people who can enter into a contract in their own name. To book or purchase, you must have reached the age of majority in the country where you live. That age is not the same everywhere. In some countries it is below 18 and in others above it, so the age that applies to you is the one set by your own country's law rather than a single fixed age.
Where a person below the age of majority in their country of residence will take part in the sessions, a parent or legal guardian with full legal capacity is our client and enters into the agreement in their own name, and is responsible for payment and for that person's participation. We process that person's data only as far as we need to in order to deliver the engagement, and on the guardian's instructions. We do not knowingly collect data from a person below the age of majority in their country outside that arrangement. Where we learn that we hold such data without it, we delete it within 30 calendar days.
12. If our business changes hands
Where our business is reorganized, sold, merged or transferred in whole or in part, personal data may be transferred as part of that transaction, subject to the data protection law that applies. Where that happens and it materially affects your rights, we tell you by email at least 14 calendar days before it takes effect.
13. Changes to this policy
We update this policy when what we do changes. The version above always describes what we do now, and the date at the top shows when it last changed. Where a change materially affects your rights, we tell you by email at least 14 calendar days before it takes effect.
14. Contact
GR Enterprises SRL (Built to Convert)
Registration number: 1026609000529
Registered address: MD-3601, str. Bogdan Petriceicu Hașdeu 8, ap. 35, mun. Ungheni, Republic of Moldova
Email: ratagleb1@gmail.com