Privacy Policy (English)

1. Controller

Rum Doodle, sole proprietorship, owner Geoff Brown

Bichlnweg 9, 6370 Kitzbühel, Austria

Phone +43 650 2333 3585, email: office@rumdoodle.net

2. What data we process and why

2.1 Visiting the website (hosting)

When you visit the website, our hosting provider processes technically necessary data (IP address, date, time, page requested, browser) to deliver the site and keep it secure. Legal basis: Art. 6(1)(f) GDPR (our legitimate interest in a secure, working website). The website runs on Lovable (Lovable Labs Incorporated). [OPEN: confirm the exact hosting set-up (Lovable hosting and/or Supabase), the contracting entity with its address, and the server region.]

2.2 Content delivery and security (Cloudflare)

The website is delivered through the network of Cloudflare, Inc. (101 Townsend St, San Francisco, CA 94107, USA) so that it loads quickly and is protected against attacks. Your IP address is processed for this purpose. Legal basis: Art. 6(1)(f) GDPR. Transfers to the USA are based on the EU-US Data Privacy Framework or on Standard Contractual Clauses. [OPEN: confirm whether we use Cloudflare directly or through Lovable, which determines the contracting party.]

2.3 Contact by email or form

We use the details you give us (name, company, email, phone, message) to handle your enquiry. Legal basis: Art. 6(1)(b) GDPR (steps prior to entering into a contract). Our mailbox is operated by Hetzner Online GmbH, Germany. [OPEN: name the form or sending service used for notify.rumdoodle.net (provider, seat, storage location).]

2.4 Booking a consultation (€390)

When you book a paid consultation, we process your name, email address and, where provided, your phone number and company, the appointment you choose and what you tell us about your needs, in order to arrange and deliver the consultation. Legal basis: Art. 6(1)(b) GDPR (contract or steps prior to a contract). We use Microsoft Bookings for appointment booking and the Microsoft 365 calendar to manage appointments (Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland), acting as our processor. [OPEN: confirm that Microsoft Bookings/Microsoft 365 calendar are actually used for consultation bookings; the booking link has not been decided yet.]

We keep invoices and the related accounting records because the law requires us to. Legal basis: Art. 6(1)(c) GDPR in conjunction with Section 132 of the Austrian Federal Fiscal Code (BAO); retention period: 7 years.

Payment is handled by PayPal. The provider is PayPal (Europe) S.à r.l. et Cie, S.C.A., 22–24 Boulevard Royal, L-2449 Luxembourg. PayPal processes your payment data as an independent controller, not on our behalf. Legal basis for passing data to PayPal: Art. 6(1)(b) GDPR. For details, see PayPal's privacy statement: https://www.paypal.com/at/legalhub/privacy-full

2.5 Ebook download and questionnaire

2.6 Newsletter and marketing emails

You will only receive our newsletter if you tick a separate box, which is not pre-ticked. Sign-up uses double opt-in: we send you an email with a confirmation link, and only after you click it do we send you the newsletter. Legal basis: Art. 6(1)(a) GDPR and Section 174 of the Austrian Telecommunications Act 2021 (TKG 2021). We store the time and wording of your consent and of your confirmation. You can withdraw your consent at any time using the unsubscribe link in every email or by writing to office@rumdoodle.net. [OPEN: name the service that sends the newsletter/welcome email; sending via Clarify is planned, please confirm.]

2.7 Customer management (CRM): Clarify

We manage enquiries, bookings, ebook sign-ups and prospects in the CRM system Clarify. The provider is Clarify, Inc., USA [OPEN: confirm Clarify, Inc.'s business address]. Clarify processes the data on our behalf as a processor; a data processing agreement under Art. 28 GDPR will be signed before launch. According to the provider, the data is stored on Amazon Web Services servers in the USA. Transfers to the USA rely on Clarify, Inc.'s certification under the EU-US Data Privacy Framework and on the EU Standard Contractual Clauses in the data processing agreement.

2.8 Analytics and cookies

Only with your consent via the cookie banner (Art. 6(1)(a) GDPR, Section 165(3) TKG 2021) do we use Google Tag Manager and Google Analytics 4 (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) to analyse how the website is used. Without your consent these services are not loaded. Data may be transferred to Google LLC in the USA; this is based on the EU-US Data Privacy Framework. Analytics data is kept for 14 months. You can withdraw your consent at any time via "Cookie settings" in the footer of every page.

3. Recipients and transfers to third countries

Your data is only shared with the service providers named above. The hosting and CDN providers, Hetzner, Microsoft, Clarify and Google act as our processors and are bound by our instructions. PayPal processes payment data as an independent controller. Transfers to countries outside the EEA (in particular the USA) take place only with appropriate safeguards: the adequacy decision for the EU-US Data Privacy Framework for certified companies, or EU Standard Contractual Clauses. [OPEN: confirm the role of Cloudflare/Lovable depending on the contract set-up.]

4. Retention

5. No automated decision-making

We do not carry out automated decision-making, including profiling, that has legal effects on you or similarly significantly affects you (Art. 22 GDPR).

6. Your rights

You have the right of access, rectification, erasure, restriction of processing, data portability and objection, and the right to withdraw consent at any time with effect for the future. Please send requests to office@rumdoodle.net. You can lodge a complaint with the Austrian Data Protection Authority, Barichgasse 40–42, 1030 Vienna, www.dsb.gv.at.

Last updated: 15 October 2026