Effective Date: August 2025

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE.

Welcome to https://www.projectevenkeel.com/ (“Website”), operated by Project Even Keel, a sole trader business owned by Carina Tudor Sfetea (“we”, “us”, “our”). By using our website, you, the person using this website (hereinafter: the ‘User’) agree to our Privacy Policy - as well as our Website Terms & Conditions.

Project Even Keel / Carina Tudor Sfetea values its User’s privacy. This Policy discloses the privacy practices of https://www.projectevenkeel.com/ (hereinafter: the “Website”), owned by Project Even Keel / Carina Tudor Sfetea, a Sole trader in the United Kingdom (hereinafter: the “Sole trader”). This Privacy Policy (herein: the “Policy”) will help the User understand how we collect and use personal information from the Users of our Website. This Policy applies solely to information collected by this Website and any affiliated social media accounts.

The Sole trader and the Website reserve the right to make changes to this Policy at any given time. If the User wants to make sure that they are up to date, we advise the User to frequently visit this page. If the Sole trader or Website decides to utilise any personally identifiable information in any other manner than prescribed when initially collected, the User will be notified by email.

By using this Website and affiliated social media accounts, the User is consenting to the data collection procedures expressed in this Policy.

By accepting our Policy, you hereby acknowledge that you are above the age of consent and majority in your jurisdiction. Minors should not use this platform and, as such, we do not knowingly or intentionally collect, share, or use Personal Information from minors.. 

Information the website collects, uses, and shares

1.1. This Website provides several opportunities for the User, to voluntarily provide the Sole trader and Website with personal information in exchange for a free resource, to be added to the Sole trader email or subscriber list, or to contact us on the Website or via social media they automatically “opt-in”. If the User elects to “opt-in” and provide the Sole trader and/or Website with personal information for any of these purposes, we will collect the information provided, which may include the User’s name, email address, phone number, and the text of any messages sent to us. We will also process personal information in the form of comments, images, or videos that the User makes or shares on our blogs, social media pages, or any other online forum currently available now, or made available in the future. The User understands that their decision to provide any information to the Website and/or the Sole trader in this manner is voluntary and constitutes their clear consent to allow the Website and/or the Sole trader to collect, process, and retain such information.

1.2 If the User elects to fill out the “contact us” portion of our Website, or provide us with any other communication data, including but not limited to that provided via email, social media messaging or posts, or text messages, the Website or Sole trader may collect personal information including their name, email address, phone number, the information the User shared with that social media platform, as well as the text of any message sent electronically. This data will be processed based on the Website’s or the Sole trader’s legitimate interest in communicating with the User, and/or answering any questions or concerns raised. We may also retain the aforementioned data to keep a record of any such communication.

1.3 If the User becomes a customer, we will collect additional information in order to carry out and complete the purchase and sale of the goods or services as requested, including but not limited to email address, billing address, credit card or payment information, and any other information necessary in order to complete the purchase of the product or service the User has elected to buy. The Sole trader will collect and process this data in order to fulfil the contractual obligation to complete the order and will not retain the information any longer than necessary.

1.4 If the User is on the Website and or Sole trader’s email list due to their consent to be added, or due to the Website or Sole trader’s legitimate interest in engaging in direct marketing, the Website or Sole trader may also utilise User data to send targeted social media advertisements or upload User information into our social media account to create look-a-like audiences. To ensure compliance with the CAN-SPAM act, all emails from the Website or Sole trader will clearly state the sender of the email, as well as provide instructions on how to unsubscribe from such a list or contact the Website or Sole trader with any questions or concerns.

1.5 This Website may also collect information through Automatic Data Collection Technology. The Website may use or send standard “cookies” to identify the User’s browser from time to time. The Website does not include any personally identifiable information in cookies and will not employ any other mechanisms (other than those discussed above) to capture data on our Website. The Website may use both session cookies (which expire once the User closes their browser) and persistent cookies (which stay on the User’s computer until deleted). The User can accept or decline cookies using web browser settings. If the User chooses to disable cookies, some areas of the Website may not work properly or at all. The Website does not respond to Do Not Track signals sent by the User’s browser. Please see Cookie Policy for further information about cookies.

1.6 This Website may also collect data about how the User utilises the Website, browsing actions or patterns, computer equipment, IP address, internet connection, and other similar choices the User makes, including via Google Analytics and Facebook Pixels, in order to obtain statistical data, improve our Website and offerings, and ensure the User receives information relevant to them. If the Website utilises this technology, the Website will use them in compliance with all policies of these third-party companies. This Website may receive personal data from third parties including but not limited to Google, social media platforms and search engines.

How and why data is collected

2.1 This Website collects the User’s personal information when they voluntarily and/or directly provide it to the Sole trader to receive a free or paid resource, product, or service, or when the User fills out a form or sends an email to contact the Sole trader, and does so in order to provide the User with the resource the User indicated they would like to receive. The Website may also track the User’s future interactions with content, and use personal information to keep the User informed about the products and services they have elected to receive, as well as any linked or similar products or services the Sole trader thinks the User may be interested in. The information will be collected by the Website following the User’s choice to manually enter it in and click to be added to the Sole trader list. No such information will be collected without the User taking action to be added to the list, or in exchange for a free resource.

2.2 This Website may also receive data from third parties like Google Analytics, Facebook and other advertising platforms. The Website will do our best to only utilise third parties who have been deemed GDPR-compliant, and whom the Sole trader has either completed a data processing agreement with or have reviewed and confirmed their policies regarding data processing to ensure compliance.

How we use your information

3.1 The User has the right to know and understand how their information is used. The Website or Sole trader will use the personally identifiable information that the User has voluntarily provided in order to carry out the service or product requested, including free resources, training, newsletters, periodic promotional emails, and to notify the User about any changes to our policies or services. This Website may also use the User’s personal information to form “look-a-like” audiences in the Sole trader’s digital marketing campaigns, which includes uploading User information into our social media advertising campaign(s).

3.2 Non-Personally Identifiable Information: Additional non-identifying information that is collected may be used to provide an overview of how people are accessing and using the Website; it is not used for any additional purposes, and the Website does not use any such data to make automated decisions. The Sole trader and Website may also record some or all information to help create a better User experience. The Website may use information such as the User’s IP address to help diagnose technical problems with Sole trader servers or our Website, and to determine which portions of our Website receive the most traffic, to understand which content is the most useful to our visitors. The User’s IP address will not personally identify them and may be used for such limited purposes as outlined above, in order to improve User experience.

How information is stored and shared

4.1 The User has the right to know what information is stored (and not stored) and how it is processed. User information is stored through a data management system, and it is important to this Website and Sole trader to take appropriate measures to ensure User information is kept confidential. The User understands that there are limited purposes where this Website and Sole trader will share the User’s confidential information, including with those who are providing technical support for our Website, or those who are members of our team, including legal and accounting. Any parties who will have access to the User’s information will keep such information confidential and will never share it with any unrelated parties to the best of the Sole trader’s abilities. Information provided by the User will never be shared, sold, or given to any other Sole trader, company, or person without prior consent, other than what is required to complete a purchase or request made by the User, unless required to do so by law, or any governmental requirements. This Website and Sole trader requires all such third parties to treat the User’s personal information in accordance with the law, and only allows them to process personal data for specific, necessary purposes.

4.2 Please be aware this Website may disclose information provided if required to do so by law, or if there is an honest, good-faith belief that such disclosure is necessary to protect the rights of our Website or of the Sole trader that any portion of our policies are being violated, to prevent or mitigate a belief that a crime may be committed, or to protect the safety or rights of other Users. This information may also be shared as a result of the sale of the Sole trader business or any branch of the Sole trader business, as well as with any joint venture partners or affiliate marketers, should the Sole trader deem it necessary to share such information. This Website will always take all reasonable measures to protect and safeguard the User’s information.

4.3 The internet laws of the United Kingdom govern any and all matters relating to this Website. However, some of our providers (e.g., Squarespace, Acuity, PayPal) are based outside the UK. When this happens, your data is protected by the UK’s approved transfer mechanisms (such as Standard Contractual Clauses or adequacy decisions). Any information the User chooses to provide through this Website, including but not limited to subscribing to a newsletter, opting-in to receive a free gift, sending us a message or purchasing something will be transferred to the United Kingdom for processing. That information may then be transferred within the United Kingdom or back out of the United Kingdom to other countries outside of the User’s country of residence, depending on the type of information, and how it is stored by the Website and Sole trader. If transferred to another country, it may not have data protection laws that are as comprehensive or protective as those in the User’s country of residence; however, our collection, storage, and use of the User’s Personal Information will at all times be governed by this Policy. By visiting our Website, the User acknowledges this information, and by submitting any personal information onto our Website, hereby authorises this transfer and processing of information.

4.4 By collecting and using the User’s personal data, this Website is acting as a data controller, meaning we determine what information is collected, how long it is stored, and what the personal information will be used for. This Website utilises a third-party Company to act as a data processor, which stores information such as names and email addresses that make up our email list. To the best of our ability, we have researched and concluded that all third-party data processors this Website and Sole trader uses, have advised us they are compliant with the General Data Protection Regulations as well.

Your access to, and control over, information

5.1 The User has the right to update, edit, or delete their information from the Sole trader and Website database. It is also within the User’s right to opt-out of any future communications from us at any time by clicking the “unsubscribe” button at the bottom of any email we send the User from our list or to send us a direct email at carina @ projectevenkeel . com. Should the User wish to:

• See what data this Sole trader holds about the User, if any,

• Change/correct any data this Sole trader holds about the User,

• Have us delete any data this Sole trader holds about the User,

• Express any concern they have about this Sole trader’s use of the User’s data,

The User can do so at any time, free of charge, by reaching out via the following email address to: carina @ projectevenkeel . com.

Unsubscribe or opt-out

6.1 All Users and visitors to our Website have the option to discontinue receiving communications from us by way of email or newsletters. To discontinue or unsubscribe from our Website please send an email that you wish to unsubscribe to carina @ projectevenkeel . com or by clicking the “unsubscribe” button at the bottom of any email we send the User from our list. The Website and Sole trader will continue to adhere to this Policy with respect to any personal information previously collected.

Information protection and disclosure

7.1 This Website and our Sole trader take precautions to protect the User’s information against unauthorised access, unlawful processing, accidental loss, destruction, and damage. Any information submitted to the Sole trader via the Website is protected both online and offline. However, no method of transmission over the Internet or method of electronic storage is 100% guaranteed, therefore we can only guarantee a reasonable level of absolute security of the User’s personally identifiable information.

7.2 Wherever this Website collects sensitive information, that information is encrypted and transmitted to the Sole trader in a secure way. The User can verify this by looking for a lock icon in the address bar and/or looking for “https” at the beginning of the address of the Web page.

7.3 While this Website uses encryption to protect sensitive information transmitted online, we also protect User information offline. Only employees who need the information to perform a specific job are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

7.4 Our Sole trader business has determined it is not required to appoint a Data Protection Officer as our core activities do not consist of processing operations that require regular and systematic monitoring of data subjects, nor do we process sensitive categories of data on a large scale.

How long we keep your information

8.1 The data this Website collects from the User will be stored no longer than necessary, based on how long User information remains relevant, the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations, any limitation periods prescribed by law within which claims might be made, the type of contract we have with the User, the existence of consent and our legitimate interest in keeping such information as stated in this Policy. In any event, only for as long as the Data Protection Legislation allows.

GDPR compliance

9.1 In order to ensure compliance with the European Union’s General Data Protection Regulation (“GDPR”) this Website and Sole trader confirms we have lawful grounds for processing the information we collect from the User. If the User provides personal information via the Website “contact us” page or sends us any other form of electronic communication, we will process the User’s data based upon our legitimate interest to respond to User or customer inquiries. If the User elects to receive communication from our Sole trader business by “opting in” and provides us with their name and email address in exchange for a free resource, training or services, or if the User makes a purchase from us, we will process User data for the purpose it was collected based on affirmative consent to do so, and may periodically send additional email marketing based upon our legitimate interest in marketing to those that have shown an interest in our products or services. The Sole trader may also give the User the option to be added to our email list, in order to receive our newsletter, information about our products and services, and other information we believe may be of interest to the User based upon their decision to opt-in to one or more of our free resources and will obtain User consent to do so. The User may withdraw consent at any time by contacting us and requesting your information be edited, updated, or deleted. We do not collect any sensitive data, nor any information regarding criminal offences or convictions.

9.2 The data controller responsible for the User’s personal information for the purposes of GDPR compliance is: Carina Tudor Sfetea, carina @ projectevenkeel . com.

9.3 For more information regarding the User’s rights to their Personal Information in the European Union, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

Governing law

10.1 Any claim relating to Project Even keel / Carina Tudor Sfetea or this Website shall be governed by the laws of the United Kingdom without regard to its conflict of law provisions.

How to contact us

12.1 If the User has any questions or concerns regarding the Policy related to our Website, please feel free to contact us at the following email address: carina @ projectevenkeel . com. If the User feels that the Website is not abiding by this Policy, they should contact us immediately.

SUMMARY / MAIN POINTS:

What data do we collect, how do we collect data, how are the data used?

Any data provided by you by using this website and its services in any way will be used based on my legitimate interest in communicating with you. These data may be used to keep records of this communication.

Analytics

This website collects personal data to power our site analytics, including:

• Information about your browser, network, and device

• Web pages you visited prior to coming to this website

• Your IP address

This information may also include details about your use of this website, including:

• Clicks

• Internal links

• Pages visited

• Scrolling

• Searches

• Timestamps

We share this information with Squarespace, our website analytics provider, to learn about site traffic and activity.

Visitor data

For website visitors

This website is hosted by Squarespace. Squarespace collects personal data when you visit this website, including:

Information about your browser, network and device

Web pages you visited prior to coming to this website

Web pages you view while on this website

Your IP address

Squarespace needs the data to run this website, and to protect and improve its platform and services. Squarespace analyses the data in a de-personalised form.

For form submissions

When you submit information to this website via webform, we collect the data requested in the webform in order to track and respond to your submissions. We share this information with Squarespace, our online store hosting provider, so that they can provide website services to us. We also share this information with Google for storage.

Scheduling

When you schedule an appointment by booking on this website via Acuity Scheduling, we collect personal information from you to complete the booking. We may collect information like your:

• Name

• Email address

• Phone number

• Details relating to your appointment (for example, who referred you)

• Files you uploaded

We share this information with Squarespace, our scheduling service provider, so that they can provide online booking services to us.

Squarespace Payments

When you make a purchase from us on this website, we use Squarespace Payments as our payment solution. Squarespace Payments is a fully integrated, native payment solution provided to us by our online store service provider Squarespace. Squarespace Payments makes use of the following third party service providers which will also receive your personal information and process it in accordance with their privacy policies:

• PayPal - payment processing services. You can read PayPal’s privacy policy at https://www.paypal.com/uk/legalhub/privacy-full.

Emails

Order and account emails

We may email you with messages about your order or account activity. For example, we may email you to tell you that:

• You’ve created a customer account

• Your customer account password has been reset or updated

• You’ve made a purchase

• Your order has shipped

It’s not possible to unsubscribe from these messages.

We share your contact information with Squarespace, our website hosting provider, so they can send these emails to you on our behalf.

Marketing emails

We may send you marketing emails, which you can unsubscribe from by clicking the link at the bottom of the email or contacting us via the specified methods. We share your contact information with Squarespace, our email marketing provider, so they can send these emails on our behalf.

Fonts

This website serves font files from and renders fonts using Google Fonts and Adobe Fonts. To properly display this site to you, these third parties may receive personal information about you, including:

• Information about your browser, network, or device

• Information about this site and the page you’re viewing on it

• Your IP address

How are your data stored?

The computers/servers in which we store personally identifiable information are kept in a secure environment, and we maintain reasonable safeguards to protect data against any unlawful form of use or processing; however, no methods of information transmission or storage on the internet is 100% secure, and so, you use the website at your own risk.

The data provided by you will be stored no longer than necessary, depending on the way in which you have engaged with the website or our services.

Data sharing

Very limited situations exist in which users’ confidential information may be shared - these include sharing with services that provide technical, legal, or accounting support to Project Even Keel/Carina Tudor Sfetea (in which case these services or individuals will be bound by the same policy of keeping the information confidential), where there is a legal or any governmental need or requirement, or where we believe, in good faith, that this is necessary to protect ourselves and our rights from e.g., but not limited to, fraudulent activity or liability.

Third-party websites

This website contains links to third-party websites, which have their own data controllers and privacy policies. This privacy policy applies to this website only.

This website may also receive data from third parties like Google Analytics, Facebook and other advertising platforms which have been deemed GDPR-compliant. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the website or services. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

We may use data you provide to send targeted social media advertisements or upload your information into our social media account(s) to create look-a-like audiences.

Cookies 

This website uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app. For information about viewing the cookies dropped on your device, visit The cookies Squarespace uses.

• These functional and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you.

• These analytics and performance cookies are used on this website, as described below, only when you acknowledge our cookie banner. This website uses analytics and performance cookies to view site traffic, activity, and other data.

For further information, visit allaboutcookies.org.

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

What are your data protection rights?

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• The right to access – You have the right to request Project Even Keel/Carina Tudor Sfetea for copies of your personal data. We may charge you a small fee for this service.

• The right to rectification – You have the right to request that Project Even Keel/Carina Tudor Sfetea correct any information you believe is inaccurate. You also have the right to request Project Even Keel/Carina Tudor Sfetea to complete the information you believe is incomplete.

• The right to erasure – You have the right to request that Project Even Keel/Carina Tudor Sfetea erase your personal data, under certain conditions.

• The right to restrict processing – You have the right to request that Project Even Keel/Carina Tudor Sfetea restrict the processing of your personal data, under certain conditions.

• The right to object to processing – You have the right to object to Project Even Keel/Carina Tudor Sfetea’s processing of your personal data, under certain conditions.

• The right to data portability – You have the right to request that Project Even Keel/Carina Tudor Sfetea transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: carina @ projectevenkeel . com

More information regarding your rights to personal information in the European Union is available here: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.