Privacy Policy

1. Information We Collect

We collect personal information that you voluntarily provide when you submit our contact form:

• Identifiers: Full name, email address, phone number (optional)
• Commercial information: Investment comfort level (budget range)
• Communication data: Subject and message content, how you heard about us (source attribution)

We also automatically collect limited information, only after you accept cookies:

• Analytics data (Google Analytics 4): If you accept cookies, Google Analytics 4 sets the _ga and _ga_* first-party cookies and measures aggregate traffic, sessions, traffic sources, and the same conversion events as the Meta Pixel below (page_view, generate_lead, schedule). IP-anonymisation is enabled, Google Signals is disabled, and we have disabled all advertising personalisation and ad-data-sharing in our Google Analytics property settings.
• Advertising data (Meta Pixel):If you accept cookies, the Meta Pixel records page views, completion of our eligibility pre-screening form ("Lead" event), and Calendly bookings ("Schedule" event). Meta Platforms, Inc. receives a pseudonymous browser identifier, your IP address, the page URL, and the event type. For California residents we transmit the Limited Data Use (LDU) signal, which instructs Meta to apply CCPA-restricted processing.

2. How We Use Your Information

We use the personal information we collect for the following purposes:

• To respond to your inquiry and provide genealogy consulting services
• To send you a confirmation email after form submission
• To improve our website and services through anonymous analytics
• To measure the performance of our advertising on Facebook and Instagram and build advertising audiences (e.g. lookalike audiences) - only after you accept cookies
• To comply with legal obligations

3. Service Providers (Third Parties)

We share your personal information with the following categories of service providers, solely for the purposes described above:

4. Sale or Sharing of Personal Information

We do not sell your personal information.

However, once you accept cookies, we use the Meta Pixel to measure the performance of our advertising on Facebook and Instagram. Under California law (CCPA/CPRA), sending pseudonymous identifiers to Meta for advertising-performance measurement and audience building is classified as "sharing personal information for cross-context behavioral advertising."

You can opt out of this sharing at any time by:

• Clicking "Decline" on our cookie consent banner
• Opening "Cookie Settings" in our website footer and selecting "Decline"
• Visiting our Do Not Sell or Share page

If you decline, the Meta Pixel is not loaded at all - no data is transmitted to Meta. For California residents who accept cookies, we transmit the Limited Data Use (LDU) signal, which instructs Meta to apply CCPA-restricted processing.

5. Your Rights Under the CCPA/CPRA (California Residents)

If you are a California resident, you have the following rights:

• Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You may request that we delete the personal information we have collected from you, subject to certain exceptions.
• Right to Correct: You may request that we correct inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale/Sharing:We do not sell personal information. We share pseudonymous identifiers with Meta Platforms, Inc. for advertising-performance measurement, which qualifies as "sharing for cross-context behavioral advertising" under the CCPA. You can opt out by clicking "Decline" on our cookie consent banner or in the "Cookie Settings" dialog accessible from our website footer, or by visiting our Do Not Sell or Share page.
• Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information beyond what is necessary to provide our services.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

To exercise any of these rights, please contact us at info@athena-genealogy.com. We will respond to your request within 45 days as required by law.

5a. Other US State Privacy Laws

If you are a resident of a US state with a comprehensive consumer privacy law - including but not limited to Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon, Montana, Iowa, Tennessee, Indiana, Delaware, New Hampshire, New Jersey, Maryland, Minnesota, Rhode Island, Kentucky, or Nebraska - you have substantially similar rights as those described in the California section above (right to know, delete, correct, and opt out of sale/sharing or targeted advertising). You can opt out of targeted advertising and the sharing of pseudonymous identifiers with Meta Platforms, Inc. by clicking "Decline" on our cookie consent banner or in the "Cookie Settings" dialog. To exercise any other right, contact us at info@athena-genealogy.com.

6. Data of Minors

Our services are not directed at individuals under the age of 16. We do not knowingly collect personal information from minors. If we learn that we have inadvertently collected personal information from a person under 16, we will promptly delete that information. Under the CCPA/CPRA, personal information of consumers under 16 is automatically classified as sensitive personal information.

7. Data Retention

We retain your personal information for up to 24 months after your last interaction with us, unless a longer retention period is required by law or necessary for the establishment, exercise, or defense of legal claims. After the retention period, your data is securely deleted.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. All data transmissions are encrypted using TLS/SSL. However, no method of transmission over the Internet is 100% secure.

9. International Data Transfers

Our company is based in Dubai, United Arab Emirates. By submitting personal information through our Site, you acknowledge that your data may be processed in the UAE and/or the United States. In particular, our hosting (Vercel), email delivery (Resend), and business productivity tools (Google Workspace - Gmail, Drive, Sheets) operate on servers located in the United States, which means your contact information, message content, and related correspondence may be stored and processed there. We ensure that all data transfers comply with applicable data protection laws.

10. UAE Personal Data Protection Law (PDPL)

As a company registered in the UAE, we comply with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL). Under the PDPL, you have the right to access, rectify, and request deletion of your personal data. Requests can be directed to info@athena-genealogy.com.

11. Cookies and Tracking Technologies

Our Site uses a cookie consent banner. If you accept, we load Vercel Web Analytics (no cookies, no personal identifiers) and the Meta Pixel (sets _fbp and conditionally _fbc first-party cookies, shares data with Meta Platforms, Inc. for advertising-performance measurement). If you decline, neither tool loads at all. For full details, see our Cookie Policy.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. The "Last Updated" date at the top of this page indicates when the policy was last revised. We encourage you to review this page periodically. This policy is reviewed at least once every 12 months in accordance with CCPA requirements.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights: