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 when analytics and advertising tools are active (see Section 10):

• 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.

Client engagement data. If you become a client, we collect additional information needed to provide our services: genealogical and vital records (such as birth, marriage, and death certificates), copies of passports or other government-issued identification, and related family documents. In restoration cases under Article 116(2) of the German Basic Law or Section 15 of the German Nationality Act (StAG), these documents may reveal religious affiliation or a family history of persecution. This information is provided directly by you during client onboarding (by email or shared drive folder), is not collected through website forms, and is used solely to provide the services you have engaged us for.

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) - when the Meta Pixel is active (see Section 10)
• 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, when the Meta Pixel is active (see Section 10), we use it 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)

Athena Genealogy may fall below the statutory thresholds at which the CCPA/CPRA becomes binding on a business. We nevertheless extend the following rights to California residents voluntarily and to the extent applicable. 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. We also honor the Global Privacy Control (GPC) signal from your browser as a valid opt-out of sharing when you have not made an explicit consent choice.
• 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). These state laws generally apply only to businesses above certain data-volume thresholds; we honor these rights for all US residents as a courtesy, regardless of whether a particular statute applies to us. 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. For clients, engagement records are retained for the duration of the engagement and thereafter as required for legal, tax, and accounting purposes.

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. In the event of a breach of security affecting your unencrypted personal information, we will provide notice in accordance with the Florida Information Protection Act (Fla. Stat. 501.171) and other applicable breach-notification laws.

9. International Data Transfers

Athena Genealogy LLC is based in Estero, Florida, United States. If you are located outside the United States and submit personal information through our Site, you acknowledge that your data will be processed in 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.

Visitors from the EEA, United Kingdom, and Switzerland. If you visit our Site from the European Economic Area, the United Kingdom, or Switzerland, analytics and advertising tools stay off until you accept them through our consent banner. Where the data protection law of your home jurisdiction applies to you, you may also have rights to access, rectification, erasure, and objection under that law. To exercise any of these rights, contact us at info@athena-genealogy.com.

10. Cookies and Tracking Technologies

Our Site uses Google Analytics 4 and the Meta Pixel. Visitors in the European Union, United Kingdom, and European Economic Area see an opt-in consent banner, and these tools stay off until they accept. Visitors elsewhere (including the United States) have these tools enabled by default and can opt out at any time via "Cookie Settings" in the website footer or our Do Not Sell or Share page. Your choice is stored in your browser (localStorage key athena_consent). For full details, see our Cookie Policy.

11. 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.

12. Contact Us

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