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. Amended October 2026: when our booking calendar is full and you book your call on Calendly's own page instead, that booking (the "schedule" event) is reported to Google Analytics from our server (Google Analytics Measurement Protocol) rather than from your browser, so that a closed tab does not lose it. For this, your browser's Google tag hands our server its pseudonymous Google Analytics client identifier and, where available, its session identifier. We transmit the client identifier, the session identifier only where the booking still falls within that analytics session, the time of the booking, the event type with the name of our booking form, and the consent signals Google Analytics uses (advertising user data permitted, ad personalisation not permitted) - no name, email address, phone number or form answer is sent to Google this way. It follows the same consent rules as Google Analytics in your browser (see Section 10): where consent is required, only after you accepted cookies; and it stops if you withdraw your consent or your browser sends a Global Privacy Control signal.
• Advertising data (Meta Pixel and Meta Conversions API): Where the Meta Pixel is active, it records page views, enquiries and eligibility assessments that leave us your contact details ("Lead" event), and bookings ("Schedule" event). The "Lead" event does not wait for a completed assessment: it is recorded as soon as an assessment has left us an email address and a phone number in international format, whether or not the assessment is finished or the page is closed afterwards. A confirmed booking normally records both events - the booking itself and, under the same daily identifier, the "Lead" - so an assessment abandoned in the morning and the call booked that afternoon count as one lead and not two. Where the booking reaches us without a usable phone number in international format, only the booking is recorded and no "Lead" is: the same bar applies to a booking as to an enquiry, and a contact detail we cannot use is not turned into a conversion. Meta Platforms, Inc. receives a pseudonymous browser identifier, your IP address, the page URL, and the event type. Amended September 2026: the two events that name a person - "Lead" and "Schedule" - are also transmitted from our server through Meta's Conversions API, so that a blocked or interrupted browser does not lose the measurement. Amended October 2026: a message you send us from one of our message pages (for example /lp/us/message or /es/lp/cl/mensaje, in every country we serve) is additionally recorded as a "Contact" event. It is transmitted only from our server, only after we have stored your message, and carries your email address, phone number and name in hashed form together with the technical identifiers described here - never the text of your message or your answers. A message sent from a restitution message page is reported under the address of the message page of the same country (for example /lp/us/message), without any reference to restitution. Page views are not sent that way: the browser pixel still records them where it is active, but nothing about a page view is transmitted a second time from our server. That transmission carries your email address, phone number, name and country of residence in irreversibly hashed form (SHA-256), together with your IP address, browser user agent, the address of the page the event happened on, and Meta's own click and browser identifiers. Your country of residence is one of your form answers, and it is the only one that travels: no ancestry, family, citizenship-status, religion or free-text detail ever leaves our systems this way. When this happens depends on where you are (amended September 2026): in the EU, the UK, Switzerland, the EEA, Quebec, New Jersey and Maryland nothing is recorded or transmitted until you accept the consent banner - and the same applies whenever we cannot tell which country you are in, because we would otherwise be guessing in our own favour. If we know you are in the United States or Canada but not in which state or province, you are treated like the rest of that country. In the remaining cases - including the rest of the United States, Canada and Latin America - it is active by default and you can opt out at any time via "Cookie Settings" or the Global Privacy Control signal. If your browser sends that signal, it takes precedence over an acceptance you gave earlier, and pressing "Accept" while it is on changes nothing: nothing loads and nothing is measured, the banner says so, and your answer is kept for the moment you switch the signal off again. If you decline or opt out, neither the pixel nor the server transmits anything. We transmit the Limited Data Use (LDU) signal on every event; it instructs Meta to apply the restricted processing required by United States state privacy laws, and Meta determines from the event which state's rules apply. Events already transmitted cannot be recalled; withdrawing consent stops future ones.

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 §15 of the German Nationality Act (StAG), this information may reveal religious affiliation or a family history of persecution. You provide the supporting documents during client onboarding (by email or shared drive folder); our online eligibility assessment also collects some ancestry details at the inquiry stage, such as ancestor names and any family-history notes you add. We use this information solely to assess your eligibility and provide our services.

Eligibility assessment. The details you enter in our eligibility assessment are stored in our internal case management system, including when you do not complete the assessment. You can request deletion at any time at info@athena-genealogy.com.

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 - or, where the tools are active by default, opt out via "Cookie Settings" or the Global Privacy Control signal - the Meta Pixel is not loaded at all and no data is transmitted to Meta, from your browser or from our server. We transmit the Limited Data Use (LDU) signal with every event, which instructs Meta to apply the restricted processing required by United States state privacy laws.

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 - and since September 2026 it outranks an acceptance you gave earlier, because the signal is the later statement (CCPA regulations, 11 CCR section 7025(c)(3)). While your browser sends it, nothing is shared even if a "yes" is stored from a previous visit, and pressing "Accept" while it is on changes nothing. Your stored choice is not erased: it applies again if you switch the signal off.
• 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, the United Kingdom, Switzerland and the European Economic Area, and since September 2026 also visitors in Quebec, New Jersey and Maryland, see an opt-in consent banner, and these tools stay off until they accept. A visitor we can place in the United States or Canada but not in a state or province is treated like the rest of that country. The same banner is shown to anyone whose location we could not determine at all. While that is the case nothing is loaded and nothing already stored is deleted either: click identifiers from an earlier visit through an ad stay on your device unused - not read, not sent, not shared - until we know where you are and that place does not require consent first, or until you accept. They are deleted when you decline, send a Global Privacy Control signal, or - as long as you have not accepted anything - we learn that you are somewhere that does require consent. An acceptance you have given stands. Visitors elsewhere - including the rest of the United States, Canada and Latin America - have these tools enabled by default and can opt out at any time via "Cookie Settings" in the website footer, the Global Privacy Control signal, 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: