01 / Scope and service status
This Privacy Policy explains how Valerii Voinovskyi, operating under the EffDes Agency brand, handles information through the EffDes Agency website, including business enquiries, support and privacy requests.
UTM Contact Attribution is a pre-release product and is not represented here as an App Market production service. Its final production providers, retention rules, international-transfer setup and uninstall behavior will be documented before public release.
02 / Website information we process
Agency enquiries include the name, work email and business challenge submitted through the form, plus any optional company or website, desired result, timeframe and additional context. The form also records the landing page, referrer, available UTM source, medium, campaign, term and content values, GCLID, submission identifier and submission time.
The website does not use advertising trackers or third-party analytics. Normal hosting and security operations may process technical request data such as IP address and browser or request metadata.
03 / How website information is used
Website information is used to understand and respond to Agency enquiries, preserve relevant enquiry context, secure and troubleshoot the website, respond to support and privacy requests, maintain necessary business records and meet applicable legal obligations.
EffDes does not sell enquiry information or use it to build an unrelated contact database.
04 / UTM Contact Attribution — pre-release
The product is being developed for Wix and has not been released through the Wix App Market. Product pages describe intended functionality and current development direction; they do not establish final production processing terms.
Before release, EffDes will finalize and publish the app-specific categories of information, purposes, production providers, retention and deletion rules, uninstall behavior, international-transfer setup and any applicable commercial terms. No paid-product billing, cancellation or refund policy applies until a paid product is actually offered.
05 / Website infrastructure and processors
Cloudflare Pages serves the website and its enquiry endpoint. Cloudflare D1 stores submitted Agency enquiries and their attribution fields. The production D1 database was created with an Eastern Europe location hint, which optimizes placement but is not a legal data-residency restriction.
No email delivery service, analytics service, advertising platform or other provider is configured by this website to receive submitted enquiry content.
06 / Website data sharing
Website information is processed by Cloudflare to provide the hosting, request handling, security and database services described above. It may also be disclosed when required by law or valid legal process, to protect rights and service security, or in connection with a business reorganization subject to appropriate safeguards.
EffDes does not authorize service providers to use enquiry information for their own unrelated marketing.
07 / Security
EffDes uses technical and organizational measures intended to protect information against unauthorized access, alteration, disclosure and loss. Measures are selected according to the nature of the information and service. No internet service or storage system can be guaranteed completely secure.
08 / Website enquiry retention
Agency enquiries and related attribution data may be retained for up to 24 months after the last meaningful interaction, then deleted or anonymized. Information may be kept longer where required by a legal obligation, for the establishment, exercise or defense of legal claims, or while an active contractual relationship requires the record.
App-specific retention and deletion rules remain pre-release and will be finalized before an App Market release.
09 / Privacy rights
Depending on location and applicable law, individuals may have rights to request access, correction, deletion, restriction, objection, portability or withdrawal of consent.
Requests concerning EffDes website processing can be sent to support@effdes.agency. Identity and authority may need to be verified before a request is completed.
10 / Website international processing
The operator is based in Kyiv, Ukraine. Cloudflare operates a global network, so website requests and related technical metadata may be processed outside Ukraine and the visitor’s country. Cloudflare states that some metadata is processed in the United States and Europe.
Where European or UK data-protection rules require safeguards for restricted transfers, Cloudflare’s Data Processing Addendum provides for the applicable EU Standard Contractual Clauses, UK Addendum and additional safeguards. The final international-transfer setup for UTM Contact Attribution will be documented before App Market release.
11 / Children
The Agency website and pre-release product information are directed to businesses and are not designed for children. EffDes does not knowingly seek personal information directly from children through the website.
12 / Policy changes
This policy may be updated when the services, processing practices or legal requirements change. The effective date will be revised, and material changes will be communicated through an appropriate service or account channel when required.
13 / Contact
Privacy requests can be started through support@effdes.agency.
UTM Contact Attribution is operated by Valerii Voinovskyi under the EffDes Agency brand.
49 Heroiv Dnipra Street, Kyiv, 02000, Ukraine