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> 1  300  000 FOLLOWERS

Privacy Policy

If we link to this Privacy Policy from our official social media profiles, the following information applies only insofar as the processing takes place within our area of responsibility and provided that no more specific privacy notices are made available for the respective social media profile.

1. Controller

The controller responsible for data processing on this website and in connection with our official social media presences is:

Open Mind Consulting GmbH
Kantstr. 44
22089 Hamburg
Germany

Email: germany@apalienko.com

Represented by the managing directors:
Maksim Burskyi
Oleksandr Paliienko
Diana Kustovskaya

2. Scope

This Privacy Policy applies to:

  • our website: https://apalienko.com/en/
  • inquiries by email and contact form
  • orders, shopping cart and contract processing via our website
  • our newsletter
  • our official social media presences

Facebook:

https://www.facebook.com/people/Alexander-Palienko/61576637321952/

https://www.facebook.com/AlexandrPalienko.seminary

https://www.facebook.com/profile.php?id=61577210894098

Instagram:

https://www.instagram.com/alexander_paliens/

https://www.instagram.com/alexanderpalienko/

https://www.instagram.com/alexander_paliens/

Threads:

https://www.threads.com/@alexander.paliens?igshid=NTc4MTIwNjQ2YQ==

https://www.threads.com/@alexander_paliens?igshid=NTc4MTIwNjQ2YQ==

https://www.threads.com/@alexanderpalienko?igshid=NTc4MTIwNjQ2YQ==

YouTube:

https://www.youtube.com/@AlexanderPaliens

https://www.youtube.com/@Palienko

https://www.youtube.com/@Alexander.Paliens

TikTok:

https://www.tiktok.com/@apalienko.eng?_t=ZM-8zyAxWIopL6&_r=1

https://www.tiktok.com/@apalienko?_r=1&_t=ZS-977vqchJ9L3

https://www.tiktok.com/@apalienko.espanol?_t=ZM-8zyB4Hjhy5w&_r=1

This Privacy Policy does not apply to third-party websites and services to which we merely provide links.

3. Legal bases for processing

Where we obtain your consent, the legal basis is Art. 6(1)(a) GDPR.

Where processing is necessary for the performance of a contract or for carrying out pre-contractual measures, the legal basis is Art. 6(1)(b) GDPR.

Where processing is necessary for compliance with a legal obligation, the legal basis is Art. 6(1)(c) GDPR.

Where processing is necessary for the purposes of our legitimate interests or those of a third party and no overriding interests, fundamental rights or freedoms stand in the way, the legal basis is Art. 6(1)(f) GDPR.

Where we store information in end devices or access information in end devices, the permissibility is additionally governed by Section 25 TDDDG.

4. Provision of the website and server log files

When our website is accessed, our hosting provider or web server automatically collects technical access data. In particular, the following data may be processed:

  • IP address
  • date and time of access
  • page / file accessed
  • referrer URL
  • browser type and browser version
  • operating system
  • hostname of the accessing computer
  • language settings
  • amount of data transferred
  • access status / HTTP status code

Processing takes place for the technical provision of the website, to ensure security and stability, and to prevent misuse.

The legal basis is Art. 6(1)(f) GDPR.

Storage period: The log files are stored for 30 days and then deleted unless longer retention is required for evidentiary or security purposes.

5. Contact by email, contact form, telephone or messenger

If you contact us, we process the data you provide to handle your inquiry.

Depending on the nature of the inquiry, the following data in particular may be processed:

  • first and last name
  • email address
  • telephone number
  • content of the message
  • other information voluntarily provided

Processing takes place in order to handle your inquiry, communicate with you and, if applicable, initiate or perform a contract.

Legal bases:

  • Art. 6(1)(b) GDPR where pre-contractual measures or contract performance are concerned
  • Art. 6(1)(f) GDPR in other cases

Storage period: The data will be deleted once your inquiry has been conclusively processed and there are no legal retention obligations or other legitimate grounds for further storage.

6. Orders, shopping cart, digital products and contract processing

If you order products or services via our website, we process the data required for contract handling, in particular:

  • first and last name
  • billing address and, if applicable, delivery address
  • email address
  • order data
  • payment data or payment status
  • contractual and transaction data

Processing takes place for the performance of the contract, payment processing, provision of digital content, customer support and compliance with commercial and tax law obligations.

Legal bases:

  • Art. 6(1)(b) GDPR
  • Art. 6(1)(c) GDPR

Recipients: Where we use external payment service providers, shop systems, shipping service providers or accounting service providers, they receive the data required for the respective service.

Storage period: We store contractual and billing data within the framework of the statutory retention obligations.

7. Newsletter

If you subscribe to our newsletter, we process your email address and, if applicable, other data voluntarily provided by you for the purpose of sending the newsletter.

Registration takes place using the double opt-in procedure. In doing so, we store the time of registration, the time of confirmation and technical proof data insofar as this is necessary to prove consent.

The legal basis is Art. 6(1)(a) GDPR.

You can revoke your consent at any time with future effect, in particular via the unsubscribe link in the newsletter or by email to: germany@apalienko.com

If we measure open rates or click rates, we will inform you separately of this. If information is stored on or read from your end device in this context, this will only take place on the basis of your consent pursuant to Section 25(1) TDDDG and Art. 6(1)(a) GDPR.

8. Direct advertising to existing customers / product information

Where we send product information or notices about similar own services in connection with an existing customer relationship, this is done on the basis of the legal requirements for direct advertising and our legitimate interest in customer communication.

The legal basis is Art. 6(1)(f) GDPR, provided that the requirements are met in the individual case.

You may object to the processing of your data for direct advertising purposes at any time with future effect.

9. Consent management, cookies and similar technologies

On our website, we use technically necessary and – only with your consent – optional cookies and similar technologies.

9.1 Technically necessary technologies

Technically necessary cookies and similar technologies serve to provide the website securely and functionally and to enable the basic functions requested by you.

Legal bases:

  • Section 25(2) TDDDG
  • Art. 6(1)(f) GDPR

9.2 Technologies requiring consent

Where we use analytics, marketing, convenience functions or external media services, this only takes place after your express consent.

Legal bases:

  • Section 25(1) TDDDG
  • Art. 6(1)(a) GDPR

9.3 Withdrawal of your consent

You may withdraw any consent granted at any time with future effect. You may also delete cookies already stored at any time via your browser settings and restrict the storage of cookies there. Please note that this does not affect the lawfulness of processing carried out before the withdrawal.

10. Web analytics

10.1 Google Analytics 4

If activated, we use Google Analytics 4, a web analytics service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics helps us analyse the use of our website and understand reach, interactions and technical usage patterns. In particular, usage data, device information, approximate location data, page views, interaction data and identifiers may be processed.

We use Google Analytics only on the basis of your consent.

Legal bases:

  • Section 25(1) TDDDG
  • Art. 6(1)(a) GDPR

Storage period: The storage period depends on our specific configuration in Google Analytics and the retention periods stored there.

Further information:
https://policies.google.com/privacy
https://support.google.com/analytics

11. External content and social media integrations on the website

11.1 YouTube videos

YouTube videos may be embedded on our website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

When such content is loaded, personal data, in particular the IP address as well as device and usage data, may be transmitted to Google/YouTube.

Unless the integration is purely local or technically neutral, we only load such content after your consent.

Legal bases:

  • Section 25(1) TDDDG
  • Art. 6(1)(a) GDPR

11.2 Meta / Instagram / Threads content

Content or functions from Meta may be embedded on our website. The provider is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

When such content is loaded, personal data such as the IP address, browser data or usage data may be processed.

Where this is not a purely static link, this only takes place after your consent.

Legal bases:

  • Section 25(1) TDDDG
  • Art. 6(1)(a) GDPR

11.3 TikTok content

Content or functions from TikTok may be embedded on our website. The provider is TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland, and/or affiliated companies.

When such content is loaded, personal data, in particular the IP address, browser data and usage data, may be processed.

Where this is not a purely static link, this only takes place after your consent.

Legal bases:

  • Section 25(1) TDDDG
  • Art. 6(1)(a) GDPR

12. Our official social media presences

We maintain official presences on social networks in order to communicate with interested parties, customers and users, provide content, present our services and evaluate reach.

If you visit our social media presences or interact with us there, we may in particular process the following data:

  • profile name / username
  • public profile data
  • comments
  • direct messages
  • reactions / likes
  • interaction and reach data
  • other content you provide to us

Processing takes place for communication, handling inquiries, external presentation and analysis of our reach.

Legal bases:

  • Art. 6(1)(f) GDPR
  • in the case of contract-related contacts, additionally Art. 6(1)(b) GDPR

Please note that the platform operators also process personal data on their own responsibility in accordance with their own privacy policies.

Insofar as Meta provides us with insights / statistics data for Facebook, Instagram or Threads presences, joint controllership with Meta may exist for this, insofar as provided for by Meta.

Further information:
https://privacycenter.instagram.com/policy
https://www.facebook.com/legal/terms/page_controller_addendum
https://policies.google.com/privacy
https://www.tiktok.com/legal/privacy-policy-eea

13. Recipients and categories of recipients

Within our company, only those departments have access to personal data that require it for the fulfilment of the respective purposes.

In addition, personal data may – where necessary – be transferred to the following categories of recipients:

  • hosting service providers
  • IT and security service providers
  • consent management providers
  • analytics, advertising and marketing service providers
  • newsletter service providers
  • payment service providers
  • shop / checkout service providers
  • shipping service providers
  • communication and support service providers
  • operators of social networks
  • consultants, tax advisors, lawyers, auditors
  • authorities and public bodies where required by law

Where we use processors, this is done on the basis of a contract pursuant to Art. 28 GDPR.

14. Transfers of data to third countries

A transfer of personal data to third countries outside the EU or the EEA may take place, in particular, if we use services of international providers or load content from external platforms.

Where data are transferred to third countries, this takes place only in compliance with the legal requirements, in particular on the basis of an adequacy decision, appropriate safeguards such as standard contractual clauses or – where applicable – your express consent.

Please note that on platforms such as Meta, Google/YouTube or TikTok, additional processing operations may take place outside our immediate sphere of influence.

15. Storage period

We store personal data only for as long as this is necessary for the respective purposes or as long as statutory retention obligations exist.

16. Rights of data subjects

Within the scope of the legal requirements, you have in particular the following rights:

  • right of access
  • right to rectification
  • right to erasure
  • right to restriction of processing
  • right to data portability
  • right to object to processing on the basis of Art. 6(1)(f) GDPR
  • right to withdraw consent with effect for the future
  • right to lodge a complaint with a data protection supervisory authority

17. Obligation to provide data

Where the provision of personal data is required by law or contract or is necessary for the conclusion of a contract, we will inform you of this in each individual case. Without the necessary data, we may not be able to provide certain services in some cases.

18. Automated decisions / profiling

We do not carry out exclusively automated decision-making within the meaning of Art. 22 GDPR unless something else is expressly stated in this Privacy Policy.

19. Security of data processing

We take technical and organisational measures to protect your data against loss, destruction, access, alteration or dissemination by unauthorised persons. This includes in particular – where technically implemented – encrypted transmission via HTTPS/TLS.

20. Currency and amendments to this Privacy Policy

We adapt this Privacy Policy if this is necessary due to changes in the legal situation, technical changes or adjustments to our services. The version published on our website at the relevant time shall apply.

As of: 28.05.2026