Privacy Policy

Last updated: 11 August 2026

Personal data is processed in accordance with Legea nr. 133/2011 of the Republic of Moldova on the protection of personal data and, where the client is in the European Union, with the GDPR.

The operator is A.I. Ghenadi Nicolaev, IDNO 1026023035183, s. Congaz, str. Pionierii 5, Republic of Moldova, nikolaev.gd@gmail.com.

Sessions are not recorded. No audio or video recording of a session is made, stored or passed on. What is written down is only what is needed to carry on the work — notes on goals, agreements and next steps.

What data is collected

Contact details of the client — name and email address, and a messenger handle or phone number if you choose to write from one.
Information about the teenager, where the work concerns one — first name, age or school year, and what the parent tells us about studies, interests and the situation in the family. Only what the parent chooses to share.
Working notes — goals set during the sessions, agreements reached, what to return to next time.
Order details — which service was paid for, when, and the amount. Confirmation of payment comes from the payment provider.

Card details are never received: payment takes place on the page of the payment provider, and card data does not reach us at any point.

No special categories of data are asked for — no medical diagnoses, no psychological or psychiatric records. If a client mentions something of that kind in conversation, it is not recorded in the notes.

Data about a teenager

Where the work concerns a person under 18, the contract is concluded with the parent or legal guardian, who provides the information about the teenager and consents to it being processed for the purpose of the sessions. A teenager can ask at any time to see what is written about them, and a parent can ask for it to be corrected or deleted.

Why it is processed

To deliver the sessions and keep continuity between them.
To arrange times and stay in touch with you.
To keep the records that accounting and tax law require for payments received.

The legal basis is the performance of the contract with you and, for the records of payments, a legal obligation. No data is used for advertising, and none is sold or passed on to anyone for advertising purposes.

Who it is shared with

The payment provider — Creem (Armitage Labs OÜ, registry code 16977866, Telliskivi 57b/1, Tallinn 10412, Estonia), which acts as merchant of record and processes the payment. It receives the data needed for the transaction and handles it under its own privacy policy.
Email and video-call services used to correspond with you and to hold the sessions.
Specialists brought into the project — a tutor, a subject teacher — where the work involves assembling a team around the teenager. They are told only what they need for their own part of the work, and only with the prior agreement of the parent. Nothing is passed to them without asking you first.

Data is not shared with anyone else, except where disclosure is required by law.

How long it is kept

Working notes are kept while the work is going on and for one year after it ends, in case you come back and the history is useful. After that they are deleted. Records relating to payments are kept for the period required by tax and accounting legislation. You can ask for your data to be deleted earlier — see below.

Your rights

Under Legea nr. 133/2011, and under the GDPR if you are in the European Union, you have the right to obtain access to your data, to have it corrected or updated, to have it blocked or deleted, to object to processing, and to receive a copy of it.

Write to nikolaev.gd@gmail.com from the email address you use for the work. Requests are answered within 3 business days at the latest.

If you believe your data has been handled improperly, you may complain to the National Centre for Personal Data Protection of the Republic of Moldova (datepersonale.md), or, if you are in the EU, to the supervisory authority of your country.

This website

The site uses Yandex.Metrica to count visits and see which pages are read. It sets its own cookies and collects technical information about the visit — the pages opened, the browser, the approximate region. It is not used to identify you personally and is not linked to the data described above. You can block it in your browser settings or with any tracker-blocking extension.

Changes

Any change to this policy is published on this page with the date of the update shown.