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Privacy

Privacy notice

Plain English, short as we can make it. This website has no cookies, no analytics and no forms.

Draft for review. This notice is not final until it has been checked by the founder and a qualified lawyer.

Last updated: [CEO TO CONFIRM: publication date]

1. Who we are

LogiSpirit is an AI automation studio based in Colombo, Sri Lanka. For the personal data described here, the data controller is [CEO TO CONFIRM: legal name of the business, for example "Devaka Dabare, trading as LogiSpirit", or the registered company name and registration number if one exists].

  • Email: hello@logispirit.com
  • Postal address: [CEO TO CONFIRM: postal address for privacy requests]
  • EU and UK representative: [CEO TO CONFIRM after legal review: whether a representative is needed under Article 27 of the EU GDPR and UK GDPR and, if so, their name and contact details]

Data Protection Officer: [CEO TO CONFIRM after legal review: whether a Data Protection Officer must be designated (the Sri Lanka PDPA may require one) and, if so, their contact details]

2. What we collect

We only collect what you choose to send us, plus the basic technical data that every website needs to work.

  • Emails you send us. Your name, email address and whatever you write, including any files you attach.
  • Call bookings. When you click "Book a call", you leave this site and go to our booking page on Cal.com. There you give your name, email address, the time you picked and your answers to three short questions (your team size, the task you want to automate and the tools you use).
  • Technical data. Our hosting provider, Cloudflare, processes your IP address, browser type and the pages you request so that it can deliver the site and protect it from attacks. We don't use this data to identify you.

What we don't do: this website has no contact forms, no cookies, no analytics, no tracking pixels, no advertising, and no third-party fonts or scripts. We don't sell or rent your data.

3. Why we use it, and our legal basis

  • To reply to you and arrange a call. Under the EU and UK GDPR, our legal basis is our legitimate interest in answering enquiries about our services, and taking steps you've asked for before entering into a contract (Article 6(1)(f) and 6(1)(b)).
  • To prepare a quote and, if you go ahead, deliver the work. Basis: steps before a contract, and then performing the contract (Article 6(1)(b)).
  • To keep the website secure. Basis: our legitimate interest in protecting the site and its visitors (Article 6(1)(f)).
  • To keep business and tax records if you become a client. Basis: legal obligation (Article 6(1)(c)).

Under Sri Lanka's Personal Data Protection Act, No. 9 of 2022 (PDPA), we rely on the matching lawful grounds in that Act: steps before or for a contract, compliance with a legal obligation, and legitimate interests. [CEO TO CONFIRM after legal review: the PDPA grounds relied on, and which PDPA provisions are in force at launch]

We don't make decisions about you based solely on automated processing.

4. Who else handles your data

We use a small number of service providers who process data on our behalf, under their own data-processing terms:

  • Cloudflare (website hosting, DNS and security). Cloudflare privacy policy
  • Cal.com (call booking). Cal.com privacy policy
  • Our email provider: [CEO TO CONFIRM: email provider, for example Zoho Mail or Google Workspace, or Cloudflare Email Routing forwarding to another inbox, with a link to its privacy policy]
  • Video call tool for the call itself: [CEO TO CONFIRM: video tool used for calls, for example Google Meet, Zoom or Cal Video, with a link to its privacy policy]

We only share your data with anyone else if the law requires it, or with your permission.

5. International transfers

We are based in Sri Lanka, so your data is handled there. Our service providers may also process it in the United States, the EU or the UK. Where EU or UK law requires it, these transfers are protected by recognised safeguards, such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or the EU-US Data Privacy Framework where the provider is certified. Cross-border transfers from Sri Lanka follow the rules in the PDPA.

[CEO TO CONFIRM after legal review: the transfer safeguards each provider actually uses, and the PDPA cross-border transfer position at launch]

6. How long we keep it

  • Enquiry emails and booking details (if you don't become a client): up to [CEO TO CONFIRM: 24 months] after our last contact, then deleted.
  • Client records (contracts, invoices and related emails): for as long as tax and company law requires [CEO TO CONFIRM: retention period required in Sri Lanka].
  • Technical data held by Cloudflare: for the short periods set by Cloudflare for security and delivery.

7. Your rights

Depending on where you live, you can ask us to:

  • give you a copy of the personal data we hold about you;
  • correct data that is wrong or incomplete;
  • delete your data;
  • restrict how we use it, or object to how we use it;
  • send your data to you or to another organisation in a common format (portability);
  • withdraw your consent, where we rely on consent.

To use any of these rights, email hello@logispirit.com. We may need to confirm your identity first. We'll reply within one month. Using your rights is free.

8. Complaints

If you're unhappy with how we've handled your data, please tell us first so we can try to put it right. You also have the right to complain to a data protection authority:

  • UK: the Information Commissioner's Office (ICO). ico.org.uk/make-a-complaint
  • EU: the supervisory authority in the country where you live or work. List of EU authorities
  • Sri Lanka: the Data Protection Authority of Sri Lanka. [CEO TO CONFIRM: Authority's official website and contact details]

9. Cookies

This website does not set any cookies and does not use local storage or any other way of tracking you. If that ever changes, for example if we turn on cookie-free visitor statistics, we'll update this notice first.

[CEO TO CONFIRM before launch: in the Cloudflare dashboard, check that no security feature that sets a cookie (for example Bot Fight Mode, which can set a "__cf_bm" cookie) is switched on, or list that cookie here as strictly necessary]

Cal.com is a separate website with its own cookie notice, which applies when you use the booking page.

10. Security, children, links and changes

  • Security. The site is served only over HTTPS with strict security headers. We protect our accounts with strong passwords and two-factor authentication, and we limit access to your data to the people who need it.
  • Children. Our services are for businesses. This site is not aimed at children, and we don't knowingly collect data from anyone under 18.
  • Links. Links to other websites (such as LinkedIn, GitHub or Medium) are covered by those sites' own privacy notices.
  • Changes. If we change this notice, we'll post the new version here and update the date at the top.