This Privacy Policy explains how Roman Kolesnichenko, an individual entrepreneur registered in Ukraine, operating as Vendward (“we”, “us”), handles personal information when you visit vendward.com (the “Site”) or subscribe to our email newsletter, What Changed This Week (the “Digest”).
Who we are
Vendward is operated by Roman Kolesnichenko, an individual entrepreneur (Ukrainian: фізична особа-підприємець, “ФОП”) registered in Ukraine, based in Kharkiv, Ukraine. For any privacy question or request, contact privacy@vendward.com.
What we collect
- Your email address — when you subscribe to the Digest. This is the only personal information we ask you for.
- Aggregate website analytics — we use Cloudflare Web Analytics, a privacy-first, cookieless tool that collects aggregate, non-identifying metrics (such as page views, referrers, pages visited, approximate country, and device type). It does not use cookies, does not fingerprint you, and does not track you across sites.
- Email engagement — our email provider may record whether emails are delivered, opened, or clicked, to help us improve the Digest and maintain deliverability.
We do not knowingly collect sensitive personal data, and we do not ask for your name, company, or payment information on the Site.
Why we use it and our legal basis
| Purpose | Data used | Legal basis (GDPR) |
|---|---|---|
| Send you the Digest you signed up for | Email address | Consent |
| Improve the Digest and keep sending trustworthy | Email delivery & engagement metadata | Legitimate interests |
| Understand and improve how the Site is used | Aggregate, cookieless analytics (Cloudflare) | Legitimate interests |
| Comply with the law | As required | Legal obligation |
We rely on your consent to send you the Digest. You can withdraw it at any time (see “Your choices”).
Who we share it with
We don’t sell or rent your personal information, and — as a matter of principle — we never take money from vendors to influence what we cover. We use a small number of trusted service providers (“processors”) that handle data on our behalf:
- Email/newsletter platform: Buttondown — stores your email address and sends the Digest.
- Website hosting & analytics: Cloudflare — hosts the Site (Cloudflare Pages) and provides privacy-first, cookieless Cloudflare Web Analytics.
Each processes data only to provide its service to us. Some may store data outside Ukraine; where required, appropriate safeguards (such as Standard Contractual Clauses) apply.
How long we keep it
We keep your email address until you unsubscribe or ask us to delete it, after which we remove it from active lists within 30 days (we may retain a minimal suppression record so we don’t accidentally email you again). Aggregate, non-identifying website analytics are retained by Cloudflare for a limited period (around six months).
Your choices and rights
- Unsubscribe any time via the link in the footer of every email.
- Access, correct, or delete your data — email privacy@vendward.com and we’ll action it, typically within 30 days.
- Object to or restrict certain processing, and withdraw consent, at any time.
- If you’re in the EU/UK, you may also lodge a complaint with your local data protection authority.
Cookies
The Site does not use tracking cookies. Our analytics — Cloudflare Web Analytics — is cookieless and does not fingerprint you or track you across sites, so no cookie-consent banner is required. The Site may use only strictly necessary cookies needed to function. If we add cookie-based tools later, we’ll update this section and add a cookie notice where required.
Children
The Site and Digest are intended for professional adults and are not directed to anyone under 16. We don’t knowingly collect data from children.
Changes
We may update this policy; we’ll change the “Last updated” date and, for material changes, note it in the Digest. Continued use after an update means you accept the revised policy.