How We Handle Your Data
1. Introduction & Controller Identity
This Privacy Policy explains how Ciprian Titire, trading as titi.re ("we", "us", "our") collects, uses, and protects your personal data when you use our website at titi.re and purchase our services.
We are the data controller responsible for your personal data. Contact: cip@titi.re
We comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR).
2. Data We Collect
Information you provide directly
- Account data: name, email address, password (when you create an account)
- Order data: name, email, billing address, project details submitted via forms
- Payment data: processed by Stripe — we do not store card numbers
- Communications: emails, messages, and form submissions you send us
- FAQ questions: the question you type into the Services FAQ, and the answer you were shown. No name or email is attached, and we do not store your IP address: to limit abuse we keep only a one-way hash of it. The last few questions and answers are also kept in your own browser, in this tab only, so the thread is still there if you reload the page; closing the tab clears them. The last three are sent along with your next question so the answer can follow on from them
- Speech, if you use the microphone: pressing the microphone in the Services FAQ hands the audio to your own browser's speech recognition, not to us. Depending on your browser, that service may process the audio on your device or on its maker's servers. The words arrive in the box for you to read and edit, and nothing is sent to us until you press Ask. We do not record or keep audio
Information collected automatically
- Server logs: IP address, browser type, pages visited, time of access
- Visit statistics: when you open the home page, we count the page, the referring site, your browser and device type, and your country. The tool sets no cookies, and we configure it not to keep your name, email address or IP address
- Payment fraud detection: device and location signals gathered by Stripe, our payment processor, when you pay
- Error reports: when something on this site or its server functions breaks, a report goes to an error-monitoring service in the EU: the error message, where in the code it happened, the page path (without the part of the address after "?"), and your browser and operating system. We configure error reports to leave out names, email addresses, cookies and form content. Reports are sent only when something breaks
We do not use analytics cookies or advertising trackers. Visit statistics come from a cookie-free tool that we host ourselves.
3. Lawful Bases (GDPR Art. 6)
| Processing Activity | Lawful Basis |
|---|---|
| Order fulfillment (name, email, project details) | Contract (b) |
| Payment processing (via Stripe) | Contract (b) + Legal Obligation (c) — tax |
| Account creation / login | Contract (b) |
| Maintenance service delivery | Contract (b) |
| Email confirmations / receipts | Contract (b) + Legitimate Interest (f) |
| Marketing emails (opt-in only) | Consent (a) |
| Fraud prevention (payment processor) | Legitimate Interest (f) |
| Error reporting | Legitimate Interest (f): keeping the site working |
| Visit statistics | Legitimate Interest (f): understanding which pages are useful |
| Legal compliance (accounting, disputes) | Legal Obligation (c) |
4. Purposes of Processing
We use your data to:
- Process and fulfill your orders
- Deliver services and communicate about your projects
- Process payments securely through Stripe
- Send transactional emails (order confirmations, receipts, project updates)
- Comply with legal and tax obligations
- Prevent fraud and protect our services
5. Recipients
We share data with the following categories of recipient, under written agreements with appropriate safeguards for any transfer outside the UK. We may also disclose data to our accountant and professional advisers, and where the law requires it, for example to HMRC or a court.
| Recipient | Purpose |
|---|---|
| Stripe, our payment processor | Payments, checkout and fraud prevention |
| Hosting and database providers | Running the site, storing orders and accounts, and signing you in |
| Email delivery provider | Sending order confirmations, receipts and project updates, and marketing email if you opted in |
| Project, messaging and scheduling tools | Managing projects, internal notifications and booking discovery calls |
| Third-party AI model providers | Answering questions typed into the Services FAQ: question text only, no account, order or payment data |
| Error-monitoring service (EU region) | Error reports from the site and its server functions: error details only |
We do not sell your data.
A question typed into the Services FAQ is sent to one or more third-party AI model providers, together with the public facts from this site that the answer must be drawn from. Nothing else about you is sent with it. Please do not type personal details into that box; the contact form is the place for those.
6. International Transfers
Some of these recipients are based outside the UK, mainly in the United States. Where data is transferred internationally, we rely on the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, or on an adequacy arrangement, as appropriate safeguards. Contact us at cip@titi.re for details of the safeguards.
7. Retention Periods
| Data Category | Retention | Basis |
|---|---|---|
| Order / contract data | 6 years from end of tax year | HMRC / Companies Act |
| Payment records (Stripe) | 6 years + current | Tax and accounting law |
| Account / profile data | Until deletion request + 30 days | GDPR Art. 17 |
| Email correspondence | 3 years from last contact | Legitimate interest |
| Marketing consent logs | 6 years | PECR / GDPR |
| Server access logs | 12 months | Security |
| Visit statistics | For as long as we use the tool; deleted if we stop | Legitimate interest: understanding which pages are useful |
| Error reports | Up to 90 days | Legitimate interest: keeping the site working |
| FAQ questions & answers | 180 days | Legitimate interest: answering better |
| Project records | Until project closed + 2 years | Contract fulfillment |
8. Your Rights (GDPR Art. 15–22)
You have the right to:
- Access your personal data (Art. 15)
- Rectify inaccurate data (Art. 16)
- Erase your data ("right to be forgotten") (Art. 17)
- Restrict processing (Art. 18)
- Data portability — receive your data in a structured format (Art. 20)
- Object to processing based on legitimate interest (Art. 21)
To exercise any right, email cip@titi.re. We respond within 1 month.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO): ico.org.uk/make-a-complaint
9. Cookies & Tracking
We set only the cookies needed for the site to work, for payment processing and sign-in. If we add others, we ask first. For full details, see our Cookie Policy.
We do not use analytics, advertising, or social media cookies.
10. Security Measures
We use appropriate technical and organisational measures to protect your data. Data is sent over encrypted HTTPS connections, and card details are handled by our payment processor, not by us.
11. Changes to This Policy
We may update this policy from time to time. Changes will be posted on this page with an updated "Last updated" date. Where the law requires it, we will also tell you of significant changes.
12. Contact & Supervisory Authority
For any privacy-related queries, contact: cip@titi.re
Supervisory authority: Information Commissioner's Office (ICO)
Website: ico.org.uk
Complaints: ico.org.uk/make-a-complaint