Privacy policy

Last updated: 18.02.2026

Data Controller

Sugori Consulting Services, operated by Sugori Goran Shutinovski, acts as the data controller with respect to personal data processed via sugori.com. Please read this Privacy Policy carefully before using the Sugori Consulting Services website.

Personal data is processed in accordance with applicable data protection laws, including Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR).

General Principles

Sugori Consulting Services respects the privacy of website visitors and processes personal data in accordance with applicable data protection laws, including the GDPR. Personal data is processed lawfully, fairly, and transparently, and only to the extent necessary for defined purposes.

Personal Data Provided Voluntarily

Personal data may be processed when voluntarily provided by users, including:

✔ Name and surname
✔ Email address
✔ Message content

Such data is processed exclusively for communication purposes, including responding to inquiries or providing requested information. Legal basis: Article 6(1)(b) GDPR (pre-contractual steps requested by the user) or, where applicable, Article 6(1)(f) GDPR (legitimate interest in responding to communications). Failure to provide required data may prevent response to the inquiry.

Why do we process your data?

Sugori Consulting Services processes personal data strictly within applicable legal bases and only where necessary for legitimate operational, contractual, legal, or consent-based purposes.

✔ User consent (Article 6(1)(a) GDPR)
✔ Contractual necessity (Article 6(1)(b) GDPR)
✔ Legal obligations (Article 6(1)(c) GDPR)
✔ Legitimate interests (Article 6(1)(f) GDPR), where appropriate.

Personal data is processed exclusively for legitimate purposes such as:

✔ Communication with users
✔ Provision and administration of services (where applicable)
✔ Website security and integrity
✔ Compliance with legal obligations

Sugori Consulting Services does not require users to actively provide personal data to browse the website. Where specific website functionalities require additional data (such as account creation, booking systems, or payment processing), personal data may also include: Account credentials (e.g. email, login identifiers), Billing or invoicing details, Transaction-related information, Service booking details. Such data is processed exclusively where users actively use those functionalities.

Users who are uncertain about what information is mandatory are welcome to contact us via info@sugori.com.

Website Analytics

Sugori Consulting Services uses privacy-focused analytics technologies to understand aggregated website usage, improve website performance, and enhance user experience.

Analytics processing:

✔ Occurs only after valid user consent
✔ Is not activated prior to consent
✔ Is performed using appropriate data protection safeguards

Sugori Consulting Services currently uses analytics services provided by Amplitude.

These technologies may process limited technical and interaction data, such as:

✔ Device and browser information
✔ Pages visited and interactions
✔ Approximate location derived from IP address

Analytics data is processed using technical identifiers and aggregated usage signals. Sugori Consulting Services does not use such data for the purpose of identifying individual users. Legal basis: Article 6(1)(a) GDPR — user consent. Users may refuse or withdraw consent at any time via the cookie consent interface or browser settings.

Refusal of analytics technologies does not affect website functionality.

Your rights:

If you are a European resident, you have the following rights related to your personal data:

✔ The right to be informed.

✔ The right of access.

✔ The right to rectification.

✔ The right to erasure.

✔ The right to restrict processing.

✔ The right to data portability.

✔ The right of withdrawal of consent (where consent is the legal basis)

✔ The right to object.

✔ Rights in relation to automated decision-making and profiling.

These rights may be exercised subject to conditions and limitations provided by applicable law. If you would like to exercise this right, please contact us through the contact information below.

Links to other websites:

Our website may contain links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for such other websites or third parties' privacy practices. We encourage you to be aware when you leave our website and read the privacy statements of each website that may collect personal information.

Information security:

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We keep reasonable administrative, technical, and physical safeguards to protect against unauthorized access, use, modification, and personal data disclosure in its control and custody. While Sugori Consulting Services applies reasonable safeguards, no method of electronic transmission or storage is entirely secure.

Newsletter and Marketing Communications:

We may send you newsletters and marketing emails if you have expressly consented to receive them. Consent is collected through an unchecked opt-in checkbox on the signup form. We implement a double opt-in mechanism: after signing up you will receive a confirmation email. Only after confirming your subscription will you receive newsletter communications. You may withdraw your consent at any time by clicking the unsubscribe link in any newsletter email or by contacting us at info@sugori.com. Withdrawal of consent does not affect prior lawful processing. Legal basis: Article 6(1)(a) GDPR – consent.

Account Creation and Service Booking

Where Sugori provides account-based services, personal data is processed for:

✔ Account registration, administration and management.
✔ Booking and scheduling of services.
✔ Customer support and communications.

Legal basis: Article 6(1)(b) GDPR – performance of a contract or pre-contractual steps. Failure to provide required data may prevent account creation or service delivery.

Payments and Transaction Processing

Where payments are made via the website, payment processing is performed by specialised third-party payment providers operating under their own legal and regulatory frameworks.

Sugori Consulting Services does not store or retain full payment card details.

Payment providers may process data necessary to complete transactions, including payment identifiers and transaction metadata, in accordance with their own privacy policies and legal obligations.

Legal bases:

✔ Article 6(1)(b) GDPR — performance of a contract
✔ Article 6(1)(c) GDPR — compliance with legal obligations

Hosting and Technical Infrastructure

The website is hosted using services provided by Hostinger International Ltd. Hostinger processes technical data necessary for website delivery, security, and performance strictly as a data processor acting on documented instructions. Legal basis: Article 6(1)(f) GDPR – legitimate interest.

International Data Transfers

Where personal data is transferred outside the European Economic Area (EEA), Sugori Consulting Services applies appropriate safeguards in accordance with applicable data protection laws.

Data Retention

Personal data is retained only for as long as necessary to fulfil:

✔ Communication purposes
✔ Legal obligations
✔ Establishment, exercise, or defence of legal claims

Newsletter data is retained until consent withdrawal. Technical and security data is retained strictly within operational necessity limits.

Data Security

Sugori Consulting Services applies appropriate technical and organisational safeguards designed to protect personal data against unauthorised access, disclosure, alteration, or destruction.

Legal disclosure:

Personal data may be disclosed where required by applicable laws or regulatory obligations.

Contact information:

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may send an email to info@sugori.com.