Privacy Policy

Last updated: June 2026  |  Version: 1.01

This Privacy Policy applies to the website at astrym.top (the “Website”), operated by Astrym.

1. Data Controller

The data controller responsible for your personal data is:

Astrym
71 Lower Baggot Street, Dublin 2, D02 P593, Ireland
Email: [email protected]
Phone: +353 1 539 4821

2. What Data We Collect

When you book a retirement lifestyle consultation through astrym.top, we collect:

• Name — to address you during the consultation and in follow-up communication.
• Phone number — to confirm your booking and conduct the consultation by phone or video call.
• Technical data — IP address (hashed in consent logs), browser type, and cookie identifiers when you interact with our cookie banner or analytics tools (only with your consent).

We do not collect email addresses through the booking form unless you contact us separately.

3. Purposes and Legal Basis (Art. 6 GDPR)

• Processing your booking — Legal basis: performance of a contract (Art. 6(1)(b) GDPR) and your consent via the Privacy Policy checkbox (Art. 6(1)(a) GDPR).
• Contacting you about your appointment — Legal basis: contract performance (Art. 6(1)(b) GDPR).
• Analytics cookies — Legal basis: your consent (Art. 6(1)(a) GDPR). Only activated if you accept Analytics cookies.
• Marketing/advertising cookies — Legal basis: your consent (Art. 6(1)(a) GDPR). Only activated if you accept Marketing cookies.
• Compliance and record-keeping — Legal basis: legitimate interest in maintaining business records (Art. 6(1)(f) GDPR).

4. Recipients of Your Data

Your data may be shared with:

• Our staff who manage consultation bookings.
• Hosting and IT service providers who process data on our behalf under data processing agreements.
• Google Ireland Limited (Google Analytics, Google Ads conversion tracking) — only if you consent to the relevant cookie categories. Google may transfer data outside the EEA under Standard Contractual Clauses.

We do not sell your personal data to third parties.

5. International Transfers

If you consent to analytics or marketing cookies, data may be transferred to Google LLC in the United States. Google participates in applicable transfer mechanisms including EU Standard Contractual Clauses. You can withdraw cookie consent at any time via Cookie Settings in the footer.

6. Retention Periods

• Booking data (name, phone): retained for up to 3 years after your last consultation or enquiry, unless a longer period is required by law.
• Cookie consent logs: retained for 3 years as proof of consent.
• Analytics data: according to Google Analytics settings (typically up to 26 months) if you have consented.

7. Your Rights (Art. 15–22 GDPR)

Under GDPR, you have the right to:

• Access — request a copy of your personal data.
• Rectification — correct inaccurate data.
• Erasure — request deletion where legally applicable.
• Restriction — limit how we use your data.
• Data portability — receive your data in a structured format.
• Object — object to processing based on legitimate interests.
• Withdraw consent — at any time for consent-based processing, without affecting prior lawful processing.

To exercise your rights, email [email protected]. We respond within 30 days.

8. Right to Complain

If you believe we have not handled your data correctly, you may lodge a complaint with the Data Protection Commission (DPC), Ireland:

www.dataprotection.ie  |  21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland

9. Mandatory Fields

Name and phone number are required to process your booking. If you do not provide them, we cannot schedule your consultation. The Privacy Policy checkbox must be ticked before submitting the form.

10. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal or similarly significant effects.

11. Data Security

We use HTTPS encryption for data transmission. Access to booking records is restricted to authorised personnel. We do not log personal data in publicly accessible files.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The current version is always available on this page with the date and version number above.