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Privacy policy

Last updated: 22.10.2026

This policy explains what personal data we collect through neagoedragos.com, why we collect it, how long we keep it and what your rights are. It applies together with the Terms and conditions and the Cookie policy. If this English version and the Romanian version differ, the Romanian version prevails.

1. Who the controller is

The data controller is HILGARD HOLDING LLC, a company organised under the laws of the State of Wyoming, USA, EIN 37-2248584, registered at 30 N Gould St Ste R, Sheridan, WY 82801. For any question about your data, write to contact@neagoedragos.com.

For people in the European Union / European Economic Area, Regulation (EU) 2016/679 (GDPR) applies regardless of where the Company is based.

2. What data we collect and why

  • The clarity call booking form (hosted by Fillout): your name, email address, phone number and whatever you choose to write about your situation. We use it to contact you, schedule the call and make you a proposal. Legal basis: steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR).
  • The free guide and emails (form hosted by Fillout): your first name, email address, language and, if you come from the check-in, the relationship it pointed to. We use them to send you the guide and, only if you tick a separate box, occasional emails with practices and program news. Legal basis: your consent (Art. 6(1)(a) GDPR). You can unsubscribe at any time from any email or by writing to us.
  • Email, phone or WhatsApp correspondence: your contact details and the content of your messages, so we can reply. Legal basis: our legitimate interest in answering requests (Art. 6(1)(f) GDPR) or pre-contractual steps.
  • Program clients: identification and billing details, payment history and session notes. Legal basis: performance of the contract and tax obligations (Art. 6(1)(b) and (c) GDPR).
  • Health information, only if you choose to share it (for example, to assess whether a particular activity is suitable for you). We process it only with your explicit consent (Art. 9(2)(a) GDPR).
  • The 7-question check-in: your answers are calculated in your own browser and are neither sent to nor stored by us.
  • Online payments (once available): processed by Stripe. We never receive or store full card details.

We do not use your data for marketing without separate consent, and we make no automated decisions that affect you.

3. Who we share data with

We use providers that process data on our behalf under data processing agreements:

  • website hosting (static hosting provider);
  • Fillout (booking form and free guide form);
  • the email provider for the neagoedragos.com domain;
  • Zoom (online sessions);
  • WhatsApp / Meta (if you choose to message us or join the free group);
  • Stripe (payment processing, once available);
  • accounting and invoicing services.

Some of these providers are outside the EEA (mainly in the USA). Transfers rely on the EU–US Data Privacy Framework where the provider is certified, or on the Standard Contractual Clauses adopted by the European Commission.

4. How long we keep data

  • booking form data, if you don't become a client: up to 12 months from our last contact;
  • free guide and email data: until you withdraw consent or unsubscribe;
  • client data and session notes: for the duration of our work together and up to 3 years after it ends;
  • health information: only as long as necessary, and no longer than 6 years from the last interaction;
  • tax documents: 10 years, as required by accounting law.

5. Your rights

You have the right of access, rectification, erasure, restriction of processing, objection, data portability, and the right to withdraw consent at any time without affecting earlier lawful processing. To exercise any of them, write to contact@neagoedragos.com. We reply within one month.

You may also lodge a complaint with the Romanian data protection authority (ANSPDCP), www.dataprotection.ro, or with the authority in your country of residence.

6. Security

The site is served over HTTPS only. Access to client data is limited to Dragoș Neagoe and the providers above, as far as necessary.

7. Minors

Our services are for people aged 18 and over. We do not knowingly collect data from minors.

8. Changes

We may update this policy. The current version is always the one published on this page, with the date shown above.