Legal

Privacy Policy

Last updated: 10 August 2026

ENGVA is an accountability coaching service operated by Zoltan Szabó ("ENGVA," "we," "us," "our"), based in Serbia, working with entrepreneurs and small business owners in the UK, Ireland, the United States, and Canada. This policy explains what personal data we collect, why, and what rights you have over it, wherever you're located.

On this page

Who we are
What we collect
How and why we use your data
A note on ADHD and sensitive information
How we store and protect your data
International data transfers
Who we share your data with
Cookies
How long we keep your data
Your rights
Children's privacy
Changes to this policy
Contact us

1. Who We Are

Contact: zoltan@engvaservices.com
Data controller: Zoltan Szabó, trading as ENGVA, 12, Subotica, Serbia

If you have any questions about this policy or how your data is handled, contact us at the address above.

2. What We Collect

When you book a free Execution Audit or enquire about our services:

Name, email address, and any details you share via the booking form or our online scheduling page (e.g. time zone, brief context about your business)

When you become a client:

Contact and billing details needed to deliver the service and process payment
Information you share during sessions relevant to your business goals and priorities (we don't keep clinical or diagnostic records — see Section 4)
Signed service agreements, stored via our e-signature tool

When you browse our website:

Standard technical data (IP address, browser type, pages visited) via website analytics
Cookie data — see Section 8

3. How and Why We Use Your Data

We collect and use your data for a few clear reasons:

With your consent — when you book a call or submit a contact form
To deliver our service — when you become a paying client, we need your details to provide the service, invoice you, and manage the engagement
For legitimate business purposes — such as basic website analytics and improving our service, always balanced against your privacy interests

4. A Note on ADHD and Sensitive Information

ENGVA is an accountability service, not a clinical or medical provider. We don't ask for a diagnosis, request medical records, or maintain health files on clients. If ADHD or related topics come up naturally during sessions, that's treated as ordinary business context — not a medical record — and isn't stored, categorised, or processed as health data.

5. How We Store and Protect Your Data

We use the following tools to run ENGVA, each of which processes data under their own privacy and security terms:

Purpose	Tool
Email	Google Workspace (custom domain)
Booking	Google Calendar (Appointment Schedule)
Payments	Payoneer, PayPal, SWIFT bank transfer
Contracts / e-signature	eSignature by Google (Google Docs)
Website / hosting	WordPress

We don't store full payment card or bank details ourselves — payment processing and transfers are handled directly by Payoneer, PayPal, and our bank, under their own security standards.

6. International Data Transfers

ENGVA is based in Serbia. Wherever you're contacting us from — the UK, Ireland, the United States, or Canada — your personal data will be processed in Serbia and, in some cases, by the third-party tools listed in Section 5.

If you're in the UK or Ireland: UK GDPR and EU GDPR apply to how we handle your data regardless of where we're based — a built-in feature of both laws, designed to protect you even when the business you're dealing with is outside the UK/EU. You have the same underlying rights described in this policy either way.

If you're in Canada: under Canada's federal privacy law (PIPEDA), we're required to be transparent that your information may be processed outside Canada, including in Serbia and via international service providers, and that once information leaves Canada it becomes subject to the laws of the country where it's held. We apply the same privacy practices described in this policy regardless of where your data is processed.

If you're in the United States: there isn't a single federal transfer-restriction law comparable to GDPR or PIPEDA, but the same privacy practices in this policy apply to you as to every other client.

Where your data passes through third-party tools, those providers are responsible for using an appropriate legal safeguard for any international transfer under their own data processing terms. If you'd like a pointer to a specific provider's documentation, contact us at zoltan@engvaservices.com.

We don't sell your data. We share it only with:

The service providers listed in Section 5, to the extent needed for them to do their job
Legal or regulatory authorities, if required by law

8. Cookies

Our website uses essential cookies needed for basic site functionality, and may use analytics cookies to help us understand how visitors use the site. You can manage or disable cookies at any time through your browser settings.

9. How Long We Keep Your Data

Enquiry/audit call data: retained for 12 months if you don't become a client, then deleted
Client data and signed contracts: retained for 7 years after the end of the engagement — a conservative window that covers standard financial record-keeping practice across the UK, Ireland, the US, and Canada

10. Your Rights

Your rights depend on where you're located:

UK or Ireland: you have the right to access, correct, delete, restrict, or object to our processing of your data, request a copy of it in a portable format, and withdraw consent at any time. You can complain to the ICO (UK) or the DPC (Ireland).

Canada: under PIPEDA, you have the right to access the personal information we hold about you, request corrections, and withdraw consent, subject to legal or contractual limits. You can complain to the Office of the Privacy Commissioner of Canada (OPC).

United States: your rights depend on your state of residence. Where applicable state law gives you rights to access, delete, or opt out of the sale or sharing of your personal information — for example under California's CCPA or similar laws in other states — we'll honor those requests. ENGVA does not sell personal information.

To exercise any of these rights, wherever you're located, email zoltan@engvaservices.com.

11. Children's Privacy

ENGVA's services are intended for business owners aged 18 and over. We don't knowingly collect data from anyone under 18.

12. Changes to This Policy

We may update this policy from time to time. The "last updated" date at the top will reflect the most recent revision.

Questions about this policy or your data? Email zoltan@engvaservices.com