How this site handles data. It is a short page, because the site collects very little.
Last updated: 13 September 2026
Who is responsible
This website is operated by OÜ ETHEL CONSULTING, registry code 14459908, VAT number EE102102495, registered at Kaupmehe 19-6, Tallinn, 10104, Estonia. Luxury Hospitality Projects is the trading name of the practice. OÜ ETHEL CONSULTING is the data controller for this website.
For any question about this page or about your data, write to [email protected].
What this site collects
This site has no accounts, no forms, no payments, no newsletter and no comments. There is nothing to submit and nothing to sign up for.
Three things involve personal data: website analytics, which run only if you accept them, email correspondence if you write to the address above, and the technical processing needed to deliver and secure the site. Each is described below.
Website analytics
With your consent, this site uses Google Analytics 4, provided by Google Ireland Limited, to understand how the site is found and which pages are read. It records the pages viewed, the page a visit started on, the source that brought the visit, an approximate country, and whether a visitor reached and spent time on a page describing the services.
For visitors in the European Economic Area, IP addresses are used to derive coarse geographic information such as country and are then discarded. Individual IP addresses are not logged or stored in Google Analytics.
Google Signals is not enabled for this property. Analytics data is retained for 14 months.
Email and hosting
If you write to the address on this site, the message is received in a mailbox operated on our behalf by Google Workspace. Your email address, your name if you give it, and whatever you choose to put in the message are processed so the enquiry can be read, answered, and acted on if it leads to work. Correspondence is not added to a marketing list, because there is no marketing list.
This site is hosted and delivered by Cloudflare. To serve a page and to protect the site from abuse, Cloudflare processes technical data including the IP address the request came from, the browser and device type, and the pages requested. This happens for every visitor, before any question of analytics arises, and it is not something a website can switch off and still function.
Legal basis
Analytics are used on the basis of your consent. You give or withhold it using the banner, and you can change it at any time.
Email correspondence is processed so that an enquiry can be answered, and where it leads to an engagement, so that the engagement can be carried out. The technical processing carried out by Cloudflare is necessary for the site to work and to remain available.
Cookies and similar technologies
A cookie is a small file a website stores in your browser. This site sets no non-essential cookies unless you accept analytics. Cloudflare may set cookies that are strictly necessary for security and delivery. Those are not analytics, and they are not subject to consent.
- Your consent choice. Set by this site, to record whether you accepted or rejected analytics so that you are not asked again. Held in your browser’s local storage rather than as a cookie, until you clear it. Choosing Reject therefore leaves no cookie behind.
- Engagement marker. Set by this site, to record once per browsing session that a services page was read, so that it is not counted twice. Held in your browser’s session storage rather than as a cookie, and cleared when you close the tab.
- Google Analytics cookies. Set only after you accept. One distinguishes one visitor from another and one maintains the session state. The standard GA4 cookies used by this site can persist for up to two years.
Sharing, transfers and retention
Analytics data is processed by Google, and email correspondence is handled through Google Workspace, in both cases as a processor acting on the controller’s instructions. Cloudflare processes technical data in order to host and deliver the site. Nothing is sold, and nothing is shared for any other purpose.
Google and Cloudflare may process personal data outside the European Economic Area, including in the United States. Both providers state that they rely on recognised transfer mechanisms, including the EU-US Data Privacy Framework and, where applicable, Standard Contractual Clauses.
Analytics data is retained for 14 months and then deleted automatically. Email correspondence is retained for as long as needed to deal with the enquiry and any engagement that follows, and for any period required for tax and accounting purposes.
Your rights
Under the General Data Protection Regulation you have the right to access your data, to have it corrected or erased, to restrict or object to its processing, and to data portability. You also have the right to withdraw consent at any time, which you can do using the Cookie settings link in the footer of any page.
You have the right to lodge a complaint with a data protection supervisory authority, including the supervisory authority in the Member State of your habitual residence, place of work, or the place of the alleged infringement.
To exercise any of these rights, write to [email protected].
Changing your choice
Use the Cookie settings link in the footer of any page to change or withdraw your consent at any time. Rejecting after having accepted stops further collection immediately.
Any material change to how this site collects data will be reflected here, and the date at the top of this page will be updated.