Based in Cyprus | Remote across Europe & Middle East
Privacy Policy
Last updated: March 2026 · pramlc.com
1. Who We Are
PRAM LC is a marketing advisory brand operating through the website pramlc.com. We are committed to protecting your personal data and processing it in full compliance with the General Data Protection Regulation (GDPR) and applicable European data protection law.
For the purposes of data protection legislation, PRAM LC acts as the data controller for personal data collected via this website.
2. Data We Collect
We collect personal data only where there is a lawful basis to do so. The types of data we may collect include:
– Contact and enquiry data — name, email address, and any information you voluntarily provide when reaching out to us.
– Comment data — when visitors leave comments on the site, we collect the information shown in the comment form, along with the visitor’s IP address and browser user-agent string for spam detection purposes.
– Technical data — IP address, browser type and version, time zone, operating system, and other technical identifiers collected automatically when you visit our site.
– Usage data — pages visited, time spent on pages, referral sources, and similar browsing behaviour collected via analytics tools (see Section 4).
An anonymised string derived from your email address may be shared with the Gravatar service to determine whether you use it. Gravatar’s own privacy policy is available at automattic.com/privacy.
3. Cookies
We use cookies to improve your experience on our website. Cookies are small text files stored on your device. Here is how we use them:
– Comment cookies — if you leave a comment and opt in, your name, email address, and website are saved in cookies for one year, so you do not need to re-enter them on your next visit.
– Session cookies — when you visit our login page, a temporary cookie is set to check whether your browser accepts cookies. It contains no personal data and is deleted when you close your browser.
– Authentication cookies — when you log in, we set cookies to save your session (lasting two days) and screen preferences (lasting one year). Selecting “Remember Me” extends login persistence to two weeks. These cookies are removed upon logout.
– Editor cookies — if you publish or edit content, a cookie is set containing the post ID. It contains no personal data and expires after one day.
– Analytics cookies — Google Analytics places cookies on your device to help us understand how visitors interact with our site (see Section 4).
You may disable or manage cookies through your browser settings at any time, though doing so may affect certain functionality of the site.
4. Analytics
We use Google Analytics 4 (GA4), a web analytics service provided by Google LLC, to understand how visitors engage with our website. GA4 collects information such as:
– Pages visited and time spent on each page
– Referring websites and traffic sources
– General geographic location (country/city level)
– Device type, browser, and operating system
– User interactions such as clicks and scrolls
This data is processed by Google and may be stored on servers outside the European Economic Area. Google LLC is certified under the EU–US Data Privacy Framework, providing an adequate level of data protection.
We have configured GA4 with IP anonymisation enabled, meaning your full IP address is never stored. The data we receive is aggregated and does not directly identify you as an individual.
You may opt out of Google Analytics tracking at any time by installing the Google Analytics Opt-out Browser Add-on (tools.google.com/dlpage/gaoptout), or by adjusting your cookie preferences on this site.
For more information on how Google uses data, visit policies.google.com/privacy.
5. Media Uploads
If you upload images to the website, please ensure they do not contain embedded location data (EXIF GPS). Visitors to the website can download images and extract any location data embedded within them. We recommend removing such metadata before uploading any images.
6. Embedded Content from Other Websites
Articles and pages on this site may include embedded content — for example, videos, images, or social media posts — sourced from third-party websites. Embedded content behaves in exactly the same way as if you had visited those third-party websites directly.
These external websites may collect data about you, use cookies, embed additional tracking technologies, and monitor your interaction with the embedded content, including if you have an account and are logged in to those services.
7. Who We Share Your Data With
We do not sell, rent, or trade your personal data. We may share data with trusted third parties only where necessary and under appropriate data protection agreements:
– Google LLC — for analytics purposes (GA4), as described in Section 4.
– Automattic / Akismet — visitor comments may be checked through an automated spam detection service. Data submitted is shared with Akismet solely for spam filtering.
– Hosting provider — our website host processes data on our behalf as a data processor, under a data processing agreement.
Where a password reset is requested, your IP address will be included in the reset email as part of our security process.
8. How Long We Retain Your Data
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law:
– Comments — comments and associated metadata are retained indefinitely to allow automatic recognition and approval of follow-up comments.
– User profiles — registered users may view, edit, or delete their personal information at any time (with the exception of their username). Website administrators may also access and update this information.
– Analytics data — GA4 data is retained for a maximum of 14 months, in line with our analytics configuration.
9. Your Rights Under GDPR
If you are located in the European Economic Area (EEA) or the United Kingdom, you have the following rights regarding your personal data:
– Right of Access — request a copy of the personal data we hold about you.
– Right to Rectification — request correction of inaccurate or incomplete data.
– Right to Erasure — request deletion of your personal data, subject to legal obligations.
– Right to Portability — request an export of your data in a structured, machine-readable format.
– Right to Object — object to processing of your data based on legitimate interests.
– Right to Restriction — request that we restrict processing of your data in certain circumstances.
To exercise any of these rights, please contact us via the contact form available on our website. We will respond within 30 days as required by GDPR. You also have the right to lodge a complaint with your national data protection authority.
10. Legal Basis for Processing
We process your personal data on the following legal bases under Article 6 of the GDPR:
– Legitimate interests — for analytics, security, spam prevention, and improving our website.
– Consent — for non-essential cookies (such as analytics cookies) where your consent is obtained prior to placement.
– Legal obligation — where we are required to process data to comply with a legal requirement.
You may withdraw consent at any time without affecting the lawfulness of processing that took place prior to withdrawal.
11. International Data Transfers
Some of our third-party service providers — including Google LLC — are based outside the European Economic Area. Where data is transferred internationally, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, or reliance on an adequacy decision.
This Privacy Policy may be updated from time to time to reflect changes in our practices or applicable law. We encourage you to review this page periodically. The date at the top of this page indicates when it was last revised.
Fractional CMO & Strategic Marketing Advisor based in Cyprus. Helping business leaders make better marketing decisions and build growth with confidence.
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