Privacy Policy

Last updated: 10 July 2026

1. Introduction

PRAM LC respects your privacy and is committed to handling personal data responsibly and transparently.

This Privacy Policy explains how personal data is collected, used, stored and shared when you:

• visit pramlc.com;

• submit an enquiry;

• complete a form, questionnaire or Marketing Health Scorecard;

• book a meeting or advisory session;

• become a Client;

• communicate with PRAM LC;

• receive marketing advisory Services.

2. Data Controller

PRAM LC is a marketing advisory brand operated by Louis Castellani.

PRAM LC is not a separate company or legal entity.

The data controller responsible for personal data processed through PRAM LC is:

Louis Castellani, operating under the PRAM LC brand

Business location: Cyprus

Website: https://pramlc.com

Email: hello@pramlc.com

Telephone: +357 99 988 889

The full business correspondence address is available through the relevant contractual documentation or by contacting hello@pramlc.com.

3. Applicable Data-Protection Law

Personal data is processed in accordance with applicable data-protection legislation, including:

• the General Data Protection Regulation, Regulation (EU) 2016/679;

• applicable data-protection law in the Republic of Cyprus;

• applicable electronic-communications and cookie requirements.

4. Personal Data Collected

The personal data collected depends on how you interact with PRAM LC.

Contact and Identity Information

This may include:

• first and last name;

• professional position;

• business or organisation name;

• email address;

• telephone number;

• country or location;

• preferred method of contact.

Enquiry Information

This may include:

• information submitted through the contact form;

• the Service you are interested in;

• information about your business or marketing challenge;

• messages sent through email or professional platforms;

• records of responses and follow-up communication.

Scorecard and Questionnaire Information

Where you complete a Marketing Health Scorecard, assessment or pre-session questionnaire, information may include:

• your responses;

• your calculated score;

• current marketing activities;

• channels and resources used;

• business or marketing priorities;

• challenges or areas of concern;

• information you choose to provide before a session.

A scorecard result is an indicative advisory assessment. It is not used to make an automated decision that produces legal or similarly significant effects.

Booking Information

When you book a meeting or session, information may include:

• name;

• email address;

• company;

• selected date and time;

• time zone;

• answers to booking questions;

• meeting link;

• cancellation or rescheduling information.

Client and Contract Information

Where you engage PRAM LC, information may include:

• business and billing details;

• authorised contact information;

• proposals and agreements;

• project instructions;

• meeting notes;

• communications;

• approvals;

• Deliverables;

• records relating to the Client relationship.

Marketing and Business Information

A Client may provide information such as:

• marketing strategies and plans;

• budgets;

• performance reports;

• website or analytics reports;

• campaign data;

• sales or lead information;

• customer segments;

• brand documents;

• agency reports;

• commercially sensitive information.

Clients should avoid providing personal data that is not necessary for the agreed Service.

Aggregated, anonymised or pseudonymised information should be used where individual-level personal data is not required.

Transaction and Billing Information

This may include:

• invoice details;

• billing details;

• amounts due or paid;

• payment status;

• transaction references;

• refund information.

PRAM LC does not request or store full payment-card information through ordinary Website forms.

Website and Technical Information

Depending on your cookie choices, information may include:

• internet protocol address;

• browser and device type;

• operating system;

• approximate location;

• referring website;

• pages visited;

• date and time of access;

• Website interactions;

• cookie preferences;

• technical and security logs.

Non-essential analytics information is collected only where the required consent has been provided.

Communication Information

This may include:

• emails;

• contact-form messages;

• meeting invitations;

• service-related correspondence;

• written feedback;

• complaint records;

• notes made during professional discussions.

Meetings are not recorded without prior notice and any consent required by law.

5. Information Not Intentionally Requested

PRAM LC does not normally request:

• medical or health information;

• biometric data;

• religious or philosophical beliefs;

• political opinions;

• trade-union membership;

• sexual-orientation information;

• criminal-conviction information;

• identification documents;

• full payment-card details.

Please do not submit sensitive personal data unless it is genuinely necessary and has been specifically requested.

6. How Personal Data Is Collected

Personal data may be collected:

• directly from you;

• through Website forms;

• through questionnaires and scorecards;

• through a booking platform;

• through email and telephone communication;

• during online meetings;

• through proposals, invoices and agreements;

• through cookies and analytics, where permitted;

• from an authorised colleague or representative;

• from publicly available professional or business sources.

7. Purposes and Legal Bases

Responding to Enquiries

Personal data is used to:

• understand your request;

• respond to your enquiry;

• recommend an appropriate Service;

• arrange an introductory meeting.

Legal bases:

• taking steps at your request before entering into a contract;

• legitimate interests in responding to genuine business enquiries.

Providing Advisory Services

Personal data is used to:

• arrange and prepare for meetings;

• provide advisory Services;

• analyse information supplied by the Client;

• prepare Deliverables;

• provide agreed follow-up communication;

• manage the professional relationship.

Legal bases:

• performance of a contract;

• taking steps before entering into a contract.

Invoicing and Business Administration

Personal data is used to:

• prepare proposals and invoices;

• record payments;

• administer refunds;

• maintain business and financial records;

• comply with tax and accounting obligations.

Legal bases:

• performance of a contract;

• compliance with legal obligations;

• legitimate interests in managing the professional activity.

Website Operation and Security

Technical information may be used to:

• operate and protect the Website;

• detect malicious activity;

• prevent spam and abuse;

• investigate errors;

• maintain security and availability.

Legal bases:

• legitimate interests in operating and securing the Website;

• compliance with legal obligations where applicable.

Website Analytics

Where you provide consent, analytics information may be used to:

• measure Website traffic;

• understand how pages are used;

• identify usability or technical issues;

• improve Website content;

• evaluate Website performance.

Legal basis:

• consent.

You may withdraw analytics consent through the Website’s cookie-preference controls.

Service Communication

Contact information is used to send:

• booking confirmations;

• appointment reminders;

• requested information;

• proposals;

• invoices;

• Deliverables;

• contractual follow-ups.

Legal bases:

• performance of a contract;

• taking steps before entering into a contract;

• legitimate interests in managing professional communication.

Marketing Communication

Information about PRAM LC Services or insights may be sent where:

• you have specifically requested such information;

• you have provided consent;

• applicable law otherwise permits the communication.

Marketing communication will provide an unsubscribe option.

Booking messages, invoices, Deliverables and contractual communication are service communications rather than marketing communications.

Legal bases:

• consent;

• legitimate interests where legally permitted.

Legal Compliance and Claims

Personal data may be used to:

• comply with legal obligations;

• respond to lawful authority requests;

• establish or defend legal claims;

• investigate complaints;

• enforce agreements.

Legal bases:

• compliance with legal obligations;

• legitimate interests;

• establishment, exercise or defence of legal claims.

8. Cookies

The Website may use cookies and similar technologies for:

• essential Website operation;

• security;

• storage of cookie preferences;

• form functionality;

• analytics, where consent has been provided.

Non-essential cookies will not be activated before the required consent is obtained.

Further information is available in the Cookie Policy and the Website’s cookie-preference panel.

9. Service Providers

PRAM LC may use selected service providers to support the Website and professional activity.

These may include:

Website Hosting

Hostinger or another appointed hosting provider may process Website files, server logs, security information and form data.

Website Platform and Forms

The Website uses WordPress and may use WPForms or a similar form provider to collect and deliver enquiries.

Form submissions may be stored temporarily or within the Website database and delivered by email.

Appointment Scheduling

Calendly or another booking provider may process appointment details, time-zone information and responses to booking questions.

Where Calendly is accessed through an external link, Calendly’s own privacy terms apply when you visit its platform.

Online Meetings

An online meeting provider may process participant names, email addresses, meeting details and technical connection information.

Meetings are not routinely recorded.

Analytics

Google Analytics 4 may process Website usage and technical information where analytics consent has been provided.

Email and Document Services

Email, cloud-storage or document-delivery providers may process professional communications and Client documents where required to provide the Services.

Professional Advisers

Information may be shared where necessary with:

• accountants;

• legal advisers;

• IT or cybersecurity advisers;

• insurers;

• other professional advisers subject to confidentiality obligations.

Public Authorities

Information may be disclosed where legally required by:

• a court;

• a tax authority;

• a law-enforcement authority;

• a regulatory body;

• another competent public authority.

Service providers are expected to process personal data only for authorised purposes and to apply appropriate safeguards.

10. International Transfers

Some technology providers may process personal data outside Cyprus or the European Economic Area.

Where personal data is transferred to a country that has not been recognised as providing an adequate level of protection, an appropriate legal transfer mechanism will be used where required, such as:

• European Commission Standard Contractual Clauses;

• an applicable adequacy decision;

• another lawful transfer safeguard.

Information about relevant safeguards may be requested through hello@pramlc.com.

11. Retention

Personal data is retained only for as long as reasonably necessary for the relevant purpose.

General retention periods are:

Enquiries

Enquiry information may normally be retained for up to 24 months after the last meaningful communication.

Scorecards and Questionnaires

Scorecard or questionnaire information may normally be retained for up to 24 months after completion or the related advisory session.

Where the participant becomes a Client, relevant information may form part of the Client engagement record.

Booking Records

Appointment and booking records may normally be retained for up to 24 months after the scheduled meeting.

Client Records

Proposals, agreements, meeting notes, communications and Deliverables may normally be retained for up to seven years after the engagement ends where reasonably necessary for professional accountability, contractual records, dispute management and legal claims.

Financial Records

Invoices, payment records and accounting information are retained for the period required by applicable tax and accounting law.

Analytics Information

Analytics information is retained according to the period configured in the analytics service.

Consent Records

Cookie and marketing-consent records may be retained for as long as reasonably necessary to demonstrate the choices made.

Information may be retained for longer where:

• a legal claim or dispute exists;

• a legal preservation obligation applies;

• a competent authority lawfully requires it;

• another statutory retention period applies.

12. Security

Reasonable technical and organisational safeguards are used to protect personal data.

These may include:

• restricted access;

• password and account controls;

• secure hosting;

• encrypted data transmission where supported;

• software and plugin updates;

• backups;

• access limitation;

• confidentiality obligations;

• Website security and monitoring measures.

No online system or electronic-storage method can provide absolute security.

13. Your Rights

Subject to applicable conditions and exemptions, you may have the right to:

• request access to your personal data;

• request correction of inaccurate information;

• request completion of incomplete information;

• request deletion of personal data;

• request restriction of processing;

• object to processing based on legitimate interests;

• object to direct marketing at any time;

• receive eligible information in a structured, commonly used and machine-readable format;

• request transfer of eligible information to another controller;

• withdraw consent at any time;

• complain to a competent supervisory authority.

Withdrawal of consent does not affect processing that was lawful before consent was withdrawn.

14. Exercising Your Rights

Requests should be sent to:

hello@pramlc.com

Your request should provide sufficient information to identify:

• who you are;

• the information or processing concerned;

• the right you wish to exercise.

Appropriate proof of identity may be requested where reasonably necessary to prevent unauthorised disclosure.

Requests will normally be answered within one month, subject to any permitted extension for complex or multiple requests.

A fee is not normally charged. A reasonable fee may be charged, or a request may be refused, where a request is manifestly unfounded or excessive and applicable law permits this.

15. Complaints

You may first contact PRAM LC through hello@pramlc.com so that the concern can be reviewed.

You also have the right to submit a complaint to the Office of the Commissioner for Personal Data Protection in Cyprus or another competent European data-protection authority.

16. Children

The Website and Services are intended for business and professional users.

PRAM LC does not knowingly collect personal data from individuals under the age of 18 through the Website.

17. External Websites

The Website may link to external platforms such as Calendly, LinkedIn or other third-party services.

PRAM LC does not control the privacy practices of external websites. Their own privacy policies apply after you visit them.

18. Automated Decision-Making

PRAM LC does not use personal data to make solely automated decisions that produce legal or similarly significant effects.

Automated score calculations within a Marketing Health Scorecard are indicative advisory tools and do not determine access to employment, credit, insurance or another legally significant service.

19. Changes to This Policy

This Privacy Policy may be updated to reflect changes in:

• Website functionality;

• Services;

• service providers;

• processing practices;

• applicable law.

The current version will be published on pramlc.com with an updated revision date.

20. Contact

Louis Castellani

Operating under the PRAM LC brand

Website: https://pramlc.com

Email: hello@pramlc.com

Telephone: +357 99 988 889

Business location: Cyprus