Privacy Policy

Who is responsible

Fluent in Tech is my coaching practice. I’m Mark Parfenov, and I run it as a sole proprietorship in the United States. I’m the data controller for the personal data described here. For any privacy question or request, send me a message through the contact form.

The short version

I count visits with privacy-friendly analytics that don’t use cookies. Google Analytics and Google Ads cookies are only used if you accept them in the cookie banner.
Fonts and images come from this site, not from third parties.
The video only loads from Vimeo (with tracking turned off) when you press play.
I only collect personal data when you contact me, book a call, join my email list, take part in coaching or pay, and I never sell it.

What I collect and why

Visiting the website

The site is hosted by Vercel. Like any web server, it processes technical data such as your IP address, browser type and the pages requested, to deliver the site and protect it against abuse. This is necessary for the site to work and is based on legitimate interests (GDPR Article 6(1)(f)).

Visitor statistics

I use Vercel Web Analytics to count visits: which pages are viewed, the website you came from, and your country, browser and device type. It sets no cookies and doesn’t store IP addresses or recognize you across websites or across days. I only look at the totals, to understand which pages are useful. Legal basis: legitimate interests in running and improving the site (Article 6(1)(f)). Vercel Speed Insights works the same way to measure how fast pages load for visitors (load times, the page, and the device and browser type), also without cookies.

Google Analytics and Google Ads (only if you accept)

The cookie banner lets you accept or reject two kinds of cookies separately, or all at once. Both are services of Google Ireland Limited and Google LLC.

Analytics. Google Analytics 4 sets cookies (_ga and _ga_0ZXM181Z19, which last up to two years) to count visits and see which pages and buttons are used: for example, whether visitors open the booking calendar or download a program guide. Google Analytics 4 does not log or store IP addresses. Analytics data is kept for no longer than 14 months.
Advertising. Google Ads cookies (such as _gcl_au on this site and Google’s own advertising cookies on google.com and doubleclick.net, which last up to 13 months) let me measure whether my ads on Google lead to visits and bookings, and show my ads to people who have visited this site. Google may combine this with information from your Google account, according to your Google ad settings.

Legal basis: your consent (Article 6(1)(a)). If you choose “Reject all”, or don’t choose, Google Analytics and Google Ads are not loaded. You can change your choice at any time with “Cookie settings” at the bottom of every page. If you withdraw consent, the Google cookies already set by this site are deleted. For how Google uses this data, see how Google uses information from sites that use its services; you can control personalised ads at adssettings.google.com.

Settings saved in your browser

Your cookie choice is saved in your browser’s local storage so the banner doesn’t appear on every page. If you switch to US dollar, British pound or Polish złoty prices, that choice is kept in your browser only until you close the tab, and the latest exchange rate is saved in local storage so the page doesn’t have to fetch it every time. The exchange rate comes from the European Central Bank through this site’s own server; nothing about you is sent with it. After you download a program guide, your browser also remembers for that visit that you’ve seen the consultation offer, so it isn’t shown again. None of this is a cookie, none of it is sent to me, and you can clear it at any time in your browser settings.

Contacting me

The message form on the booking page asks for your name, email address, current role and what you’re preparing for and, if you want to answer them, the communication situation you find difficult, your timeline and the name of the person who referred you, so they can get their free session. I store them, together with the page you were on and the service you were looking at, in the Neon Postgres database described below. If you arrived from a Google ad and accepted advertising cookies, the ad’s click ID is stored with your message too, so I can tell Google Ads which ads led to a client. They’re emailed to me, and I use them only to reply to you and prepare for and arrange a free consultation. They are not added to my email list. When you email me directly, I receive your name, email address and message in my Gmail account and use them to reply and to prepare for a free consultation. Legal basis: steps taken at your request before entering into a contract (Article 6(1)(b)) and legitimate interests in answering enquiries (Article 6(1)(f)).

Joining the newsletter and email list

If you sign up for my newsletter or for new guides (in a sign-up form, or by ticking the box when you download a guide or an assessment report), your email address, and your name if you gave it, are stored together with the date, the page you signed up on and the wording you agreed to, so there’s a record of your consent. I use your address only to send you the newsletter, new guides and occasional coaching tips, and I never share or sell it. The list is stored in a Neon Postgres database hosted in the United States (Washington, D.C. region). Legal basis: your consent (Article 6(1)(a)), which you can withdraw at any time.

To unsubscribe, use the unsubscribe link in any email or send me a message through the contact form. I then mark your address as unsubscribed so you won’t get any more emails. If you’d like it deleted completely, just tell me.

Joining a group waitlist

The waitlist form asks for your email address, the group you’re interested in and, if you want, your first name and a short note. I store them, with the date, in the Neon Postgres database described below, and use them only to send you a confirmation and to tell you when that group has a start date. You aren’t added to my newsletter. Legal basis: steps taken at your request (Article 6(1)(b)). Reply to any of my emails and I’ll take you off the waitlist.

Messaging me on Telegram

If you message me on Telegram, I see your Telegram name and whatever you send me, and I use them only to reply to you. Telegram processes your messages under its own privacy policy.

Messaging me on WhatsApp

If you message me on WhatsApp, I see your WhatsApp name, your phone number and whatever you send me, and I use them only to reply to you. WhatsApp (Meta) processes your messages under its own privacy policy.

Taking the Mini English test

The Mini English test is scored in your browser, which shows your estimated level. When you finish, your answers are also sent to my server to be scored, and I receive an email with your score by area; it contains nothing that identifies you, and nothing is stored at that point. To see the full result, you enter your name and email, and your answers are sent to my server. I store your email, your name, your answers, your score and level, and the date, in the Neon Postgres database described below. I use them to email you the result and, if you want, to reply to you, and I receive a copy of the result by email. You only join my newsletter if you tick that box. Legal basis: your request (Article 6(1)(b)) and, for the newsletter, your consent (Article 6(1)(a)). Ask me at any time and I’ll delete your result.

Downloading a free guide as a PDF

Most of every guide can be read on this website without sharing anything. The last part of each guide, usually the phrases or the checklist, and the PDF need your name and email address: once you enter them for any guide, the last part of every guide stays open in your browser (local storage). I store them, with the guide and the page you were on, in the Neon Postgres database described below, email you a copy of the guide, and receive an email about the download. I use your details to send you the guide and may follow up once to offer a free consultation. You only join my email list if you tick that box. Legal basis: your request (Article 6(1)(b)) and my legitimate interest in following up once on it (Article 6(1)(f)); for the email list, your consent (Article 6(1)(a)). I delete downloads that don’t lead to coaching within 12 months.

Taking a free assessment

The English level, soft-skills and career assessments show your results once you enter your name and email address. When you reach the end, your answers are sent to my server to check they’re complete and score them. They aren’t stored at that point, but I receive an email saying someone finished, with the scores and the options you chose. It leaves out anything you typed yourself, such as the writing task, your role or your goals, and anything that identifies you. While you work, your answers are also saved in your own browser (local storage) so a refresh doesn’t lose them; they expire after 7 days and can be removed earlier with “Clear answers”; your name and email are not stored in this draft. When you enter your name and email to see your results, your browser downloads the PDF report and I store them with your answers and result in the Neon Postgres database, email you the report and receive a copy of it by email, so I can prepare if you book a consultation. Please don’t include your employer’s confidential information in your answers. You only join my email list if you tick that box. Legal basis: your request (Article 6(1)(b)) and my legitimate interest in following up once on it (Article 6(1)(f)); for the email list, your consent (Article 6(1)(a)). I delete results that don’t lead to coaching within 12 months, or sooner if you ask.

Leaving a review

The review form on the reviews page asks for your name, email, review and, if you want, your role and a rating. I store them in the same Neon Postgres database and receive them by email. Your email is only used if I want to reply to you, and it’s never shown. I only show your review on this website if you tick the box that allows it, and then only with your first name and role. You can ask me to change or remove it at any time. Legal basis: your consent (Article 6(1)(a)).

Requesting a consultation after downloading a guide

Program guides are free to download. Before the download starts, you can leave your name and email address to request a free consultation, or choose “No thanks” and download without sharing anything. If you share them, I store your name, email, the guide you downloaded and the page you were on in the same Neon Postgres database, and use them only to contact you about that consultation. They’re not added to my email list. Legal basis: steps taken at your request before entering into a contract (Article 6(1)(b)). I delete requests that don’t lead to coaching within 12 months.

Booking a call

The booking calendar is provided by Cal.com and shown on my booking page. When you book, Cal.com collects the details you enter (your name, email address, current role, what you’re preparing for and any notes) and shares them with me so the call can take place. If you arrived from a Google ad and accepted advertising cookies, the ad’s click ID is saved with the booking, so I can tell Google Ads which ads led to a client. Sessions run on Google Meet. Legal basis: steps taken at your request before entering into a contract, and performance of the coaching contract (Article 6(1)(b)).

Coaching sessions

To coach you well, I keep notes on your goals, your progress and the material you choose to share, such as a CV, a job description or a presentation. Before we start, I ask you to complete the personal-plan form on this website and accept my session and cancellation policy. The onboarding section below explains how I process those answers. Please don’t share your employer’s confidential information. I use Bluedot to make a transcript of each session, so I can send you the transcript and a summary of the main points. I don’t keep audio or video recordings unless you ask me to. If you’d rather not have a transcript, tell me and I won’t make one. The AI practice partner I give clients runs in your own ChatGPT account, under OpenAI’s terms and privacy policy, and I can’t see those conversations. Legal basis: performance of the coaching contract (Article 6(1)(b)).

Payments and invoices

Payments are handled by the provider you choose: Stripe, PayPal, Wise, Revolut, Zelle, a bank, or a crypto wallet or exchange. I receive confirmation of payment and the details I need for an invoice (such as your name, company and billing address). Card numbers are never shared with me. I keep invoices and payment records to meet tax and accounting obligations (Article 6(1)(c)).

Reviews

Reviews shown on this site come from public reviews that clients left on Preply, italki and Superprof, and are shown with a first name only. If you’d like your review removed from this site, email me and I’ll take it down.

Who else processes your data

I use these services to run my practice. Each one processes data under its own privacy terms:

Vercel: website hosting, visitor statistics and page speed measurement
Cal.com: the booking calendar for free consultations
Neon: database for the email list, contact requests, consultation requests, guide downloads, assessment results, group waitlists, reviews and Mini English test results
Cloudflare: domain name service (DNS)
Google: email, calendar booking, video calls, Google Analytics and Google Ads (only with your consent)
Vimeo: the introduction video, only when you press play
Payment providers: the one you choose: Stripe, PayPal, Wise, Revolut, Zelle, your bank or a crypto service
Bluedot: session transcripts and summaries
Telegram: only if you choose to message me there
WhatsApp: only if you choose to message me there

Links to LinkedIn, Instagram, Facebook, Telegram, WhatsApp, Preply, italki and Superprof take you to those sites, which have their own privacy policies.

International transfers

Some of these providers are based in, or process data in, the United States and other countries outside the UK and the European Economic Area. Where that happens, transfers rely on the safeguards the providers offer, such as the EU–US Data Privacy Framework (and its UK extension) or Standard Contractual Clauses.

How long I keep data

Enquiries that don’t lead to coaching: deleted within 12 months.
Guide downloads and assessment results that don’t lead to coaching: deleted within 12 months.
Reviews: kept until you ask me to change or remove them.
Email list: kept until you unsubscribe. If you ask, I delete your address completely.
Group waitlists: kept until the group starts or you ask to leave, and deleted within 12 months at the latest.
Coaching notes, materials, transcripts and summaries: kept while you’re a client and deleted within 12 months after your last session, or sooner if you ask.
Invoices and payment records: kept for as long as tax and accounting law requires.

Your rights

Under the GDPR and UK GDPR you can ask to access your personal data, correct it, delete it, restrict or object to how it is used, or receive a copy in a portable format. Where processing relies on your consent, you can withdraw it at any time. To make a request, send me a message through the contact form. I’ll reply within one month.

You also have the right to complain to a data protection authority: in the UK, the Information Commissioner’s Office (ico.org.uk); in the EU, the authority in the country where you live or work.

Children

I coach adults. This site isn’t aimed at children under 16, and I don’t knowingly collect their data.

Changes to this policy

If I change how I handle personal data, for example by adding new analytics or advertising tools to this site, I’ll update this page first and ask for your consent where the law requires it.

Personal plan and onboarding

I store your name, email, learning preferences, answers and the time and version of your policy acceptance in Neon Postgres. A copy of your answers is also emailed to my Gmail so I can prepare for our sessions. I use ChatGPT (OpenAI) to help prepare recommendations and a personal learning-plan PDF, which I keep in your existing client folder in Google Drive. The recommendations are coaching suggestions, not a verified English-level assessment or an automated decision about eligibility for coaching. This does not subscribe you to marketing emails. Please do not include confidential employer information. The coaching-record retention and data rights described on this page also apply. Legal basis: performance of the coaching contract and steps requested before it (Article 6(1)(b)).