§1. General Information
1. This Privacy Policy describes how Spiritus Experts Practice processes and protects personal data of Users using the platform at a‑spiritus‑practice.com.
2. This document has been prepared in accordance with Regulation (EU) 2016/679 (GDPR) and applicable data protection laws.
3. The Administrator takes appropriate technical and organisational measures to protect Users’ personal data and ensure the security of transmitted data, including the use of SSL encryption and secure communication protocols.

§2. Legal Basis and Purpose of Data Processing
1. Personal data (name, e‑mail, date of birth, submitted visual materials) are processed based on:  
a) Art. 6(1)(b) GDPR – for the purpose of concluding and performing a contract (delivery of personalized practice or analysis).  
b) Art. 6(1)(c) GDPR – for the purpose of fulfilling legal obligations (e.g., invoicing, accounting, and tax reporting).  
c) Art. 6(1)(f) GDPR – for the legitimate interests of the Administrator, including the management of disputes and compliance with legal and contractual obligations.

§3. Cookies Policy
1. The platform uses cookies, which are small data files stored on the User’s device.
2. Types of cookies used:  
a) Necessary cookies – enable the operation of the platform (e.g., security, authentication).  
b) Functional cookies – remember user preferences (e.g., language, font size).  
c) Analytical cookies – collect information about how Users interact with the website to improve functionality and user experience.  
d) Marketing cookies – allow the platform or third‑party partners to provide advertising content tailored to Users’ interests.
3. The platform uses session cookies (temporary) and persistent cookies (stored for a defined period in browser settings).
4. Users can manage cookies in their browser at any time. Disabling certain cookies, especially marketing cookies, may affect the functionality of the platform or the types of information you receive.

§4. Data Retention Period
1. Data processed for the purpose of delivering a service are stored for the duration required to complete the service and for up to 30 days thereafter for archival purposes. After this period, sensitive data (e.g., photos) are permanently deleted.
2. Accounting and invoicing data are retained for 5 years, counted from the end of the calendar year in which the tax payment deadline expires.

§5. User Rights and Contact
1. Each User has the right to access their data, correct it, request deletion, limit processing, transfer data, and object to processing.
2. To exercise these rights, the User may contact the Administrator at: info@a‑spiritus‑practice.com.
3. Users have the right to file a complaint with the relevant Data Protection Authority if they believe their data processing violates regulations.