Privacy policy.

Who I am

I am Fabrice Ficerai, based in Luxembourg. I build AI, automation and marketing systems for small and medium businesses across Europe. This policy explains how I handle personal data collected through this website.

For the purposes of the GDPR, I am the data controller for personal data collected through this website. You can reach me at [email protected] about anything in this policy.

What information I collect

I only collect information that is necessary. This may include:

• Contact details: name, email address, and whatever else you choose to share when reaching out through the contact form or by email.
• Project information: details about your business and project shared during onboarding or while working together.
• Chat messages: if you open the chat on this site, the messages you type, the address of the page you were on, your language, basic details about your browser and device, and your email address if you choose to give it. An AI assistant answers you, and I can read the conversation and take over at any point. Your IP address is not stored with the conversation, but it appears in my server's technical logs while they last (see how long I keep it).
• Website usage data: I run my own self-hosted, cookieless analytics to see which pages are useful. It records the page URL, the referring page, and basic technical details about the visit. It sets no cookies and uses no device storage. Your IP address is used only in memory, at the moment of the request, to derive an approximate location and, for business visitors, the organisation visiting; it is then discarded, and none of this usage data is linked to your identity. If my server is offline, these visit details wait at Cloudflare, with the IP address encrypted so that only my server can read it, until my server collects them; they are then deleted there, and after 7 days at the latest.
• Approximate location on the home page: the picture of the Earth on the home page marks roughly where you are. When you load the page, Cloudflare, which hosts this site, works out an approximate location (city level, rounded to about 11 km) from your IP address, and my site passes it straight to your browser, which places a small dot on the globe. It is not stored or logged by me, not linked to you, and not sent to anyone else. It can be wrong: a VPN or a mobile network can put the dot in another city.

I do not run advertising trackers, pixel tags, or a third-party analytics service such as Google Analytics on this site. The analytics described above is software I host myself: the data goes to my own server and is never shared with or sold to anyone. That server is in Australia, so your request is processed there at the moment of the visit; your IP address is used in memory only, as described above, and never stored on my server. Browsing this site sets no cookies and stores nothing on your device. The only exception is the chat, and only once you open it: see The chat, cookies and your device.

How I use your information

Information you provide is used solely to:

• Respond to your enquiry and discuss your project.
• Deliver agreed services and communicate about ongoing work.
• Send invoices and keep the records that tax and accounting law require.

I do not sell, rent, or share your personal information with third parties for marketing purposes.

These service providers process data on my behalf so the site, the contact form and the chat can function:

• Cloudflare: hosts this website, receives the email sent to my address at this domain and forwards it to my inbox, and processes request data (including IP address) to serve pages and protect against abuse. If my analytics server is offline, Cloudflare also holds the website usage data for it, with the IP address encrypted, until my server collects it (7 days at most).
• Resend: sends the message you type into the contact form to my inbox. The name, email address, topic and message you submit pass through Resend's systems. Resend is a US company; I use its Ireland sending region, but your message may still be processed outside the EU/EEA.
• OpenRouter and DeepInfra: write the chat assistant's replies. When you use the chat, your messages and the text of this site are sent to an AI language model through OpenRouter, which passes them to the hosting company DeepInfra. Both are US companies. I have set OpenRouter to use only providers that state they do not store your data or train models on it.
• Chatwoot's push service and Apple: when a chat starts or you write in it, a notification that may include the first words of your message is sent to my phone through the chat software's push service and Apple's notification service.

I also read aggregated search-performance data for this domain from Google Search Console, which shows which searches lead people here. This is data about how the site performs in search, not data collected from you as an individual visitor.

Note that the analytics is not in this list: it runs on infrastructure I control, so no analytics vendor handles it. The only outside party on its path is Cloudflare, which carries the network connection and, while my server is offline, holds the visits for it as described above.

The chat, cookies and your device

This site has a chat button. Nothing about the chat is loaded or stored until you click it: browsing alone sets no cookies, stores nothing in your browser and makes no request to the chat server.

When you open the chat, this is stored because it is needed to run the chat you asked for:

• cw_conversation, a cookie on doppio.lu holding a random identifier so your conversation carries on as you move between pages. It lasts up to one year (some browsers shorten that). Delete it in your browser settings and the next chat starts fresh.
• _chatwoot_session, a session cookie on chat.doppio.lu set by the chat software for its own security and session handling. It ends when you close the browser.
• A small cache in the chat window's local storage on chat.doppio.lu, for example whether anyone is available.

These are strictly necessary for a service you explicitly requested, so under the ePrivacy rules they need no consent banner. They are not used for advertising, analytics or tracking. If you have chatted before, the chat software loads quietly on later pages so that a reply from me can reach you. On large screens a short hint about the chat may appear; if you dismiss it, your browser remembers that for the rest of the visit.

The chat is an AI assistant, and it says so in the chat window. It answers from the pages of this site and makes no decisions about you. I can read every conversation. It passes the chat to me when you ask for a person, when you ask about prices, a quote or working together, or when the site does not answer your question, and when I join, I reply myself.

Conversations are stored on my own server, which is in Australia (the same place as the analytics), and the connection is carried by Cloudflare.

Legal bases for processing

The GDPR requires me to state the lawful basis for each kind of processing:

• Enquiries and client work: processed to take steps at your request before entering a contract, and to perform that contract (Article 6(1)(b)). Without your name, email and a description of the project, I cannot reply or deliver the work.
• Website analytics: processed under my legitimate interest in understanding which pages are useful and keeping the site working (Article 6(1)(f)). The analytics is cookieless, stores no identifiers, and discards the IP address in memory, so the impact on your privacy is minimal. No consent banner is required because nothing is stored on or read from your device.
• Approximate location on the home page: processed under my legitimate interest in showing visitors a relevant picture (Article 6(1)(f)). Nothing is stored, so the impact on your privacy is minimal.
• Chat: processed under my legitimate interest in answering visitors' questions about my services (Article 6(1)(f)) and, when you ask about working together, to take steps at your request before a contract (Article 6(1)(b)). The chat's cookies are strictly necessary for the service you asked for, so they do not rest on consent.
• Invoicing and records: processed to comply with legal obligations, principally tax and accounting law (Article 6(1)(c)).

I do not use personal data for automated decision-making or profiling, and I do not process special categories of personal data. The chat assistant only answers questions; it decides nothing about you. Please do not share sensitive information in the chat.

How long I keep it

• Enquiries that do not become projects: up to 24 months, then deleted.
• Client project files and correspondence: for the engagement, and afterwards for as long as accounting and tax law require the records to be kept.
• Chat conversations: deleted automatically after 90 days without activity. Opening the chat without writing anything leaves only an anonymous record, deleted after 7 days.
• Backups and logs: a nightly backup of the chat is kept for 14 days, so a deleted conversation can remain there for up to two more weeks. The chat server's technical logs, which show IP addresses, are overwritten automatically as they fill up and kept only for a limited time.
• Approximate location on the home page: not kept. It exists only in your browser while the page is open.
• Website analytics: retained in aggregate. No IP address or personal identifier is stored on my server, so there is nothing in it that identifies you. While my server is offline, visits wait at Cloudflare with the IP address encrypted, for 7 days at most.

Your rights

Under the GDPR, you have the right to:

• Access: a copy of the personal data I hold about you (Art. 15).
• Rectification: correction of inaccurate or incomplete data (Art. 16).
• Erasure: deletion of your data where I have no overriding legal reason to keep it (Art. 17).
• Restriction: to have processing paused while a dispute is resolved (Art. 18).
• Portability: your data in a structured, machine-readable format (Art. 20).
• Objection: to processing based on legitimate interest, including the website analytics and the chat (Art. 21).

To exercise any of these rights, email me at [email protected]. I will respond within one month. There is no charge. A chat is not tied to an account, so to find yours I need something to go on: roughly when you chatted and, if you gave one, your email address.

In practice, most of what people ask about is the analytics, and because it stores no identifiers at all, there is genuinely nothing held about you to access, export or erase. Chat conversations, enquiries and client correspondence are the data that actually exists.

Complaints

If you think I have mishandled your personal data, please contact me first and I will try to put it right. You also have the right to complain to a supervisory authority: the Commission nationale pour la protection des données (CNPD), the data protection authority for Luxembourg, at cnpd.public.lu, or the data protection authority in the country where you live or work.

Changes to this policy

I may update this policy from time to time. Material changes will be noted by updating the date at the top.