This policy explains what personal data we collect through conceptmanagers.com, why, who helps us process it, how long we keep it and what your rights are.
1. Who is responsible
Concept Managers is run by Brand managers, MB, a small partnership registered in Lithuania, which is the controller responsible for the processing described here:
Brand managers, MB
Company code: 306966162
VAT code: LT100019837814
Registered address: Žvejų g. 2C, Ringaudų k., LT-53337 Kauno r., Lithuania
Email: kamile@conceptmanagers.com
This policy covers this website, its forms and newsletter, and direct contact with us. Work for clients follows the terms agreed for each project.
2. Project brief form
The brief form on the Contact page asks for your name, email address, what you would like to change or create, and your preferred timing. Your organisation and the service you are interested in are optional.
When you send the form, the website checks the entries on the server and stores them, with the time they were received and the language of the page, in our database. We then receive an email notification with your brief so we can reply to you directly, and you receive a short confirmation email that we have received it. The confirmation repeats your name, organisation, service and timing, but not your message.
The website doesn’t place form entries in cookies, browser storage or page addresses. Please don’t send passwords, payment details or sensitive personal information through the form; it has no file-upload field.
3. Newsletter
To subscribe, you enter your email address and tick the box agreeing to receive our news by email. We then send you an email with a confirmation link, valid for 7 days. You are subscribed only after you confirm; until then we send you nothing else.
When you confirm, we add your email address and the language of the page to our mailing list, held with our email provider Resend, and record the time of your sign-up and confirmation in our database as proof of your consent. Every newsletter includes a link to unsubscribe at once. You can also unsubscribe by writing to kamile@conceptmanagers.com.
4. Why we process information
- Replying to a brief from an individual: to take steps you ask for before a possible contract (GDPR Article 6(1)(b)). Where you write for a business or organisation, replying relies on our legitimate interest in communicating with potential clients and partners (Article 6(1)(f)). A brief doesn’t form a contract or book work.
- Newsletter and Google Analytics: your consent (Article 6(1)(a)), which you can withdraw at any time.
- Protecting the website and its forms from spam and misuse: our legitimate interest in secure, reliable operation (Article 6(1)(f)).
- Answering privacy requests and keeping legally required records: our legal obligations (Article 6(1)(c)).
We don’t use your details for marketing unless you subscribe to the newsletter, we don’t sell personal data, and there is no automated decision-making with legal or similarly significant effects.
5. Cookies and your choices
This website uses no advertising cookies. It sets one necessary cookie of its own, and Google Analytics cookies only if you allow them:
| Cookie | Purpose | Kept for |
|---|---|---|
cm_consentNecessary | Remembers your cookie choice, so we don’t ask on every visit. It contains no personal details. | 6 months |
_gaAnalytics, only if you allow it | Google Analytics: distinguishes visitors, so visits can be counted. | 6 months |
_ga_<ID>Analytics, only if you allow it | Google Analytics: keeps track of the current visit. | 6 months |
On your first visit, a banner asks whether to allow analytics. “Necessary only” and “Allow all” are equally easy to choose, and the website works the same either way. Nothing optional is stored or loaded before you choose. You can change your choice at any time through Cookie Settings at the bottom of every page or with the button below; turning analytics off stops measurement and removes the Google Analytics cookies on this website.
Fonts and images are served from this website. Other services load only where described: Cloudflare Turnstile on the Contact page (section 7), and Google Analytics if you allow it (section 6). Links to Instagram, LinkedIn, Spotify and media articles open those services, whose own privacy policies apply.
6. Google Analytics
If you allow analytics, we use Google Analytics 4 to understand how the website is used: which pages are viewed, how visitors arrive (for example from a search engine or a link), their approximate location by country and city, the type of device and browser, and how long visits last. We see totals and trends, not who you are.
We don’t send your name, email address or what you write in our forms to Google. Google Analytics 4 doesn’t store IP addresses, and we have turned off Google signals and advertising personalisation. Google uses the data on our behalf as a processor. Analytics data is kept for 14 months and then deleted automatically.
7. Spam protection and technical records
To stop automated submissions, the brief form includes a hidden field that people don’t see. When you open the Contact page, Cloudflare Turnstile checks that the form is being used by a person, using technical information about your browser and device; usually you won’t see anything. Your network address and the Turnstile result aren’t stored with your brief.
Our hosting provider may keep standard technical records, such as IP address, time and the page requested, to run and protect the service. These are kept under the provider’s own retention rules.
8. Service providers and international transfers
We use these providers, each under data-processing terms:
- Cloudflare: website hosting, the server that receives the forms, and Turnstile spam protection.
- Supabase: our database for briefs and newsletter sign-ups, stored in the European Union (Frankfurt, Germany).
- Resend: sends the brief notifications and confirmations and the newsletter, and holds our mailing list.
- Google: Google Analytics, only if you allow it.
- Hostinger: hosts our mailbox.
Cloudflare, Supabase, Resend and Google are based in, or have group companies in, the United States and may process information outside the European Economic Area. Their terms provide safeguards for such transfers, such as the EU–US Data Privacy Framework or the European Commission’s Standard Contractual Clauses. Contact kamile@conceptmanagers.com for details of the applicable safeguards.
9. Direct contact and client work
If you email or call us directly, we use what you choose to send to reply and discuss your request. Depending on the circumstances, this may be necessary for steps you request before a contract, for an agreed contract, for our legitimate business interests or for legal obligations. Information shared during client projects is handled as agreed in each contract.
10. How long we keep information
- Briefs are deleted from our database automatically 180 days after they arrive. Email about a brief that doesn’t lead to work is deleted 180 days after our last substantive exchange.
- Newsletter sign-ups that are never confirmed are deleted automatically after 30 days.
- Confirmed subscriptions: your address stays on our mailing list until you unsubscribe or ask us to delete it. After you unsubscribe, Resend keeps your address marked as unsubscribed so you aren’t emailed again. The record of your sign-up and confirmation is kept in our database as proof of consent for 3 years after confirmation, then deleted automatically.
- Google Analytics data is kept for 14 months; the analytics cookies on your device expire after 6 months.
- Contract and accounting records are kept for as long as Lithuanian law requires.
Deleting information doesn’t recall email that has already been delivered, and it doesn’t immediately erase providers’ rotating backups, which expire under their own policies. Access to briefs and sign-ups is limited to the people who handle them.
11. Your rights
Depending on the applicable law and circumstances, you may ask for access to your personal data, or for its correction, deletion, restriction or portability. You may also object to processing based on our legitimate interests and withdraw consent at any time. Withdrawing consent doesn’t affect processing carried out before the withdrawal. Some records may need to be kept to meet a legal obligation or handle a claim.
Send requests to kamile@conceptmanagers.com. We may need to verify your identity before acting. You may also complain to Lithuania’s State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija) at vdai.lrv.lt.
12. Updates
We update this policy when our purposes, providers or arrangements change. The date at the top of this page shows the current version.