Privacy policy
This policy explains what personal data this website and E2Pathway process, why, on what legal basis, for how long, and what rights you have. It is written for visitors in the EU, Switzerland and the United States. The German version at Datenschutzerklärung is the authoritative text for the German-language site.
1 · Controller
Tom Plan Law, PLLC (trading as E2Pathway), 215 Main Street, Penn Yan, NY 14527, USA · [email protected] · +1 315 575 4205.
2 · What we process, why, on what basis, for how long
Server logs. Cloudflare, our hosting provider, records IP address, timestamp, requested page, referrer and browser for security and operation. Legal basis: legitimate interest (Art. 6(1)(f)).
E-mail. Name, e-mail, optional phone, your message — to answer your enquiry and run a conflicts check. Basis: steps at your request prior to a contract (Art. 6(1)(b)). Retention: 12 months if no engagement follows.
3 · Recipients and processors
Cloudflare, Inc. (hosting — processing agreement under Cloudflare’s Data Processing Addendum). No data is sold or shared for advertising.
4 · Transfer to the United States
We are a US firm; data you send us reaches New York. The European Data Protection Board's guidance treats data a person sends directly to a controller outside the EU as a direct collection rather than a transfer; where a transfer under Chapter V nonetheless occurs — for example to our processors — it rests on standard contractual clauses (Implementing Decision (EU) 2021/914) with a documented transfer impact assessment, and only additionally on the EU–US Data Privacy Framework where a processor is certified.
5 · Your rights
Access, rectification, erasure, restriction, portability, objection (Art. 15–21 GDPR), and withdrawal of any consent at any time with effect for the future — by e-mail to [email protected] or one click in any newsletter. You may complain to a supervisory authority. Because we have no establishment in the EU there is no lead authority: the authority of your own German federal state (list), the Austrian Datenschutzbehörde, or the Swiss FDPIC.
6 · Visitors in the United States
We do not sell personal information and do not use it for cross-context behavioural advertising.
7 · Changes
This policy is dated at the top. Material changes are announced on this page; the previous version is available on request.