Privacy Policy
Spiral — Wood-fired Banya Rituals, Funchal, Madeira
Last updated: September 2026
1Who we are
Ruslan Trubchik, independent service provider, NIF 311270530, Vereda da Cova 57, São Gonçalo, 9060-080 Funchal, Portugal, is responsible for personal data processed in connection with the Spiral website, booking enquiries and participation in our banya rituals.
2What data we process
The website is informational only and does not accept online payments or automatically confirm bookings. Depending on how you contact or book with us, we may process:
- name, phone number, e-mail or messaging username;
- booking details and messages;
- invoicing information;
- emergency contact details;
- health-related information provided in the participant consent form before the ritual;
- photos or video only where you separately consent to promotional use.
The public website does not collect health information or payment-card details.
3Why we use your data
We use personal data to answer enquiries, arrange and provide bookings, issue invoices and comply with legal obligations, manage participant safety, respond to emergencies, and use promotional photos/video only with separate consent. Health information is processed with explicit consent where required under Article 9 GDPR.
4Sharing and retention
We share data only where necessary with our accountant, IT/hosting or communication providers, public authorities, or emergency services. We do not sell personal data. Data is kept only as long as needed or required by law. Participant consent and related safety records are currently intended to be kept for up to 3 years after the ritual, unless a longer period is legally necessary.
5Third-party platforms and cookies
If you contact us through WhatsApp, Telegram or another third-party platform, that provider may process your data under its own privacy terms. The current website is intended to operate without advertising pixels, behavioural tracking or non-essential analytics cookies. If this changes, this Policy will be updated and consent will be requested where required.
6Your rights and contact
Under the GDPR, you may have rights to access, correct, erase, restrict or object to processing of your data and, where applicable, data portability. Where processing is based on consent, you may withdraw it at any time.
Contact: rtrubchik@gmail.com. You may also lodge a complaint with the Comissão Nacional de Proteção de Dados (CNPD): www.cnpd.pt.
Ruslan Trubchik — NIF 311270530
Vereda da Cova 57, São Gonçalo, 9060-080 Funchal, Madeira, Portugal
WhatsApp: +351 962 312 800
Telegram: @DariaMazalova
