Privacy policy

1. Who is responsible

Naira Airapetian, Switzerland, is responsible for the data described here. Contact: naira@holanaira.ch. This policy follows the Swiss Federal Act on Data Protection (FADP) and, for visitors in the EU and EEA, the GDPR.

2. What we collect and why

• Free trial class booking: your name, email address, Spanish level, an optional goal, the level test result if you took it, the site language and the time you chose. Naira uses this to arrange and teach the class and to reply to you. Legal basis: taking steps at your request before a contract (GDPR art. 6(1)(b)) and your consent.
• Level test: your answers are scored in your browser session and are not stored. If you ask for the result by email, we use your address and answers once to send it. Legal basis: your request.
• Spanish tips by email (only if offered): your email address, level and language, after you confirm by a double opt in link. Legal basis: your consent. You can unsubscribe at any time.
• Security: our hosting provider processes your IP address to deliver the site, limit the number of requests and run a bot check (Cloudflare Turnstile). For this check your browser sends a token and your IP address to Cloudflare. We keep a one way hash of your email address for 24 hours to limit repeated emails. Legal basis: our legitimate interest in running a secure site.

3. Who receives your data

• Cloudflare (hosting, security, bot check and logs).
• Brevo, France (sending emails, and the tips list if used).
• Cal.com (booking calendar): your name, email address, time zone, language and the notes from the booking form are passed to cal.com, which stores the booking and sends the confirmation and calendar invite. Cal.com has its own privacy policy.
• Zoom, if you attend a class there. Naira sends you the link by email. Zoom's own privacy terms apply.
• We do not sell your data and we do not use advertising or analytics trackers.

4. Transfers abroad

Some providers process data outside Switzerland and the EEA, for example in the United States. We rely on adequacy decisions, the Swiss US and EU US Data Privacy Frameworks, or standard contractual clauses.

5. Cookies and similar technologies

This site sets no cookies of its own, uses no analytics and loads no advertising or social media content. Fonts are served from this site. The Cloudflare Turnstile bot check may use temporary browser storage that is needed to tell humans from bots.

6. How long we keep data

Booking emails stay in Naira's inbox while we are in contact and for up to two years after the last contact, unless the law requires longer or you ask us to delete them sooner. Level test answers are not stored. Tips subscribers stay on the list until they unsubscribe. Server logs are kept by Cloudflare for a short period.

7. Reviews and photos

Reviews and photos of students are published only with their permission. You can ask for yours to be changed or removed at any time.

8. Your rights

You can ask for access to your data, correction, deletion, restriction, a copy in a common format, and you can object to processing or withdraw consent at any time. Write to naira@holanaira.ch. You can also complain to the Swiss Federal Data Protection and Information Commissioner (FDPIC, edoeb.admin.ch) or to the data protection authority in your own country.

9. Children

The site is meant for adults. Children under 16 should book only together with a parent or guardian.

10. Changes

We may update this policy. The date at the top shows the latest version.