Privacy policy
Last updated: 13 September 2026.
1. Responsibility and scope
Tillerstone, LLC is the controller of personal data processed through this website. Contact address: Kyiv, 01010, Instytutska 19, Ukraine. Privacy contact: contact@tillerstone.eu.
This notice covers visits and initial enquiries. Confidential disclosure, formal qualification, paid services and outreach need their own stage-appropriate arrangements before they begin. Initial contact does not imply permission for marketing, disclosure to investors or an NDA.
2. Information collected
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| Context | Information |
|---|---|
| Website visit | IP address, request time, browser and technical/security signals handled by hosting infrastructure |
| Initial enquiry | Enquiry type, name, email and short outline; organisation (required for a project-specific investor enquiry, otherwise optional) and optional role; optional project/portfolio, technology, component MW and BESS MWh, region, stage, transaction objective and instrument, amount, grid position, actual/expected commissioning, revenue arrangements and timing; investor/lender role, geography, technologies, stages, size, participation and search criteria |
| Security and delivery | IP address for rate limiting and verification, security token and a random submission identifier for delivery retries |
| Correspondence and requests | Reply contact, relevant correspondence, next action and minimum records needed to handle a request or complaint |
You supply the form information. Do not include identity documents, exact project coordinates, special-category data or confidential source documents. The form has no attachments. Providing an enquiry is voluntary, not a statutory requirement. Name, email and a brief outline are required to submit the form; organisation is also required for a project-specific investor enquiry. Without required information the form cannot be submitted, and without suitable contact details we cannot reply. Other fields may remain blank.
3. Purposes and grounds
Where the GDPR applies, the following grounds apply separately from analytics consent.
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| Purpose | Legal basis |
|---|---|
| Answer your enquiry and take the follow-up you request | Article 6(1)(b) where necessary for steps you request towards a contract with you personally; otherwise Article 6(1)(f), our legitimate interest in answering business correspondence |
| Operate the website, prevent abuse and avoid duplicate delivery | Article 6(1)(f), our legitimate interest in providing a reliable and secure service, using proportionate safeguards |
| Handle statutory rights requests | Article 6(1)(c), compliance with the applicable legal duty |
| Handle other complaints and keep limited evidence for concrete claims | Article 6(1)(f), our legitimate interest in resolving issues and establishing or defending claims |
| Remember and respect your analytics choice | Article 6(1)(c) where required for applicable consent duties; otherwise Article 6(1)(f), our interest in respecting your choice |
Optional analytics and future relevant-project emails rely on separate consent under Article 6(1)(a), as described below. Where Ukrainian law applies, the corresponding grounds are consent, necessary requested pre-contract or contractual steps, applicable legal duties and balanced legitimate interests under Article 11 of Law No. 2297-VI.
Reading this notice is not blanket consent. There is no marketing consent bundled with the enquiry. If a later activity changes the purpose, recipients or information needed, the founder must establish the appropriate basis and provide the relevant information first.
The investor/lender form offers a separate, unchecked consent to future free relevant-project emails from Tillerstone, selected using the criteria you provide. This specific project-notification permission does not cover unrelated marketing and is not required to submit an enquiry. Notifications have not launched. If selected, the enquiry email records the consent and text version, with the email delivery timestamp for the operator to review; it does not enrol you in an automated mailing system. You may withdraw via contact@tillerstone.eu. Criteria and consent are not published or sold, and do not commission paid work. The existing enquiry retention and rights rules below also apply to these records.
3.1. Optional analytics
If you accept analytics, Google Analytics 4 measures page visits, scrolling, outbound links, selected structured catalogue searches and enquiry start, error and accepted-submission events. The purpose is to understand website use and acquisition effectiveness and improve the enquiry journey. Optional analytics relies on your consent, separately from submitting an enquiry. You can reject or withdraw through Analytics settings in the footer without losing access to the site or forms.
Custom enquiry events contain only the enquiry type, language and, where applicable, a public project ID and a controlled technology label. They do not contain your name, email, phone, company, enquiry text, project description, security token or raw error response. Complete forms are not sent to Google. Page addresses are cleaned for measurement; arbitrary query parameters, URL fragments and free-text searches are excluded. Only the five campaign parameters utm_source, utm_medium, utm_campaign, utm_content and utm_term are considered for acquisition measurement. Their values are filtered for length and permitted characters before they enter a measured page address; this filter cannot recognise every name or confidential reference. Do not put personal or confidential information in campaign labels. Campaign parameters may remain in browser addresses and follow internal links before analytics consent, without a separate attribution store or transmission to Google Analytics before consent. Hosting receives the original page request; cleaning an address for Google does not remove it from browser history. Analytics is withheld when a recognised search parameter contains a non-empty value other than a supported technology or the recognised project-ID format.
Google's tag also processes pseudonymous browser/session identifiers, basic browser/device information, cleaned page addresses, the referring site's origin, interaction and consent signals, and approximate country/region information. Requests expose an IP address to the receiving service; these data are not guaranteed anonymous. Google describes its regional IP handling in its privacy documentation and information for other regions. Detailed location/device collection and advertising personalisation are disabled for all available regions in our Analytics property. Google Signals and user-provided data collection are off. We do not use User-ID, advertising cookies, remarketing, Google Ads advertising integrations or visitor fingerprinting for analytics. See the Cookie policy for storage, expiry and choices.
4. Enquiry path
Cloudflare Workers provides hosting and handles enquiry requests. When enquiries are available, Cloudflare Turnstile loads automatically for the active form on the homepage and on project pages with an enquiry form; switching enquiry tabs starts the check for the selected form. It processes browser and network signals for abuse prevention. On submission, the Worker validates the request and challenge before sending a plain-text message through the Zoho Mail API using Zoho EU endpoints over HTTPS. The sender and recipient are contact@tillerstone.eu; your validated email address is used as Reply-To.
The application stores no enquiry content in a database, does not deliberately log enquiry contents and does not save form fields in browser localStorage or sessionStorage. Inputs remain on the page following an error; after provider acceptance the form clears. Acceptance by the sending provider is not proof of inbox receipt. No automatic acknowledgement email is sent to the visitor.
Initial correspondence is received in Zoho Mail. No separate CRM or cloud document store is used.
The application does not automatically export enquiries to a tracker, storage service or AI tool.
For duplicate protection, a Cloudflare Durable Object stores a hash of the message, delivery status and expiry linked to a random submission ID. Cleanup is scheduled after 24 hours. The message text, visitor email, IP address and security token are not stored in this record.
5. Recipients and international processing
The operator uses Cloudflare for hosting, request security and duplicate-delivery protection, and Zoho Mail for enquiry email. They process the information needed to provide those services. Cloudflare, Inc. also describes its separate controller role in improving bot detection in the Turnstile privacy notice. Initial submission does not authorise release of your project or contact details to prospective counterparties.
Google processes the core Analytics service data on our instructions under the accepted Analytics data-processing terms. Provider account administration and separate provider purposes follow their own notices; not every provider use is processing solely on our behalf. See Google's partner-site data explanation.
The operator handles information in Ukraine. Google and Cloudflare processing can involve the United States and other countries. Zoho EU mail endpoints do not mean all access remains in the EEA: Zoho describes authorised support access from India. The providers publish their arrangements in Google's transfer terms, Cloudflare's data-processing addendum and Zoho's privacy information.
For transfers covered by GDPR Chapter V, the EU–US Data Privacy Framework can apply to qualifying transfers to certified US recipients; other transfers require applicable contractual or other safeguards, including Standard Contractual Clauses where within their scope. The mechanism depends on the recipient and destination; US certification does not cover access in Ukraine or India. Ukrainian foreign-transfer rules apply separately where relevant. These safeguards do not eliminate all transfer risk. Contact contact@tillerstone.eu for information about the applicable recipients and safeguards or copies of the relevant terms, with necessary confidential information protected.
Withdrawing analytics consent stops future collection; it does not automatically erase previous Analytics records. Contact the operator about applicable access or erasure rights.
6. Retention
The following periods apply to records within the operator's control.
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| Category | Period or criterion |
|---|---|
| Analytics preference and browser cookies | The analytics choice is valid for 180 days. Cookie lifetimes and browser records that may remain after the choice expires are described in the Cookie policy. |
| Google Analytics service data | Event and user-data retention settings are 14 months. Reset on new activity is enabled for user data, so new activity renews the user identifier’s retention period. Google applies monthly deletion and distinguishes user/key-event data, other events and standard aggregated reports; the settings do not mean every Google record or aggregated report is deleted after exactly 14 months. |
| Initial enquiries and active contacts | Delete or anonymise inactive enquiries six months after the last substantive interaction. Keep active contacts only while needed and review them at least every six months. The exception rules below apply. |
| Exploratory working documents, if later collected | Delete or return exploratory working documents within ninety days after the case closes, unless a documented exception below requires a limited subset. |
| Minimum permissions, complaints, rights and other evidential records | Keep only the minimum record of a permission, complaint, rights request, contract or specific incident for its documented continuing purpose or applicable legal period. Record the basis and review/end date; do not retain the full enquiry or project archive merely because one record is needed. |
| Spam and irrelevant material | Delete promptly after identification, unless minimal evidence is needed for a specific security incident. |
The operator is responsible for review and deletion. Cloudflare controls infrastructure logs and security-signal retention under its privacy notice, considering service/security needs and legal obligations. Browser security storage is described in the Cookie policy. Mail recovery and backup copies follow the provider’s applicable retention and account settings; no unverified fixed deletion deadline is promised. The operator remains responsible for establishing applicable limits and applying deletion to records it controls. Later statutory or contractual records require their own justified schedule, not indefinite retention of every enquiry.
Longer retention is limited to a specific legal obligation, an existing or reasonably anticipated dispute, handling an unresolved rights request or complaint, or minimum evidence of a permission or security incident. The founder records which information is needed, why, who may access it and the review or end date. Review exceptions at least every ninety days and delete the retained subset when the basis ends. A generic possibility of future usefulness is not an exception.
An erasure request is considered when received; the ordinary schedule is not a reason to postpone it. If deletion is lawfully restricted, explain the applicable reason and restrict other use. Provider backup copies must follow verified provider limits; remove data from active systems, restrict restored copies and reapply deletion after restoration. No unverified backup deletion deadline is promised.
The inactive-enquiry period runs from the last substantive exchange, not from an automated reminder or bulk message. Deletion covers relevant received and sent correspondence and copies within the operator's control. Moving a message into Trash does not establish permanent deletion. Zoho describes recovery after removal from Trash in its mail deletion policy; the account-specific procedure must be checked before a final deletion date is promised.
7. Rights and contact
To help locate your records, identify the email used for your enquiry, an approximate date and the action you request. We first use available correspondence; additional identity information is requested only where necessary through an agreed suitable channel. An enquiry email may not identify Analytics records: provide an approximate visit date and page, and we can explain which existing browser identifier may help. We do not collect new identifying data solely to identify pseudonymous analytics records.
Where the GDPR applies, you may request access, correction, erasure or restriction, object to processing and, where its conditions are met, receive portable data. You may withdraw consent at any time without affecting the lawfulness of earlier processing. You may object, on grounds relating to your situation, to processing based on legitimate interests; you may object to direct marketing at any time without giving a reason. You may complain to a competent supervisory authority, including in the EU country of your habitual residence, work or the alleged infringement. These rights have legal conditions and exceptions. See GDPR, Articles 7 and 15–22.
GDPR requests receive a response within one month. A permitted extension of up to two further months requires notice and reasons within the first month. If we decline a request, we explain why and identify complaint and judicial remedies. Requests are normally free. See the EDPB rights guidance.
Where Ukrainian law applies, you may seek information about processing and recipients, access your data, make a reasoned objection or request correction or destruction of unlawfully processed or inaccurate data, withdraw consent and complain to the Ukrainian Parliament Commissioner for Human Rights or a court. Under the access procedure, the initial decision is communicated within ten working days and the request is fulfilled within thirty calendar days unless law provides otherwise. See Law No. 2297-VI, Articles 8 and 16.
Contact contact@tillerstone.eu to ask about your data or exercise applicable rights. Only proportionate identity confirmation should be requested; do not send a passport through this form.
The founder reviews enquiries personally. There is no automated investment decision or project qualification. Automated abuse protection can block submission; use the confirmed alternative contact when available. No transmission method guarantees absolute security.