Privacy
Policy

1. Who We Are

This Privacy Policy applies to kevinleflar.com, operated by Kevin Leflar, principal of Artist Consulting Team Limited (ACT) and Project Gemini Corporation, based in Toronto, Ontario, Canada.

Kevin Leflar is the data controller responsible for your personal information collected through this Site. For any privacy-related questions, please use the contact details at the bottom of this page.

2. What Information We Collect

This is a static informational website. We do not operate user accounts, online stores, or subscription services through this Site. The personal information we may collect is limited to:

• Contact information you voluntarily provide when reaching out by email — such as your name, email address, phone number, and the contents of your message
• Technical data automatically collected by our hosting provider (Cloudflare), including your IP address, browser type, device type, pages visited, and time of visit
• Analytics data, if analytics tools are enabled, used in aggregate and anonymized form to understand how the Site is used

We do not use contact forms, newsletter sign-ups, or cookie consent banners that collect personal data without your knowledge.

3. How We Use Your Information

Any personal information you provide — for example, by emailing us directly — will be used solely to:

• Respond to your inquiry or request
• Follow up on potential business or partnership discussions
• Maintain records of professional communications as required

4. Legal Basis for Processing (GDPR)

For individuals in the European Economic Area (EEA) or United Kingdom, our legal basis for processing personal data is:

• Legitimate interests — to respond to business inquiries and maintain professional relationships
• Consent — where you have voluntarily provided information and context indicates your agreement to its use
• Legal obligation — where applicable law requires us to retain certain records

5. Cookies and Tracking

This Site is hosted on Cloudflare Pages. Cloudflare may set technical cookies necessary for security and performance. These are not used for advertising or tracking across third-party websites.

We do not use Google Analytics, Facebook Pixel, or other third-party advertising or behavioural tracking tools on this Site.

If you use a browser plugin to block cookies or tracking scripts, it will not affect your ability to use this Site.

6. Data Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share limited information only in the following circumstances:

• Service providers — such as our hosting provider (Cloudflare) who process data on our behalf under appropriate data processing agreements
• Legal requirements — if required by law, court order, or governmental authority
• Protection of rights — where necessary to protect the rights, property, or safety of Kevin Leflar, his companies, or others

7. Data Retention

We retain personal information only for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable law. Business correspondence is typically retained for up to 7 years in accordance with standard commercial and tax record-keeping requirements.

Technical log data retained by Cloudflare is subject to their own retention policies.

8. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Access — request a copy of personal data we hold about you
• Correction — request correction of inaccurate or incomplete data
• Deletion — request deletion of your personal data, subject to legal retention requirements
• Objection — object to certain uses of your personal data
• Portability — request transfer of your data in a commonly used format
• Withdrawal of consent — where processing is based on consent, withdraw it at any time

To exercise any of these rights, please contact us using the details below. We will respond within 30 days. You also have the right to lodge a complaint with your local data protection authority.

9. Data Security

We take reasonable steps to protect your personal information from unauthorized access, disclosure, alteration, or destruction. This Site is served over HTTPS via Cloudflare, which provides encryption in transit and DDoS protection.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security.

10. International Transfers

Kevin Leflar operates internationally across North America, Europe, the UK, Australia, New Zealand, and Japan. If you contact us from outside Canada, your information may be processed in Canada or other countries where our service providers operate. By contacting us, you acknowledge this.

Where applicable, we ensure appropriate safeguards are in place for international data transfers in accordance with GDPR requirements.

11. Children's Privacy

This Site is not directed at children under the age of 16. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will promptly delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically. Continued use of the Site after changes are posted constitutes your acceptance of the revised policy.

13. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact: