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Privacy

Privacy Policy

Last updated · May 11, 2026

This Privacy Policy describes how TRUE WORK LLC (operating under the "Fetén" brand) collects, uses, shares and protects personal data in connection with the website solofeten.com (the "Site").

TRUE WORK LLC is a US company organised in New Mexico, United States. This Policy is drafted to comply, where applicable, with: the EU General Data Protection Regulation 2016/679 (GDPR), the UK GDPR and the UK Data Protection Act 2018, the California Consumer Privacy Act as amended by the CPRA (CCPA/CPRA), the Australian Privacy Act 1988 and the Australian Privacy Principles, and the New Zealand Privacy Act 2020.

1. Controller

  • Controller: TRUE WORK LLC (Data Controller)
  • Form: Limited Liability Company (LLC), New Mexico, United States
  • EIN: 98-1934714
  • Address: Albuquerque, New Mexico, United States
  • Email: hola@solofeten.com

2. EU / UK Representative (GDPR Art. 27)

As of the date of this Policy, TRUE WORK LLC has not appointed a representative in the European Union or the United Kingdom pursuant to Article 27 of the GDPR or UK GDPR. TRUE WORK LLC will reassess and, if appropriate, appoint such representative as its systematic processing activities directed at EU or UK residents grow.

The absence of an appointed representative does not limit your rights as a data subject, which may be exercised directly with TRUE WORK LLC at the email above or before the competent supervisory authority (Section 14).

3. Categories of personal data we process

We process only the data strictly necessary for the purposes described. The categories are:

  • Identification and contact data you provide voluntarily by completing the contact form, booking a call or writing to us by email: name, email address, optional phone, company, role and message.
  • Booking data via Cal.com: name, email, and any qualification answers you choose to enter.
  • Technical and browsing data collected automatically: IP address (truncated by the analytics tool), browser type and version, operating system, device type, language, pages visited, date and time, referrer and aggregated interaction patterns.
  • Cookies and similar technologies as detailed in the Cookies Policy.
  • Contractual and billing data: when you book and pay a consultancy session via the Site (deposit of 100 € / USD 100), or when you engage a subsequent project, we collect legal / trading name, billing address, VAT ID / EIN or equivalent, and data needed to issue an invoice. Card or payment-method data is never processed or stored by TRUE WORK LLC: it is handled directly by Stripe under PCI-DSS.

We do not deliberately collect special categories of data (racial or ethnic origin, political opinions, religious beliefs, genetic, biometric, health or sexual-orientation data). If you voluntarily include them in a free-form message, we will minimise and delete them as soon as possible.

4. Purposes and legal bases (GDPR Art. 6)

Purpose Legal basis (GDPR)
Respond to enquiries sent through the form or by email. Consent (Art. 6(1)(a)) and/or pre-contractual measures (Art. 6(1)(b)).
Manage call bookings via Cal.com. Consent (Art. 6(1)(a)) and pre-contractual measures (Art. 6(1)(b)).
Deliver contracted professional services. Performance of a contract (Art. 6(1)(b)).
Comply with accounting, tax and legal obligations applicable to TRUE WORK LLC. Legal obligation (Art. 6(1)(c)).
Measure use of the Site through privacy-friendly analytics. Legitimate interest (Art. 6(1)(f)) where the tool is cookie-less and uses no personal identifiers (Plausible). If additional cookie-based analytics are activated, the basis becomes consent (Art. 6(1)(a)).
Activate advertising pixels and marketing tools (when enabled). Consent (Art. 6(1)(a)) provided through the cookie banner.
Prevent fraud, abuse and protect Site security. Legitimate interest (Art. 6(1)(f)), after balancing of rights.

5. Retention periods

  • Enquiries that do not become contracts: up to 12 months from last contact.
  • Call bookings: while in the calendar and up to 12 months after they are held or cancelled.
  • Booking-deposit and project invoices: retained for the applicable tax limitation period (generally up to 7 years under the laws of New Mexico, USA).
  • Active client data: for the duration of the relationship and up to the limitation period applicable under the laws of New Mexico, USA (generally up to 6 years for tax and accounting purposes).
  • Browsing / analytics data: as per the tool. Plausible stores no cookies and aggregates data without retaining individual identifiers.
  • Cookies and pixels: as detailed in the Cookies Policy.
  • Security logs: up to 12 months.

6. Recipients and processors

We do not sell personal data. We share data only with the following processors, all subject to contracts compliant with Article 28 GDPR (Data Processing Agreement) and required to apply appropriate security measures:

Provider Purpose Location
Hosting / CDN Serving the (static) Site. EU / US (global edge)
Plausible Analytics Cookie-less web analytics, aggregated data. European Union (Germany)
Formspree Processing of contact-form submissions. United States
Cal.com Call booking management and Stripe Checkout link generation. United States / European Union
Stripe (Stripe Payments Europe Ltd. + Stripe, Inc.) Booking-deposit payment processing, VAT/Tax ID validation, receipt issuance and fraud prevention. United States (Stripe, Inc., DPF-certified) and Ireland (Stripe Payments Europe Ltd.)
Google (GA4 / Google Ads), only if you give consent. Advanced analytics and campaign measurement. United States (DPF)
Meta Platforms (Meta Pixel), only if you give consent. Remarketing and campaign measurement. United States (DPF)

We may also disclose data when required by law, by court order, by a competent authority, or where necessary to defend legal rights, prevent fraud or protect the safety of persons or systems.

The current list of processors can be requested at hola@solofeten.com.

7. International data transfers

Because TRUE WORK LLC is established in the United States and some processors are too, data may be transferred to the US and other countries outside the European Economic Area, the United Kingdom, Australia and New Zealand.

In each case we apply the safeguards required by law:

  • EU / UK → US: preferred reliance on the EU-US Data Privacy Framework (DPF) and the UK Extension to the DPF with certified providers (Google, Meta). For other transfers, Standard Contractual Clauses (SCCs) approved by the European Commission + UK Addendum (IDTA), supplemented with technical and organisational measures (encryption in transit and at rest, data minimisation, access controls).
  • Australia → outside: disclosures to overseas recipients comply with Australian Privacy Principle 8, with contractual clauses requiring recipients to apply equivalent standards.
  • New Zealand → outside: disclosures comply with Information Privacy Principle 12, with equivalent contractual safeguards.

A copy of the safeguards applicable to a specific provider can be requested at hola@solofeten.com.

8. Automated decision-making and profiling

We do not carry out automated decision-making with legal effect on you, nor profiling that produces significant effects.

9. Children

The Site is not directed at children. We do not knowingly collect data from children under 16 (default GDPR threshold), under 13 (US COPPA threshold) or under 18 (the threshold applicable in some US states for sensitive data). If you become aware that a child has provided us with data without the authorisation of the parent or guardian, contact us and we will delete it.

10. Security

TRUE WORK LLC applies technical and organisational measures appropriate to the risk: HTTPS/TLS for all communications, Strict-Transport-Security, Content Security Policy, role-based access control, incident logging, internal privacy training and periodic vendor review.

In the event of a personal-data breach posing a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours pursuant to Article 33 GDPR and, where applicable, also affected individuals pursuant to Article 34.

11. Your rights (GDPR / UK GDPR)

If GDPR or UK GDPR applies to you, you have the following rights:

  • Access to your personal data and information about its processing.
  • Rectification of inaccurate or incomplete data.
  • Erasure ("right to be forgotten") where the conditions of Article 17 GDPR are met.
  • Restriction of processing in the cases set out in Article 18.
  • Objection to processing based on legitimate interest.
  • Portability of data you have provided, in a structured, commonly used format.
  • Withdraw consent at any time, without affecting the lawfulness of prior processing.
  • Not be subject to automated decisions with legal effect.

To exercise any of these rights, write to hola@solofeten.com indicating the right you wish to exercise. We may request additional information to verify your identity. We will respond within one month (extendable by two further months in complex cases under Article 12(3) GDPR).

12. Your rights (California — CCPA / CPRA)

If you are a California resident, you have the following rights in respect of the personal information we process:

  • Right to know what personal information we collect, the sources, the purposes and the recipients.
  • Right to request deletion of your personal information.
  • Right to correct inaccurate personal information.
  • Right to opt out of the sale or sharing of personal information for cross-context behavioral advertising.
  • Right to limit the use of sensitive personal information.
  • Right to non-discrimination for exercising your rights.
  • Right to designate an authorised agent.

TRUE WORK LLC does not sell personal information. When you accept marketing cookies, we may "share" information (as broadly defined under CPRA) with platforms such as Meta or Google for advertising purposes. You can exercise your opt-out right by rejecting those cookies in the banner or disabling them in the "Cookie settings" modal in the Site footer.

We also honour Global Privacy Control (GPC) signals sent by your browser, treating them as a valid opt-out request under CCPA. To exercise any other right, write to hola@solofeten.com.

13. Your rights (Australia and New Zealand)

If you reside in Australia, the Australian Privacy Principles (APP) grant you, among other things, the right to access your personal information, request its correction and file a complaint with the Office of the Australian Information Commissioner (oaic.gov.au).

If you reside in New Zealand, the Privacy Act 2020 and its Information Privacy Principles grant you equivalent rights of access and correction, and the ability to file a complaint with the Office of the Privacy Commissioner (privacy.org.nz).

14. Complaints to supervisory authorities

Without prejudice to your right to contact us directly, you may file a complaint with the supervisory authority of your country of residence. For reference:

15. "Do Not Track" and Global Privacy Control

Browsers may send signals such as "Do Not Track" or "Global Privacy Control" (GPC). The Do Not Track standard is not uniform and is not honoured automatically. We do honour GPC signals, treating them as a valid opt-out under CCPA and as a refusal of non-essential cookies in jurisdictions where applicable.

16. Changes to this Policy

We may update this Policy to reflect legal, technical or business changes. The current version is always available at this URL with the "Last updated" date shown above. If changes are substantial and affect you, we will notify you through the Site or the usual channels before they take effect.

17. Contact

For any matter relating to this Policy or the exercise of your rights, write to hola@solofeten.com with "Privacy" in the subject line.