Privacy & Cookie Policy
Last updated: July 2026
1. Data Controller
Raja Sethi, sole trader · P.IVA 02534110511 · Tuscany, Italy
Contact: contact@rajasethi.com · rajasethi.com
2. What data this site collects and why
This is a personal professional website. It does not use advertising trackers or profiling of any kind. As of July 2026 it uses privacy-first, cookieless traffic analytics (see 2.e below). The other personal data processed is:
a) Email correspondence. When you write to contact@rajasethi.com, your message is routed via Cloudflare Email Routing to a private inbox. The public address is an alias · your email and message are forwarded and never stored by Cloudflare beyond the time needed for delivery. Your data is used solely to respond to your enquiry and, where relevant, to manage an ongoing professional relationship. Legal basis: Art. 6(1)(b) GDPR (pre-contractual or contractual necessity) and Art. 6(1)(f) GDPR (legitimate interest in responding to inbound communications).
b) Hosting and CDN logs. This site is hosted and served via Cloudflare Pages and its CDN. Cloudflare automatically processes standard request data · IP address, browser type, pages requested, timestamps · for security, DDoS protection, and network performance. This processing is carried out by Cloudflare under its own privacy obligations. Raja Sethi does not have access to individual visitor logs. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in security and availability of the website).
c) Images served via Cloudinary. Profile and production images on this site are served from Cloudinary's CDN (res.cloudinary.com). When your browser loads a page, it fetches these images directly from Cloudinary's servers. Cloudinary may process your IP address as part of standard CDN delivery. No personal data is intentionally shared with Cloudinary beyond what is technically necessary to serve images.
d) Fonts served via Google Fonts. Typography on this site is loaded from fonts.googleapis.com. When your browser requests a font file, Google receives your IP address and browser information. Google operates this service under its own privacy policy. No other data is shared with Google through this site.
e) Aggregate traffic analytics. This site uses Cloudflare Web Analytics to understand overall traffic patterns (pages viewed, approximate location, referring site). This service does not use cookies, does not set any persistent identifier, and does not track you across other websites. Cloudflare states that no individual visitor is identifiable from this data. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in understanding and improving the site), no consent required as no personal identifiers are processed. Privacy policy: cloudflare.com/web-analytics/privacy-policy
3. Cookies and browser storage
This site does not use tracking cookies or advertising cookies of any kind. Its traffic analytics (2.e) is cookieless by design.
The only local storage used is a single key · cookie_consent, saved in your browser's localStorage to remember whether you have acknowledged this notice. This value never leaves your device and is never transmitted to any server. It is not a cookie under the ePrivacy Directive; it is purely a client-side preference record.
Third-party requests (Cloudflare CDN, Cloudinary, Google Fonts) may set or read their own technical identifiers as part of standard CDN operation. These are infrastructure-level and are not used for advertising or cross-site tracking.
4. Data sharing and third-party processors
Your data is never sold, rented, or shared for commercial purposes. The following third parties process data as a technical consequence of how the site operates:
Cloudflare, Inc. (US) · hosting, CDN, email routing, and cookieless Web Analytics. Cloudflare is certified under the EU/US Data Privacy Framework and processes data under Standard Contractual Clauses. Privacy policy: cloudflare.com/privacypolicy
Cloudinary Ltd. (US/Israel), image delivery CDN. Processes IP address for image serving only. Privacy policy: cloudinary.com/privacy
Web3Forms (web3forms.com) · form submission service used for masterclass applications, course registrations, programme waiting lists and online-training enquiries. Depending on the form, details such as name, email, phone, country, experience, training interests and notes are processed by Web3Forms and forwarded to contact@rajasethi.com for the purpose of responding to the request. Legal basis: Art. 6(1)(b) GDPR. Privacy policy: web3forms.com/privacy
Google LLC (US) · Google Fonts. Processes IP address for font delivery. Google participates in the EU/US Data Privacy Framework. Privacy policy: policies.google.com/privacy
Email received at contact@rajasethi.com is read and managed using a private email provider of Raja Sethi's choosing. No third party has access to your email content beyond what is technically necessary for delivery.
5. Data retention
Email correspondence is retained for as long as necessary to manage the professional relationship, and no longer than 3 years from the last exchange unless a legal or contractual obligation requires otherwise. You may request deletion at any time.
Cloudflare CDN logs are retained according to Cloudflare's own policies (typically short-term, for operational purposes). Raja Sethi does not control or extend this retention.
6. Your rights under GDPR and Italian law
Under Regulation (EU) 2016/679 (GDPR) and the Italian Codice della Privacy (D.Lgs. 196/2003 as amended by D.Lgs. 101/2018), you have the right to:
, Access the personal data held about you (Art. 15)
, Rectification of inaccurate data (Art. 16)
, Erasure ("right to be forgotten") where no overriding legal basis exists (Art. 17)
, Restriction of processing in certain circumstances (Art. 18)
, Data portability for data processed on the basis of consent or contract (Art. 20)
, Object to processing based on legitimate interest (Art. 21)
, Lodge a complaint with the Italian supervisory authority: Garante per la protezione dei dati personali, garante@garanteprivacy.it
To exercise any of these rights, write to contact@rajasethi.com. Requests will be responded to within 30 days.
7. Changes to this policy
This policy may be updated to reflect changes in the site's technical infrastructure or applicable law. The date at the top of this document reflects the most recent revision. Continued use of the site after a revision constitutes acceptance of the updated policy.