Privacy Policy
Prepared July 18, 2026
This service is designed to collect as little personal data as possible. Because the work may involve information about sexuality, privacy is part of the service, not merely a compliance task.
1. Controller
The person responsible for processing under the General Data Protection Regulation (GDPR) is:
Luis Andrés-Vázquez
Trading as Roxu
Graunstraße 30
13355 Berlin
Germany
Email: hello@roxu.coach
2. Website use
The website does not set marketing cookies and does not use an analytics SDK, advertising pixel, contact form, or third-party font. Fonts and scripts are served from the website itself.
If you arrive through a campaign link, standard campaign parameters may be carried into the Cal.com booking link so the source of the enquiry can be identified. They are not stored by this website.
3. Hosting
The website is hosted by Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, USA. Vercel processes technical request and server-log data, which may include IP address, browser information, requested page, date, and time, to deliver and protect the website.
The legal basis is Article 6(1)(f) GDPR, the legitimate interest in operating a secure and functional website. International transfers are addressed through Vercel's data processing terms and the European Commission's Standard Contractual Clauses. More information is available in Vercel's privacy notice and data processing addendum.
4. Booking a free consultation
Bookings are handled through Cal.com. When you follow a booking link, Cal.com processes the information you submit, such as your name, email address, time zone, selected time, and answers to booking questions. Roxu receives the booking details to arrange and prepare the consultation.
The legal basis is Article 6(1)(b) GDPR, steps requested before entering into a contract. Do not include explicit sexual details or health information in the booking form. Cal.com's own processing is described in its privacy policy.
5. Email
If you send an email, the email address, message content, and related metadata are processed to answer your request and, where relevant, prepare or perform the consulting agreement. The legal basis is Article 6(1)(b) GDPR or Article 6(1)(f) GDPR.
Messages sent to an address at roxu.coach are routed through the free email-forwarding service provided by Porkbun LLC, 11575 SW Pacific Hwy PMB 40649, Tigard, OR 97223, USA, and forwarded to an existing Gmail account. For users in the European Economic Area, Gmail consumer services are generally provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Porkbun and Google may process message content, sender and recipient addresses, routing information, IP addresses, dates, and times as required to route, deliver, protect, and store email. Porkbun states that personal data is processed in the United States and that it uses appropriate transfer safeguards, such as the European Commission's Standard Contractual Clauses. Google states that information may be processed on servers around the world and relies on applicable transfer frameworks, including adequacy mechanisms and Standard Contractual Clauses where required. More information is available in Porkbun's privacy policy, Google's privacy policy, and Google's data-transfer information.
Do not send explicit sexual descriptions, intimate images, identification documents, medical records, or other unnecessary sensitive information by ordinary email. Email is used for brief enquiries, scheduling, logistics, invoices, and service administration.
6. Client intake and session information
If you choose to work with Roxu, the intake process collects only the information needed to confirm scope, understand your learning goals, and prepare the sessions. Minimal continuity notes may be kept. You are never required to provide graphic detail.
Ordinary contract and service information is processed under Article 6(1)(b) GDPR. Information that reveals sexual life or sexual orientation is special-category data. If processing that information is necessary, it is based on your explicit consent under Article 9(2)(a) GDPR. You may withdraw that consent at any time for future processing without affecting earlier lawful processing.
[INTAKE, FILE-STORAGE, AND VIDEO-CALL PROVIDERS REQUIRED BEFORE PAID DELIVERY]
7. Invoices and bank transfers
Invoices are prepared manually as PDF documents and recorded in the existing business accounts. No external invoicing platform is used for this service at launch. Invoice records include the information required to document the service and payment.
Payment is made by SEPA bank transfer. The banks involved process account and transaction data under their own legal obligations. Bank details are provided only on the invoice or in private payment instructions and are not published on this website.
The legal bases are Article 6(1)(b) GDPR for performing the agreement and Article 6(1)(c) GDPR for accounting and tax obligations.
8. Retention
- Unsuccessful consultation and enquiry records are scheduled for deletion within six months unless a longer period is needed to establish, exercise, or defend a legal claim.
- Intake information and continuity notes are scheduled for deletion six months after the consulting relationship ends, unless you request earlier deletion or a justified exception applies.
- Contracts, invoices, and payment records are retained only for the statutory period that applies to business and tax records.
9. Recipients and disclosure
Personal data is shared only with the service providers needed to operate the website, booking, communications, and paid engagement, or where disclosure is legally required. Client information is not sold and is not used for targeted advertising.
10. Your rights
You may request access, correction, deletion, restriction, portability, or objection where the GDPR provides those rights. You may also withdraw consent for future processing. Requests can be sent to hello@roxu.coach.
You may complain to a data-protection authority. The Berlin authority is the Berlin Commissioner for Data Protection and Freedom of Information.
11. Adults only
The service is only available to people aged 18 or older. If information from a person under 18 is received, it will be deleted and no service will be provided.
12. Changes
This policy will be updated when the website, providers, or operating process changes. The current version will remain available on this page.