Governance // Legal Transparency

Privacy Policy

Effective Date: January 1, 2026 // Last Updated: September 21, 2026

This Privacy Policy explains how Kevin Girelli ("we", "us", or "our"), operating the website https://kevingirelli.dev, collects, processes, and protects personal information when you visit this site or submit an enquiry.

Zero Ad Tracking

We run zero commercial advertising trackers, pixel tags, or invasive cross-site profiling scripts.

Encrypted Transit

All network traffic is encrypted via HTTPS / TLS 1.3 with modern HSTS and security headers.

User Data Sovereignty

You maintain full rights to inspect, update, or request the immediate deletion of your submitted data.

1. Data Controller Identification

The data controller responsible for the processing of personal data on this website is:

Entity Name: Kevin Girelli Dev

Principal Operator: Kevin Girelli

Registered Jurisdiction: Criciúma, Santa Catarina, Brazil

Contact Email: kevingirelli.gg@gmail.com

2. Information We Collect

We collect minimal information strictly necessary to provide our web presentation and communicate with potential clients:

  • Communication Data: When you submit the contact form or send an email, we receive your name, email address, company/project details, and message contents.
  • Technical & Diagnostic Telemetry: Anonymized performance metrics collected via Vercel Speed Insights (such as First Contentful Paint, Cumulative Layout Shift, and browser family) to measure site responsiveness without identifying individual users.
  • Server Access Logs: Standard HTTP request logs collected by our hosting infrastructure (Vercel Edge Network), including IP address, user agent, requested URI, and timestamps, retained solely for DDoS mitigation and infrastructure security.

3. Purpose and Legal Basis for Processing

We process personal information under the following legal bases recognized by the European Union General Data Protection Regulation (GDPR) and the Brazilian General Data Protection Law (LGPD - Lei nº 13.709/2018):

  • Contractual Steps & Consent (Art. 6(1)(b) GDPR / Art. 7(V) LGPD): Processing your contact message to formulate a technical proposal or respond to your consultation inquiry.
  • Legitimate Interests (Art. 6(1)(f) GDPR / Art. 7(IX) LGPD): Ensuring network security, monitoring uptime, preventing abusive requests, and maintaining high platform stability.

4. Third-Party Service Providers

We do not sell, rent, or trade your personal information to third parties. We engage reputable infrastructure providers who act as data processors under contractual confidentiality:

Vercel Inc. (USA)

Provides edge cloud hosting, SSL termination, and anonymous Web Vitals performance analytics.

Nodemailer / SMTP Provider

Facilitates secure transmission of project inquiries submitted via our contact form directly to our inbox.

5. Cookies and Local Storage

This website does not utilize advertising cookies or behavioral tracking cookies. We utilize browser local storage solely for non-tracking functional states (such as remembering UI smooth-scrolling preferences). No personal data is stored in cookies.

6. Your Statutory Rights (GDPR & LGPD)

Regardless of your geographic location, you hold the following rights regarding your personal information:

  • Right of Access: You may request a copy of the personal data we hold about you.
  • Right to Rectification: You may request correction of inaccurate or incomplete information.
  • Right to Erasure ("Right to be Forgotten"): You may request that we delete your messages and contact records from our communications archive.
  • Right to Restrict Processing: You may request limitation of the processing of your data under statutory grounds.

To exercise any of these rights, email us at kevingirelli.gg@gmail.com. We will respond within 15 calendar days.

7. Updates to this Policy

We may revise this Privacy Policy periodically to reflect technological advancements, service updates, or statutory amendments. Significant revisions will be reflected with an updated effective date on this page.