Updated 11 October 2026

Privacy notice

Who is responsible

YMA Media Luxembourg S.à r.l.-S, 83, rue Emile Metz, L-2149 Luxembourg, is responsible for personal data processed through Counterfold. Contact us at info@counterfold.com.

Information we collect

When you submit an enquiry, we collect your organisation, work email, description of the decision or workflow, optional context and selected language. We also keep the submission reference, date, handling status and version of this notice.

Organisation, email and a description are required to submit the form; additional context is optional. Without the required details, we cannot accept the form enquiry. Please avoid confidential records and sensitive personal information. Submitting the form does not subscribe you to marketing.

Why we use it

We use these details to assess your enquiry, respond and discuss possible services. Where you enquire about a contract with you personally, processing is necessary to take steps at your request before entering a contract, under GDPR Article 6(1)(b). For contacts acting for an organisation, we rely on our legitimate interest in responding to business enquiries and managing prospective business relationships, under Article 6(1)(f).

We also process connection information and a hashed network identifier to operate the website and prevent abuse. Our legitimate interest is keeping the website and enquiry service available and secure.

Service providers and location

Authorised team members can access enquiries. Cloudflare provides website hosting, security and database services. The enquiry database runs and stores data within the European Union. This restriction does not cover all website processing: Cloudflare’s global services may process data outside the European Economic Area. Its published Data Processing Addendum describes applicable transfer arrangements, including the EU–US Data Privacy Framework and EU standard contractual clauses.

If you email us, Google delivers your message directly to our Counterfold mailbox for handling and response. Email processing is separate from storage of form submissions.

For handling and response, a copy of your enquiry, including any contact name you provide, is sent to our Google-hosted Counterfold mailbox. Replying to the alert uses your supplied work email. Database and mailbox access are restricted to authorised team members; the EU database restriction does not apply to email processing.

Website enquiry notifications are sent through Resend to this mailbox. Resend stores email data and logs in the United States, including when messages are sent from Ireland. The safeguards for this processing are described in its Data Processing Addendum.

Retention

For enquiries that do not become client engagements, our retention period is 12 months after the last substantive contact. Records are reviewed monthly and deletion is handled manually. If an enquiry becomes a client engagement, or particular records must be retained for legal reasons, the applicable purposes and retention arrangements will be explained separately.

Abuse-control records expire after one hour and are removed when a subsequent submission triggers cleanup.

Cookies and automated decisions

This site does not use advertising trackers or optional analytics cookies. Essential hosting and security services may process connection information to deliver and protect the website.

We do not use enquiry information for automated decisions producing legal or similarly significant effects.

Your rights

You may request access, correction, deletion or restriction of your personal data, and object to processing based on legitimate interests. Data portability applies where its legal conditions are met. Contact info@counterfold.com to exercise your rights.

You may also complain to Luxembourg’s Commission nationale pour la protection des données.