Last updated 25 October 2026

Privacy note

This site doesn’t use cookies, analytics or tracking, and has no forms. The only personal data I receive is what you choose to send me.

Who is responsible

The data controller is Holy Cow OÜ, registry code 16173866, Narva mnt 5, 10117 Tallinn, Estonia. For anything about your data, write to hello@fractional-hdo.com.

What data is processed, and why

• Visiting the site. The site is hosted on Cloudflare. Like any web server, Cloudflare records technical data for each request: IP address, browser, the page requested and the time. This is needed to deliver the site and keep it secure (legitimate interest, GDPR Art. 6(1)(f)). The site itself loads nothing from third parties: fonts and images are served from this domain.
• Emailing me. Email for this domain is hosted by Google. If you write to me, I receive your name, email address and whatever you include in the message. I use it to reply and, if we decide to work together, to prepare and run the engagement (steps before a contract, Art. 6(1)(b), and legitimate interest, Art. 6(1)(f)).
• Booking a call. The “Book a call” links open a Google Calendar booking page. The details you enter there (name, email and any notes) are processed by Google under Google’s privacy policy and shared with me so I can hold the call.
• LinkedIn. Links to LinkedIn take you to LinkedIn’s site, where LinkedIn’s privacy policy applies.

How long data is kept

Emails and call notes are kept for as long as the conversation or engagement is active, and deleted when no longer needed. If we sign a contract, related records are kept for as long as Estonian accounting and tax law requires.

Who else sees it

Your data isn’t sold or used for marketing. Apart from the services named above (Cloudflare for hosting, Google for email and calendar bookings), it is shared only when the law requires it.

Cloudflare and Google may process data outside the EU, including in the United States. Both are certified under the EU–US Data Privacy Framework, which the European Commission recognises as providing adequate protection. See Cloudflare’s privacy policy and Google’s privacy policy.

Your rights

Under the GDPR you can ask to access, correct or delete your data, to restrict or object to its processing, and to receive a copy in a portable format. Write to hello@fractional-hdo.com. You can also complain to a data protection authority. In Estonia that is the Data Protection Inspectorate (Andmekaitse Inspektsioon), or you can contact the authority where you live.