Legal information

Privacy Policy

A clear explanation of what personal data we process, why we use it and what rights you have.

Updated 22 July 2026.

In brief

We use personal data to respond to your enquiry, administer a portfolio strategy order, confirm payment, provide digital content and fulfil our accounting obligations. We do not sell personal data. We request only the information needed for a specific purpose.

Data controller

The controller of personal data collected through this website and enquiries submitted through it is Martynas Juška, carrying out individual activity in his own name. “Financial Freedom” is the business name and brand used for this activity, not a separate legal entity or data controller.

Privacy enquiries
juska.martynas@gmail.com

Telephone
+370 639 87126

Meeting location
P. Lukšio St. 32, Vilnius, Lithuania

Data relating to enquiries, orders and services is processed for the purposes of Martynas Juška’s individual activity.

Personal data we process

When you contact us or submit an enquiry

your name, telephone number and email address;
your chosen consultation topic and the range of the amount you plan to invest;
your description of your situation, questions and any other information you choose to provide;
information contained in subsequent correspondence and arrangements.

Fields marked as required are necessary so that we can contact you and respond. If you do not provide this information, we may be unable to respond to your enquiry.

Before submitting the form, you confirm that you have read this Privacy Policy and agree that the data you provide may be used to respond to your enquiry. The form plugin does not store this data in the WordPress database: it is sent directly to the email account used by Martynas Juška.

When you order a portfolio strategy

your first name, surname, email address, telephone number and the address required for an invoice or other billing details;
the selected strategy, product and purchase terms versions, order number, date, amount, currency, applicable taxes, payment method and payment status;
your acceptance of the purchase terms, request for the digital content to be supplied immediately and acknowledgement concerning the right of withdrawal, including the versions and time of those statements;
the payment provider’s transaction identifier and the payout or refund status, but not the full details of your payment instrument;
information relating to the invoice, credit document, order security code, file access, downloads, support, withdrawal or complaint.

We do not receive or store the full card number, CVC / CVV code or online banking credentials on our website. Card, Apple Pay, Google Pay and bank payment data is processed in the secure environments of Montonio and the banks or card networks involved in the payment. WooCommerce stores only the order and payment-status information needed to perform the contract, meet accounting requirements and protect the buyer’s rights.

When you use the website

Website hosting and external service providers may receive standard technical data such as your IP address, browser and device information, the time of your visit and the address of the requested page. This is necessary to deliver the website, protect its security or display external content.

Values entered into the Income Calculator are calculated in your browser and are not sent to us through the contact form unless you choose to include them in a message.

Do not enter passwords, online banking credentials, copies of identity documents, health data or other sensitive information that is not necessary for the consultation into a free-text field. If any documents are required, we will agree on an appropriate way to transfer them separately.

Why we use personal data

To respond to an enquiry

So that we can assess your needs, contact you and agree on the next step. The legal basis is taking steps at your request before entering into a contract or performing a contract (Article 6(1)(b) GDPR).

To fulfil a strategy order

So that we can accept the order, confirm payment, provide the selected files, retain evidence of your acknowledgements, and administer access, withdrawal, a refund or a complaint. The legal basis is taking steps before entering into a contract and performing the contract (Article 6(1)(b) GDPR).

To provide the service and manage documents

So that we can fulfil our agreement, manage payment or accounting documents and comply with legal obligations. The legal basis is the contract and applicable legal obligations (Article 6(1)(b) and (c) GDPR).

To protect the website

So that we can detect technical errors, prevent misuse and defend legal claims. The legal basis is our legitimate interest in operating securely (Article 6(1)(f) GDPR).

To provide the website and its functions

So that pages are displayed correctly and their technical functions work. The legal basis is our legitimate interest in maintaining a functioning and consistently presented website (Article 6(1)(f) GDPR). An external map is also displayed on the Contact page.

To understand website use

Only with your consent, we use traffic and interaction analytics to understand which pages are useful, where visitors encounter difficulties and how we can improve the website. The legal basis is your consent (Article 6(1)(a) GDPR).

If we ask for your consent in a particular case, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before the consent was withdrawn.

We do not use contact details submitted through enquiry forms for newsletters or other direct marketing without separate, freely given consent.

We do not carry out automated decision-making or profiling. Enquiries are reviewed by a person, and decisions are not based solely on automated processing.

How long we keep personal data

Enquiry emails and subsequent correspondence that do not lead to the provision of a service are generally kept for no longer than 12 months after the last communication.
WooCommerce order, product-version, payment-status, digital-content delivery, acknowledgement, withdrawal, refund and complaint data is kept for the duration of the contract and afterwards for as long as necessary to demonstrate performance of the contract and legal claims, but no longer than the applicable limitation period unless a longer period is required by law.
Invoices, credit documents and related accounting data are kept for 10 years, or for another period required by the accounting and tax laws applicable at that time.
Payment-provider transaction and payout data, and technical email-delivery logs, are kept only for as long as needed to reconcile a payment, deliver an email, investigate an error, prevent fraud or comply with a legal obligation. Mandatory retention periods applied by individual providers may differ.
Technical website-security data is kept only for as long as needed to operate the website, investigate an incident and protect its security.

If we receive a valid request to erase personal data, the enquiry email and related correspondence will be deleted sooner unless there is a lawful basis for retaining it for longer.

Who may receive personal data

Personal data may be processed, only to the extent necessary, by:

website hosting and IT maintenance providers whose environment runs WordPress and WooCommerce and stores orders;
Montonio, the banks involved in the payment, card networks and payment-instrument providers, to the extent needed to initiate, confirm or refund a payment, manage fraud and comply with legal requirements;
SMTP and email service providers, to deliver order, file-access, invoice and customer-support emails;
PDF invoicing and accounting-solution providers, and persons managing the accounts, to administer invoices, credit documents, taxes and accounting;
legal or other professional advisers when necessary to provide the service or pursue or defend a legal claim;
public authorities where disclosure is required by law.

WooCommerce is the online-store software operating on this website, so order data is initially stored in the website and hosting environment. An external WooCommerce account or cloud service receives data only if a specific related function is explicitly enabled.

We do not sell personal data or disclose it to third parties for their own advertising.

Cookies and external services

CookieYes is used to display, store and allow you to change your cookie choices. This consent-management tool and the technical cookies necessary for the website operate so that your choice can be remembered and the website can function securely.

Essential WooCommerce cookies and browser-storage entries are used to maintain cart contents, the purchase session, checkout security and payment status. They are not used for advertising and operate only to the extent necessary to provide the online-store function you request.

Contact details submitted through the “Portfolio Management” pop-up, like data from other forms, are not stored in the WordPress database and are sent by email. Only the pop-up display status is stored in the browser, and contact details are not sent to analytics services.

Analytics cookies and technologies are enabled only with your consent. Google Analytics 4 helps us view aggregate traffic, page views and actions taken on the website. Microsoft Clarity helps us understand interactions with pages, such as clicks, scrolling and session recordings, in which contact-form and calculator input areas are masked. We deliberately do not send entered contact details or calculator values to analytics services.

We do not currently use marketing or advertising-tracking technologies. If they are introduced in the future, they will not be activated without your separate consent. Analytics data is retained only for as long as configured in the relevant service accounts and necessary for the purpose of improving the website.

Consent is voluntary. You can change or withdraw it at any time by selecting “Cookie Settings” in the website footer. Withdrawal of consent does not affect the lawfulness of processing carried out before it was withdrawn.

A Google Maps map is displayed on the Contact page. When you open that page, Google may receive your IP address, device information and other technical data, and may use cookies in accordance with its privacy rules. If you follow links to Facebook, LinkedIn or Google Maps, your data will then be processed by the provider of the service you selected.

These service providers may process personal data outside the European Economic Area. Where such a transfer is made by a service provider selected by us, it is based on an applicable European Commission adequacy decision or approved standard contractual clauses.

Your rights

Depending on the circumstances and the conditions set by the GDPR, you have the right to:

receive information about the processing of your personal data and access it;
have inaccurate data corrected or incomplete data completed;
request erasure of your personal data or restriction of its processing;
object to processing based on a legitimate interest;
receive the data you provided in a structured format where the right to data portability applies;
withdraw consent at any time where processing is based on consent;
lodge a complaint with the Lithuanian State Data Protection Inspectorate.

How can you submit a request?

Email juska.martynas@gmail.com. To protect your personal data, we may ask you to verify your identity. We will respond without undue delay and normally within one month.

Changes to this policy

We may update this policy when the website, the services we use or legal requirements change. The latest version will always be published on this page, with the date of the update shown at the top.