Last updated 11 November 2026
Privacy and legal notice
Who publishes this website, what it does with the details you enter, how long we keep them, and what you can ask us.
Legal notice
This website is published by:
Gleb Gorbachev, sole trader, trading as Distribution Drift
Rua Eugénia Brandão de Melo 205
9125-060 Caniço
Madeira, Portugal
NIF: 285017950
Email: [email protected]
Distribution Drift provides audit and consultancy services to hotels. It is independent. It is not affiliated with, endorsed by or a partner of Booking.com or any other booking channel, channel manager or booking engine named on this site. Booking.com is a trade mark of its owner and is named here only to describe the channel we compare.
Informação legal
Este sítio é publicado por:
Gleb Gorbachev, empresário em nome individual, que usa a designação comercial Distribution Drift
Rua Eugénia Brandão de Melo 205
9125-060 Caniço
Madeira, Portugal
NIF: 285017950
Correio eletrónico: [email protected]
In short
- You can read this whole site without giving us anything. It sets no cookies and loads no code from advertising or tracking companies.
- If you use one of our forms, we receive what you enter when you press a button. The hotel name or link you type is also saved before that, so an interested hotel is not lost if a page fails.
- We use it to reply to you and to follow up about your hotel. We do not sell it and we do not pass it to advertisers.
- You can ask us to delete it, or tell us to stop contacting you, at any time: [email protected].
Who is responsible for your data
Distribution Drift is the trading name of Gleb Gorbachev, a sole trader established in Madeira, Portugal. He decides how and why the personal data described here is used (the “controller” under the General Data Protection Regulation, the GDPR).
Our name, address and tax number are in the legal notice above. For anything about your data, write to [email protected].
We have not appointed a data protection officer. The law does not require one for a business of our kind and size.
What we collect, why, and on what legal ground
When you visit any page
Our hosting company, Vercel, receives the technical data every browser sends with a request: your IP address, your browser and device type, and the page you asked for. It uses this to deliver the page and keeps it in server logs for a short period set by Vercel’s service. Cloudflare, which protects and routes traffic to the site, handles the same data on its way. Legal ground: our legitimate interest in running a website that works and is secure (Article 6(1)(f) GDPR).
Protection against abuse
When you use a form, our server holds your IP address in memory for up to 10 minutes to limit how many times one address can submit. It is not written to our database. Legal ground: the same legitimate interest.
Visit counts
We don’t use analytics on this site.
Requests you send
The request card on the home page and the “How it works” page asks for your hotel’s name or a link to it, then your email address. The contact form asks for your hotel’s name, a link, your email address and, if you wish, the number of properties, the topics that interest you and a message. When you press the button we save these details and receive them by email. We use them to take the first look you asked for and to reply to you.
Legal ground: steps taken at your request before a possible contract (Article 6(1)(b)) when you act for your own business. Otherwise it is our legitimate interest in answering a request made on behalf of your employer (Article 6(1)(f)).
The hotel you type
Our forms save the hotel name or link a few seconds after you type it, before you press a button and also if you never send the form. We keep only the latest text, and we receive an email with it. Your email address, your message and every other detail are saved only when you press the button.
We use the hotel name to see which hotels showed interest, and we may contact that hotel through its public address. Legal ground, where a hotel’s name relates to an identifiable person: our legitimate interest in responding to hotels that show interest (Article 6(1)(f)). You can object at any time: see Your right to object.
On your device
The forms keep two things in your browser’s storage, not in cookies:
- In session storage: a random code that joins the saves of one visit into one record, and, on the contact page, the text you have typed, so a reload does not lose it. Both stay until you send the form or close the tab.
- In local storage: if a save fails because your connection dropped, a copy of that entry, so the page can send it when you next open the site. It stays until it is sent, and for 7 days at most.
We store nothing else on your device.
If you write to us, we use your address and message to reply.
Booking a call
The “Book a call” button opens a page run by Calendly. This site loads nothing from Calendly until you follow that link. What you enter there (your name, email address and the notes you add) reaches us through Calendly. Calendly’s own privacy notice also applies on its page. Legal ground: steps at your request before a possible contract, or our legitimate interest in arranging a call you asked for.
What we do not do
We do not sell personal data. We do not pass it to advertisers. We make no decisions about you by automated means, and we build no profile of you.
Do you have to give us this?
No. Nothing on this site requires you to give personal data, by law or by contract. If you send a request without an email address that works, we cannot reply.
Who else handles it
These companies process the data for us, under contracts that bind them to our instructions:
- Vercel Inc. (United States): hosts the site and runs the code behind our forms.
- Supabase: stores what is entered in our forms, in a data centre in Ireland.
- Resend (United States): delivers to us the emails about form entries.
- Microsoft: provides our mailbox.
- Calendly LLC (United States): runs the call-booking page.
- Cloudflare, Inc. (United States): protects and routes traffic to the site.
We share personal data with no one else, unless a law obliges us.
Transfers outside the European Economic Area
Some of these companies process data in the United States or other countries outside the EEA. The safeguards are:
- Vercel, Resend and Calendly: the European Commission’s adequacy decision for the EU–U.S. Data Privacy Framework, under which each states it is certified, and the Commission’s standard contractual clauses in our contract with each.
- Supabase: the Commission’s standard contractual clauses. The form entries themselves are stored in Ireland.
- Microsoft and Cloudflare: the Commission’s standard contractual clauses and, where the company is certified, the EU–U.S. Data Privacy Framework.
You can ask us for a copy of these safeguards at [email protected].
Your right to object
You can object at any time to our use of your data on the ground of legitimate interest. If we contact you to offer our services and you tell us to stop, we stop, and we delete what you entered. No reason is needed. Write to [email protected].
How long we keep it
- Details typed into a form and not sent: 30 days from the last change, then deleted.
- Requests you sent, and our email exchange with you, when no engagement follows: 12 months after our last contact, then deleted.
- If you become a client: for the length of our work together, and afterwards for the period that Portuguese tax and accounting law requires for business records.
- The emails we receive about form entries follow the same periods.
- Server logs at Vercel: for a short period set by Vercel’s service.
- Copies in routine backups are overwritten within the backup period of our database plan.
Your other rights
You can ask us for a copy of your personal data, and to correct it, delete it, limit how we use it, or hand it to you in a portable form. Write to [email protected]. We answer within one month.
You can also complain to the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (CNPD), at cnpd.pt, or to the authority of the EU country where you live or work.
The examples on this site
The example hotels, dates, prices and policies shown on this site are illustrative. None is a live observation or a client’s result. The one real hotel named is Hotel Madeira, on the Home and “About us” pages: the facts given there describe the founder’s own past work at that hotel.
Changes to this notice
When what the site does changes, we update this page and the date at the top.