1. Data controller
- Controller: Giorgi Mamasakhlisi
- Tax ID (NIF / CIF): Y3607901C
- Registered address: Av. País Valencia, 44, 46139 Valencia, España
- Contact email: [email protected]
We do not have a Data Protection Officer because, given the type and volume of processing, one is not mandatory under article 37 of the GDPR. For anything related to your data, write to the address above.
2. Where your data comes from
We only process data that reaches us in two ways:
- When you write to us. By email or WhatsApp, to ask for information or a quote. You provide that data voluntarily in your message.
- When you browse, if you allow it. Technical and usage data collected by the analytics tool, only if you have accepted analytics cookies.
This website has no forms, creates no user accounts, sells nothing online and collects no special category data (health, political opinions, religion, etc.).
3. What data, what for and on what legal basis
| Data | Purpose | Legal basis (GDPR) | Retention |
|---|---|---|---|
| Name, email, phone and whatever you tell us in your message | Replying to you, preparing a quote and following up on the proposal | Art. 6.1.b: pre-contractual measures at the data subject's request | For the duration of the conversation and up to 1 year afterwards if nothing is contracted |
| Identification and billing data | Performing the contract and meeting tax and accounting obligations | Art. 6.1.b (contract) and 6.1.c (legal obligation) | 6 years from the last invoice (Spanish Commercial Code and General Tax Law) |
| Anonymised IP address, pages viewed, device and browser | Understanding which content works and improving the site | Art. 6.1.a: your consent, withdrawable at any time | 14 months in Google Analytics |
| Server logs and security data | Keeping the site available and protecting it against attacks | Art. 6.1.f: legitimate interest in the security of the service | As per the provider's policy, usually days or weeks |
We make no automated decisions and build no profiles with legal effects on you.
4. Who else can see your data
We neither sell nor transfer your data to anyone. Only the providers we need in order to deliver the service have access to it, all of them under a signed data processing agreement (article 28 of the GDPR):
- Web hosting: Provider de Hosting, with servers in the European Union.
- Content delivery and security: Cloudflare, Inc. Routes and protects the site's traffic.
- Web analytics: Google Ireland Limited (Google Analytics 4), only if you accept analytics cookies.
- Email: the provider hosting the mailbox we reply to you from.
In addition, we may disclose data to the Spanish tax authorities, to banks and to the courts where there is a legal obligation to do so.
5. Transfers outside the European Union
Some of these providers are based in the United States and may process data outside the European Economic Area. In those cases the transfer relies on the EU–US Data Privacy Framework (European Commission adequacy decision of 10 July 2023) and, secondarily, on the Standard Contractual Clauses approved by the Commission.
If you reject analytics cookies, none of your data is transferred to Google.
6. Your rights
You may exercise the following rights at any time:
- Access: find out which of your data we hold.
- Rectification: correct anything that is wrong.
- Erasure: ask us to delete data once it is no longer necessary.
- Objection: object to processing based on legitimate interest.
- Restriction: ask us to keep the data but not use it.
- Portability: receive it in a structured, commonly used format.
- Withdraw consent at any time, without affecting processing carried out beforehand.
To exercise them, write to [email protected] stating which right you wish to exercise and attaching a copy of your ID document so that we can verify your identity. We will reply within a maximum of one month.
If you believe we have not handled your request properly, you may complain to the Spanish Data Protection Agency: www.aepd.es, C/ Jorge Juan 6, 28001 Madrid.
7. Security
We apply reasonable technical and organisational measures to protect your data: encrypted connection (HTTPS) across the whole site, restricted access to information, regular backups and system updates. No system is infallible, but we take this seriously: it is part of our job.
8. Minors
This site is aimed at companies and professionals. We do not knowingly collect data from anyone under 14. If we find that we have received a minor's data without authorisation from their legal guardians, we will delete it.
9. Changes to this policy
We may update this policy if the services, the providers or the law change. We will always publish the date of the last revision at the top of the page.