Introduction
This Privacy Policy describes how we collect, use and protect your personal data when you visit our website, in compliance with Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR") and Organic Law 3/2018, of 5 December ("LOPDGDD").
Joint controllers
Your data is controlled by the two self-employed professionals who operate under the trade name Klave Digital. They jointly determine the purposes and means of the processing and are therefore joint controllers under Article 26 GDPR:
- Tommaso Ruzzi — Tax ID (NIF): Z5570951B · Address: Avenida del Acueducto 20, 2.º D, 40001 Segovia
- Francesco Maza — Tax ID (NIF): Z4437110R · Address: Plaza Colmenares 7, 2.º, 40001 Segovia
- Single point of contact: admin@klavedigital.es
Essence of the joint-controller arrangement (Art. 26(2) GDPR): both controllers share the same purposes and the same providers described in this policy; admin@klavedigital.es is the single point of contact for any question or request to exercise your rights, and whoever receives it handles it on behalf of both; each controller applies the security measures described below to the data they access. Irrespective of that arrangement, you may exercise your rights against either of them (Art. 26(3) GDPR).
What personal data we collect
Through the website forms we collect the data you voluntarily provide: your name, email address, phone number and what your business does and, optionally, your company name, the service you are interested in and any message you send us. Together with your request we record the date and time of your consent, the language and form used, a salted hash of your IP address — never the raw IP — and your browser identifier (user agent), for security and abuse-prevention purposes.
While you browse the site, our hosting and video providers receive your IP address and technical browser data, which they need to serve you the pages and the home-page video. Audience measurement (Vercel Web Analytics and Speed Insights) works without cookies and on aggregated data.
Purposes and legal basis for processing
We process your personal data for the following purposes, in accordance with Article 6 of the GDPR:
- To respond to your inquiries, handle your free audit or consultation request and communicate with you. Legal basis: your consent (Art. 6(1)(a) GDPR), provided when you voluntarily submit your information.
- To send you the information or materials you requested. Legal basis: your consent (Art. 6(1)(a) GDPR).
- To ensure the security of the site, prevent abuse and serve the site's pages and videos. Legal basis: legitimate interest of the joint controllers (Art. 6(1)(f) GDPR).
Recipients and international transfers
We do not sell, rent or trade your personal data to third parties. Only the following providers access it, acting as data processors under an agreement compliant with Article 28 GDPR:
- Vercel Inc. (USA) — website hosting and cookieless, aggregated audience measurement. Transfer based on the EU-US Data Privacy Framework.
- Supabase Inc. — database where requests are stored, hosted in the European Union (Germany). Any access from outside the European Economic Area relies on the European Commission's Standard Contractual Clauses.
- Resend (USA) — sending the confirmation and notification emails for each request. Transfer based on the EU-US Data Privacy Framework.
- Mux, Inc. (USA) — delivery of the home-page video; receives your IP address and technical browser data. Transfer based on the EU-US Data Privacy Framework.
- Microsoft (Microsoft 365) — the admin@klavedigital.es mailbox, where we receive and answer requests. Transfer based on the EU-US Data Privacy Framework.
Data retention
We keep the data of your request for 12 months from the last contact if you do not go on to hire our services. If you hire us, we keep it for the duration of the relationship and then for the periods required by law (tax and commercial obligations). After those periods it is deleted or anonymized, and may be blocked during the period in which liabilities may arise, in accordance with Article 32 of the LOPDGDD.
Data security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure or destruction, including encryption in transit (HTTPS/TLS), tiered access control and Row Level Security on the database. However, no method of transmission over the Internet is completely secure, and we cannot guarantee absolute security.
Your rights
In accordance with Articles 15 to 22 of the GDPR and Title III of the LOPDGDD, you have the rights of access, rectification, erasure, restriction of processing, portability, objection, and withdrawal of consent. To exercise them, send a written request to admin@klavedigital.es or to the address of either joint controller given above, with a copy of your national identity document (DNI) or equivalent; you may address either of them and the request will be handled on behalf of both. We have not appointed a data protection officer, as it is not mandatory in our case (Art. 37 GDPR and Art. 34 LOPDGDD). You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.
Processing of minors' data
In accordance with Article 7 of the LOPDGDD, processing personal data of minors under 14 requires the consent of a parent or legal guardian. This website is not directed to individuals under 14. If we become aware that we have collected such data without consent, we will delete it promptly.
Changes to this Privacy Policy
We reserve the right to update or modify this Privacy Policy at any time. Changes are effective upon posting on the website. We encourage you to review it periodically.
Contact
If you have any questions about this Privacy Policy, please contact us at admin@klavedigital.es.