Privacy Policy

Privacy Policy

Privacy Policy

Last updated: August 2026

This Privacy Policy describes how your personal data is collected, used, and protected in accordance with Regulation (EU) 2016/679 (GDPR / RGPD) and Spanish Organic Law 3/2018 (LOPDGDD).

Data Controller

  • Name: Elbert van der Waal

  • Activity: Independent Google Ads & Digital Marketing Consultant (Autónomo)

  • Tax Identification (NIF/NIE): [Your NIF/NIE]

  • Location: Barcelona, Spain

  • Contact Email: [hello@yourdomain.com]

  • Website: [https://yourdomain.com]

Personal Data Collected & Purpose

  • Contact & Inquiries:

    • Data collected: Name, email address, company name, website URL, and project notes submitted via contact forms.

    • Purpose: Responding to inquiries, scheduling intro calls, and preparing service proposals.

  • Client Engagements & Billing:

    • Data collected: Legal billing name, tax ID, business address, and transaction records.

    • Purpose: Executing consulting agreements, managing account access, and issuing legal invoices.

  • Website Analytics & Security:

    • Data collected: Anonymized IP addresses, browser types, referral sources, and interaction data.

    • Purpose: Maintaining site performance, preventing security threats, and aggregate traffic analysis.

Legal Basis for Processing

  • Consent (Art. 6.1.a GDPR): When you submit a contact form or accept optional cookies.

  • Contractual Measures (Art. 6.1.b GDPR): For discussing project scope, onboarding, and fulfilling consulting services.

  • Legal Obligation (Art. 6.1.c GDPR): Maintaining fiscal and accounting records under Spanish tax law.

  • Legitimate Interest (Art. 6.1.f GDPR): Ensuring website uptime, platform integrity, and basic usage analytics.

Data Retention

  • Inquiries without Contract: Retained for up to 12 months after the last communication.

  • Client & Tax Records: Retained for a minimum of 4 to 6 years in accordance with Spanish commercial and tax laws.

  • Analytics Data: Retained for 14 months under standard analytics retention settings.

Third-Party Data Processors Your data is never sold or rented. Service providers accessing data operate under strict Data Processing Agreements:

  • Hosting & Platform: Framer B.V.

  • Analytics & Tag Management: Google Ireland Ltd.

  • Email & Workspace: Google Workspace

  • Tax & Compliance: Appointed Spanish accounting professionals (gestoría) and the Spanish Tax Agency (Agencia Tributaria).

Your Rights Under EU data protection laws, you have the right to request access, rectification, erasure, restriction of processing, data portability, and objection.

To exercise these rights, email [hello@yourdomain.com] with the subject line "Data Rights Request" along with proof of identity. You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.