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 Hendrik van der Waal
Activity: Independent Google Ads & Digital Marketing Consultant (Autónomo)
Tax Identification (NIF/NIE): Z2182402Y
Location: Barcelona, Spain
Contact Email: elbertvdwaal@gmail.com
Website: www.elbertvanderwaal.com
Personal Data Collected & Purpose
Contact, Bookings & Inquiries:
Data collected: Name, email address, company name, website URL, and notes you submit via contact or booking forms.
Purpose: Responding to inquiries, scheduling intro calls and audits, and preparing service proposals.
Plan Finder:
Data collected: Your answers to the plan finder questions (for example your monthly ad budget and goals). Answers are only stored if you continue to a booking, in which case they are shared with that booking.
Purpose: Recommending a suitable plan and preparing for your call.
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, Advertising & Security:
Data collected: Anonymized IP addresses, browser types, referral sources, interaction data, and ad click identifiers.
Purpose: Maintaining site performance, preventing security threats, aggregate traffic analysis, and measuring which ads lead to enquiries or bookings.
Legal Basis for Processing
Steps before a contract and performance of a contract (Art. 6.1.b GDPR): Answering your inquiry, booking calls, using your plan finder answers, preparing proposals, onboarding, and delivering consulting services.
Consent (Art. 6.1.a GDPR): Optional analytics and advertising cookies, only when you accept them in the cookie banner.
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, security, and platform integrity.
Required Information
Fields marked as required in contact and booking forms (such as your name and email address) are needed to reply to you or confirm your booking. Without them, I cannot respond to your request. All other fields are optional.
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 & Advertising Data: See the Cookie Policy for how long each cookie is kept; analytics data is retained for 14 months.
Third-Party Data Processors
Your data is never sold or rented. Service providers accessing data operate under Data Processing Agreements:
Hosting & Platform: Framer B.V. (Netherlands)
Analytics, Advertising & Tag Management: Google Ireland Ltd. (Google Analytics, Google Ads, Google Tag Manager)
Cookie Consent: CookieYes Limited
Email: Google Ireland Ltd. (Gmail)
Scheduling & Booking: Cal.com, Inc. (United States)
Billing data is also shared with the Spanish Tax Agency (Agencia Tributaria) where Spanish tax law requires it.
International Data Transfers
Google and Cal.com may process personal data in the United States. These transfers are covered by the EU–US Data Privacy Framework, under which both companies are certified, and where applicable by the European Commission's Standard Contractual Clauses.
Automated Decision-Making
No decisions about you are made solely by automated means, and no profiling with legal or similarly significant effects takes place. The plan finder only gives a suggestion; the final plan is always agreed with you in person.
Your Rights
Under EU data protection laws, you have the right to request access, rectification, erasure, restriction of processing, data portability, and objection. Where processing is based on your consent, you can withdraw that consent at any time, for example by changing your cookie settings. Withdrawing consent does not affect processing that took place before.
To exercise these rights, email elbertvdwaal@gmail.com with the subject line "Data Rights Request". You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.