[{"data":1,"prerenderedAt":389},["ShallowReactive",2],{"privacy-en":3},{"id":4,"title":5,"body":6,"description":381,"extension":382,"meta":383,"navigation":384,"path":385,"seo":386,"stem":387,"__hash__":388},"pages_en\u002Fprivacy.md","Privacy Policy",{"type":7,"value":8,"toc":362},"minimark",[9,17,22,25,58,61,65,68,73,76,108,112,120,143,147,150,162,166,177,222,225,229,232,260,263,267,270,274,277,321,327,334,338,341,345,348,352,355,359],[10,11,12,16],"p",{},[13,14,15],"strong",{},"Last updated:"," 13 May 2026",[18,19,21],"h2",{"id":20},"_1-data-controller","1. Data Controller",[10,23,24],{},"In accordance with Regulation (EU) 2016\u002F679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the \"GDPR\"), and with Spanish Organic Law 3\u002F2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights (\"LOPDGDD\"), the User is informed that the Data Controller of the personal data collected through this Website is:",[26,27,28,35,41,47],"ul",{},[29,30,31,34],"li",{},[13,32,33],{},"Data Controller:"," Patricio Rivera",[29,36,37,40],{},[13,38,39],{},"Spanish Foreign Resident ID (NIE):"," Y3643511A",[29,42,43,46],{},[13,44,45],{},"Registered address:"," c\u002F Emilia Coranty 16, 08018 Barcelona, Spain",[29,48,49,52,53],{},[13,50,51],{},"Email:"," ",[54,55,57],"a",{"href":56},"mailto:patricio@patriciorivera.com","patricio@patriciorivera.com",[10,59,60],{},"No Data Protection Officer (DPO) has been appointed, as the conditions set out in Article 37 of the GDPR and Article 34 of the LOPDGDD are not met.",[18,62,64],{"id":63},"_2-personal-data-processed-purposes-and-legal-basis","2. Personal data processed, purposes and legal basis",[10,66,67],{},"The Website has no data collection forms. The only processing operations on personal data that may take place are those described below.",[69,70,72],"h3",{"id":71},"_21-communications-by-email","2.1. Communications by email",[10,74,75],{},"Where the User voluntarily contacts the Owner by sending an email to the address published on the Website, the following data is collected:",[26,77,78,84,90,96,102],{},[29,79,80,83],{},[13,81,82],{},"Identification data:"," name and email address of the sender.",[29,85,86,89],{},[13,87,88],{},"Content of the communication:"," the information that the User decides to include in his or her message.",[29,91,92,95],{},[13,93,94],{},"Purpose:"," to attend to the query, request or communication received, and to maintain the necessary correspondence with the User.",[29,97,98,101],{},[13,99,100],{},"Legal basis:"," performance of pre-contractual measures at the request of the data subject (Art. 6.1.b GDPR) where the query relates to the provision of professional services. In other cases, the legitimate interest of the Controller in managing the communications received (Art. 6.1.f GDPR).",[29,103,104,107],{},[13,105,106],{},"Retention period:"," the data will be kept for the time needed to attend to the query and, thereafter, for the periods legally required to deal with any potential liabilities arising from the processing, with a maximum of three (3) years from the last interaction, unless the communication results in a contractual relationship, in which case the corresponding retention policy will apply.",[69,109,111],{"id":110},"_22-meeting-bookings-through-calcom","2.2. Meeting bookings through Cal.com",[10,113,114,115,119],{},"The ",[116,117,118],"code",{},"\u002Fbook"," page of the Website integrates the Cal.com tool, which allows the User to book a video meeting (Google Meet) with the Owner. The data processed through this functionality is collected and processed directly by Cal.com acting as a data processor.",[26,121,122,128,133,138],{},[29,123,124,127],{},[13,125,126],{},"Data collected:"," name, email address, date and time selected, and any additional information that the User decides to provide in the booking form fields.",[29,129,130,132],{},[13,131,94],{}," to manage the meeting request, generate the corresponding calendar event and send the associated notifications (confirmation, reminder, cancellation).",[29,134,135,137],{},[13,136,100],{}," performance of pre-contractual measures at the request of the data subject (Art. 6.1.b GDPR) and the User's consent given by completing and submitting the booking form (Art. 6.1.a GDPR).",[29,139,140,142],{},[13,141,106],{}," the data will be kept for as long as the relationship arising from the booking is maintained and, thereafter, for the periods legally required, with a maximum of three (3) years from the last interaction.",[69,144,146],{"id":145},"_23-technical-browsing-data","2.3. Technical browsing data",[10,148,149],{},"By the mere fact of accessing the Website, the hosting server automatically records certain technical data — IP address, date and time of access, user agent, requested URL and response code — for the sole purpose of ensuring the security, technical functioning and operational traceability of the Website. This data is not used to identify the User, is not cross-referenced with any other information, and is not transferred to third parties for commercial purposes.",[26,151,152,157],{},[29,153,154,156],{},[13,155,100],{}," legitimate interest of the Controller in ensuring the security and functioning of the Website (Art. 6.1.f GDPR).",[29,158,159,161],{},[13,160,106],{}," the server logs are kept for a maximum of ninety (90) days, unless their additional retention is necessary for security or legal compliance reasons.",[69,163,165],{"id":164},"_24-website-usage-analytics-umami","2.4. Website usage analytics (Umami)",[10,167,168,169,172,173,176],{},"In order to understand on an aggregate basis how the Website is used and to improve its content and operation, the Owner uses the analytics tool ",[13,170,171],{},"Umami",", provided by ",[13,174,175],{},"Umami Software, Inc."," in its cloud version, acting as a data processor in accordance with Article 28 of the GDPR.",[26,178,179,185,195,201,207,212,217],{},[29,180,181,184],{},[13,182,183],{},"Data processed:"," aggregate information about Website usage (URL visited, referring URL, device type, browser, operating system, country derived from the IP address, date and time of access).",[29,186,187,190,191,194],{},[13,188,189],{},"Processing of the IP address:"," Umami ",[13,192,193],{},"does not store the User's IP address",". The IP is used only transiently to derive the country and to generate a daily, anonymous and non-reversible identifier (hash with rotating salt), which is deleted every twenty-four hours and does not allow tracking across days.",[29,196,197,200],{},[13,198,199],{},"No cookies"," or persistent identifiers are placed on the User's device for this purpose.",[29,202,203,206],{},[13,204,205],{},"No profiles"," are built of the User and no cross-site or cross-session tracking takes place.",[29,208,209,211],{},[13,210,94],{}," to obtain aggregate, anonymous metrics for the statistical analysis of Website usage and the improvement of its content.",[29,213,214,216],{},[13,215,100],{}," legitimate interest of the Controller in analysing Website usage on an aggregate basis (Art. 6.1.f GDPR), a low-impact processing activity given its anonymous and aggregate nature.",[29,218,219,221],{},[13,220,106],{}," aggregate data is kept for a maximum of twenty-four (24) months, after which it is deleted or irreversibly anonymised.",[10,223,224],{},"International transfers that may take place to Umami Software, Inc. (an entity domiciled in the United States) are governed by the Standard Contractual Clauses approved by the European Commission, in accordance with Article 46.2 of the GDPR.",[18,226,228],{"id":227},"_3-recipients-and-data-processors","3. Recipients and data processors",[10,230,231],{},"The Controller does not transfer personal data to third parties except where required by law. For the operation of the Website and the management of communications, the following providers are engaged, acting as data processors under Article 28 of the GDPR:",[26,233,234,240,246,255],{},[29,235,236,239],{},[13,237,238],{},"DigitalOcean, LLC"," — hosting provider for the Website. The Website infrastructure is hosted in its data centres located in the European Union (Amsterdam or Frankfurt). DigitalOcean has a GDPR-compliant Data Processing Agreement (DPA) in place and applies the Standard Contractual Clauses approved by the European Commission for any international transfers that may occur.",[29,241,242,245],{},[13,243,244],{},"Google Ireland Limited"," (Google Workspace) — provider of the Owner's email service. The account is subject to Google's DPA and to the Standard Contractual Clauses for any international transfer. Google Meet is also used for the meetings booked through Cal.com.",[29,247,248,251,252,254],{},[13,249,250],{},"Cal.com, Inc."," — provider of the meeting booking service available at ",[116,253,118],{},". Acts as a data processor under its DPA. International transfers are covered by the Standard Contractual Clauses approved by the European Commission.",[29,256,257,259],{},[13,258,175],{}," — provider of the Website analytics service (Umami Cloud). Acts as a data processor under its DPA. International transfers are covered by the Standard Contractual Clauses approved by the European Commission.",[10,261,262],{},"The Controller has verified that these providers offer sufficient guarantees to implement appropriate technical and organisational measures so that the processing complies with the requirements of the GDPR and protects the rights of the data subject.",[18,264,266],{"id":265},"_4-international-transfers-of-data","4. International transfers of data",[10,268,269],{},"Some of the data processors mentioned above have their parent company outside the European Economic Area. Where international transfers take place, they are carried out on the basis of the Standard Contractual Clauses approved by the European Commission or, where applicable, any other appropriate safeguard mechanism provided for in Chapter V of the GDPR.",[18,271,273],{"id":272},"_5-rights-of-the-data-subject","5. Rights of the data subject",[10,275,276],{},"The User may exercise the following rights at any time and free of charge:",[26,278,279,285,291,297,303,309,315],{},[29,280,281,284],{},[13,282,283],{},"Access:"," to know what personal data is being processed.",[29,286,287,290],{},[13,288,289],{},"Rectification:"," to request the correction of inaccurate or incomplete data.",[29,292,293,296],{},[13,294,295],{},"Erasure:"," to request the deletion of the data when it is no longer necessary or there is no legal basis for its processing.",[29,298,299,302],{},[13,300,301],{},"Objection:"," to object to the processing on grounds relating to his or her particular situation.",[29,304,305,308],{},[13,306,307],{},"Restriction of processing:"," to request that processing be restricted in the cases provided for by the regulations.",[29,310,311,314],{},[13,312,313],{},"Portability:"," to receive the data in a structured, commonly used and machine-readable format and, where technically feasible, to transmit it to another controller.",[29,316,317,320],{},[13,318,319],{},"Withdrawal of consent:"," to withdraw consent given, without prejudice to the lawfulness of any processing carried out on the basis of consent prior to its withdrawal.",[10,322,323,324,326],{},"To exercise these rights, the User may contact the Controller by email at ",[116,325,57],{},", indicating in the subject line the right he or she wishes to exercise and providing, where necessary, a document evidencing his or her identity.",[10,328,329,330,333],{},"The User also has the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, \"AEPD\"), based at c\u002F Jorge Juan 6, 28001 Madrid, and at ",[116,331,332],{},"www.aepd.es",", if he or she considers that the processing of his or her personal data infringes the applicable law.",[18,335,337],{"id":336},"_6-security-measures","6. Security measures",[10,339,340],{},"The Controller has adopted the appropriate technical and organisational measures to ensure a level of security appropriate to the risk of the processing, in accordance with Article 32 of the GDPR. These measures include, among others, the encryption of communications by means of HTTPS\u002FTLS, access control, the regular updating of systems, and the selection of providers with regulatory compliance guarantees.",[18,342,344],{"id":343},"_7-automated-decisions-and-profiling","7. Automated decisions and profiling",[10,346,347],{},"The Controller does not make automated decisions that produce legal effects on the User or significantly affect him or her, nor does it carry out profiling based on the data processed.",[18,349,351],{"id":350},"_8-minors","8. Minors",[10,353,354],{},"The Website is aimed at professionals and businesses. Personal data of children under the age of fourteen (14) is not deliberately requested or processed. Should the Controller become aware of the processing of data of minors without appropriate consent, such data will be deleted immediately.",[18,356,358],{"id":357},"_9-changes-to-the-privacy-policy","9. Changes to the Privacy Policy",[10,360,361],{},"The Controller may amend this Privacy Policy to adapt it to legislative or case-law developments or to changes in professional practice. In such cases, the updated version will be published on the Website and will indicate the date of its last revision.",{"title":363,"searchDepth":364,"depth":364,"links":365},"",2,[366,367,374,375,376,377,378,379,380],{"id":20,"depth":364,"text":21},{"id":63,"depth":364,"text":64,"children":368},[369,371,372,373],{"id":71,"depth":370,"text":72},3,{"id":110,"depth":370,"text":111},{"id":145,"depth":370,"text":146},{"id":164,"depth":370,"text":165},{"id":227,"depth":364,"text":228},{"id":265,"depth":364,"text":266},{"id":272,"depth":364,"text":273},{"id":336,"depth":364,"text":337},{"id":343,"depth":364,"text":344},{"id":350,"depth":364,"text":351},{"id":357,"depth":364,"text":358},"Privacy policy for patriciorivera.com under GDPR and LOPDGDD. Data controller, processing purposes, legal basis, and your rights.","md",{},true,"\u002Fprivacy",{"title":5,"description":381},"privacy","SWP79XzQr-6apl0jL-cuva0in0v6SOxMvSeq61iY3rU",1781128068927]