Privacy Policy
1. Data controller
- Data controller: Dani Stroe (“Reforma Pura Vida”)
- NIF (Tax ID): [NIF pending completion]
- Registered address: Madrid, Spain
- Contact: dani@reformaspuravida.es · +34 603 32 91 73
A Data Protection Officer is not required, as this activity does not fall within the cases set out in Article 34 of Organic Law 3/2018 (LOPDGDD).
2. Purpose and legal basis for processing
| Purpose | Legal basis |
|---|---|
| Handling quote requests or enquiries received via WhatsApp or the contact form | Performance of pre-contractual measures at the data subject’s request (Art. 6.1.b GDPR) |
| Responding to general enquiries about our services | Consent of the data subject when initiating contact (Art. 6.1.a GDPR) |
| Compiling anonymous/aggregated statistics on visits to the Site (pages viewed, approximate country, language) | Legitimate interest of the controller in understanding use of the Site (Art. 6.1.f GDPR), while minimising the data processed |
No automated decisions are made and no profiling is carried out based on the data processed.
3. Data processed
Depending on the contact channel used: name, telephone number and/or email address that the user voluntarily provides when writing via WhatsApp or the contact form. In addition, when browsing the Site, the following is automatically recorded: page visited, language, referral source and an approximate location (country/city) obtained from the IP address — the IP address itself is not stored in plain text, only a derived result (see the “Cookie Policy” for further detail on the visitor identifier).
Providing this data is voluntary, but necessary if the user wishes to receive a response to their enquiry.
4. Retention period
Contact data is retained for the duration of the business relationship and, thereafter, for the applicable legal limitation periods (tax and civil liability). Visit statistics data is retained for a maximum of 14 months.
5. Recipients and data processors
Data is not disclosed to third parties except where legally required. The following data processors are used, bound by contract in accordance with Article 28 GDPR:
- Site hosting provider.
- Provider of the email service used to manage enquiries.
If the user contacts via WhatsApp, that conversation is handled directly by WhatsApp Ireland Limited (Meta) under its own privacy policy; the owner does not forward or share that data with any additional third parties.
6. Rights of the data subject
The user may exercise the following rights at any time, free of charge, by writing to dani@reformaspuravida.es, attaching a copy of a document proving their identity:
- Right of access to their personal data
- Right to rectification of inaccurate data
- Right to erasure (“right to be forgotten”)
- Right to object to processing
- Right to restriction of processing
- Right to data portability
- Right to withdraw consent given at any time, without affecting the lawfulness of processing carried out prior to its withdrawal
Likewise, the user has the right to lodge a complaint with the Agencia Española de Protección de Datos (AEPD — Spanish Data Protection Agency) (www.aepd.es) if they believe their rights have been infringed.
7. Security
The Site is served over an encrypted connection (HTTPS) and reasonable technical and organisational measures are applied to protect data against unauthorised access, loss or alteration.
8. Changes to the privacy policy
This policy may be updated to reflect legislative changes or changes to the Site. Users are advised to review this page periodically.