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Privacy Policy
Effective Date: December 2025
This Privacy Policy describes how Santa Vinklere (the “Data Controller,” “we,” “us,” or “our”) collects, uses, stores, and protects Personal Data obtained through https://santavinklere.com (the “Website”), in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”) and applicable Spanish data protection laws. By accessing or using the Website, you acknowledge that you have read, understood, and agreed to this Privacy Policy. If you do not agree, you must immediately cease use of the Website.
Article 1 – DEFINITIONS
For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:
1. APPLICABLE WEBSITE: This Privacy Policy applies to https://santavinklere.com, including any related subdomains and, where applicable, future mobile applications or digital platforms operated by the Data Controller (collectively, the “Website”).
2. EFFECTIVE DATE: The date on which this Privacy Policy enters into force, as stated above.
3. DATA CONTROLLER: The natural person responsible for determining the purposes and means of processing Personal Data:
- Legal Name: Santa Vinklere
- Business Address: C/ d’EnBot 11, 08002, Barcelona, Spain
- Email: [email protected]
- VAT: ESY1875688Y
4. YOU / USER: Any natural person who accesses, browses, or uses the Website.
5. SERVICES: Any professional services made available through the Website.
6. PERSONAL DATA: Any information relating to an identified or identifiable natural person, as defined under Article 4 of the GDPR.
Article 2 – GENERAL INFORMATION
This Privacy Policy explains:
- What Personal Data is collected
- How and why it is processed
- The legal bases for processing
- How long data is retained
- The rights available to users under GDPR
This Privacy Policy applies only to data collected through the Website. It does not apply to third-party websites or services linked from the Website. We are not responsible for the privacy practices of such third parties.
We are committed to protecting your privacy and processing Personal Data lawfully, fairly, and transparently.
Article 3 – LOCATION OF DATA PROCESSING AND INTERNATIONAL TRANSFERS
Data processing activities primarily take place within the European Economic Area (EEA).
However, certain third-party service providers (including analytics, hosting, and email services) may process data outside the EEA, including in the United States.
Where Personal Data is transferred outside the EEA, such transfers are carried out in compliance with GDPR, using appropriate safeguards such as:
- Standard Contractual Clauses (SCCs)
- Adequacy decisions where applicable
Article 4 – MODIFICATIONS AND REVISIONS
We reserve the right to amend this Privacy Policy at any time. Any modifications will be published on this page with an updated Effective Date.
Changes will apply only to data collected after the revision date, unless otherwise required by law. Continued use of the Website constitutes acceptance of the revised Privacy Policy.
Article 5 – PERSONAL DATA COLLECTED
Depending on how you interact with the Website, we may collect the following categories of Personal Data:
a) Data Provided Voluntarily
- Name
- Email address
- Message content submitted via contact forms
- Newsletter subscription details (upon opt-in)
b) Passive and Technical Data
- IP address
- Browser type and version
- Device information
- Pages visited and referring URLs
- Date and time of access
c) Aggregated Data
Personal Data may be aggregated or anonymized for analytical or statistical purposes. Aggregated data does not identify individual users.
Article 6 – COOKIES AND AUTOMATIC DATA COLLECTION
The Website uses cookies and similar technologies to ensure proper functioning and to analyze usage.
Types of Cookies Used:
- Technical / Necessary Cookies: Required for Website functionality
- Analytics Cookies: Used to collect statistical information (e.g., Google Analytics)
You may manage or disable cookies through your browser settings. Disabling cookies may affect Website functionality.
Article 7 – GOOGLE ANALYTICS
The Website uses Google Analytics, a web analytics service provided by Google LLC. Google Analytics uses cookies to analyze how users interact with the Website.
Data collected may include IP address (anonymized where applicable), usage data, and device information.
You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.
Article 8 – PURPOSE AND LEGAL BASIS OF PROCESSING
Personal Data is processed for the following purposes:
- Responding to inquiries and communications
- Providing requested services
- Managing newsletter subscriptions
- Website analytics and performance improvement
- Legal compliance and security
The legal bases for processing under GDPR include:
- User consent (Article 6(1)(a))
- Performance of a contract or pre-contractual steps (Article 6(1)(b))
- Legitimate interests (Article 6(1)(f))
- Legal obligations (Article 6(1)(c))
Article 9 – DISCLOSURE OF PERSONAL DATA
Personal Data is not sold.
Data may be disclosed to third parties only when necessary, including:
- Hosting providers
- Analytics providers
- Email marketing platforms
- Legal or regulatory authorities when required by law
All third parties process data under contractual obligations consistent with GDPR.
Article 10 – DATA RETENTION
Personal Data is retained only for as long as necessary to fulfill the purposes for which it was collected, or as required by law.
You may request deletion of your Personal Data at any time, subject to legal retention obligations.
Article 11 – SECURITY MEASURES
We implement appropriate technical and organizational measures to protect Personal Data against unauthorized access, alteration, disclosure, or destruction.
While we take reasonable precautions, no data transmission over the internet can be guaranteed to be completely secure.
Article 12 – USER RIGHTS UNDER GDPR
You have the right to:
- Access your Personal Data
- Rectify inaccurate data
- Request erasure (“right to be forgotten”)
- Restrict processing
- Object to processing
- Data portability
- Withdraw consent at any time
Requests may be submitted to: [email protected]
You also have the right to lodge a complaint with the Spanish Data Protection Authority (AEPD) or another EU supervisory authority.