Privacy policy

Data controller

Data controller

Pending: holder

NIF

Pending: tax ID

Address

Pending: address

Email

hola@tenemosweb.es

Phone

+41 77 212 74 49 (also WhatsApp)

Details marked as "Pending" will be completed once the holding company is incorporated. Until then, any query is handled at the email address and WhatsApp number given.

The same data, with the detail required by the LSSI (Spain's e-commerce and information society services act), in Legal notice.

What data we process

This website has no form: there's no data we ask you to fill in. But visiting it does leave a trace, like any page: the browser requests each file from our server, and that request is kept in the connection log with your IP address and user agent (the browser and system you use). The homepage also loads the five demos you see on it (bar-pepe.tenemosweb.es and the other four): they're our own subdomains, under the same controller as this website, so there's no new recipient, but they leave the same kind of log.

Apart from that, we only process data if you decide to write to us, and only what you give us at that moment: on WhatsApp, your number and whatever you write; by email, your address, your name if you sign it and the content of the message. We don't buy lists, we don't track your browsing for analytics or advertising purposes and we don't build profiles.

What we process them for

• Keeping the service running and detecting security issues, based on the connection log.
• Answering your query on WhatsApp or by email.
• Preparing a demo or a quote if you ask for one.
• Managing the service and billing if we end up working together.

Under what legal basis

We process connection data on the basis of legitimate interest in the security and proper functioning of the service (article 6.1.f). When you write to us to ask for information, a demo or a quote, we process your message to take steps prior to a contract that you yourself have requested (article 6.1.b): you don't need to give separate consent for that. If your message isn't a commercial query, we handle it also on the basis of legitimate interest in responding to whoever writes to us (article 6.1.f). If we end up working together, the basis becomes performance of the contract (article 6.1.b) and, for invoices, compliance with our legal obligations (article 6.1.c).

How long we keep them

The connection log isn't kept indefinitely: the space its files take up is limited on the server, so once it fills up the oldest entries are discarded first, and they're never used to build profiles. If your conversation with us doesn't lead anywhere, we keep what you wrote to us for a year from the last message. If we end up working together, we keep it for as long as the relationship lasts and six years afterwards: that's the period article 30 of the Código de Comercio (Spain's Commercial Code) requires commercial documentation to be kept, longer than the four years of tax limitation under article 66 of the LGT (Spain's General Tax Law). After that period, it's deleted.

Who we share them with

No one, for commercial purposes. Connection data never leaves our own servers. If you write to us, the provider of the channel you use is involved: WhatsApp is run by Meta, and email, in our case, is hosted by Google (Gmail). These are personal accounts, so they process your message under their own terms, not as a processor that only does what we ask. If we end up working together and hire an accountancy firm for invoicing, it will see the data needed to issue invoices, under the relevant data processing agreement.

Transfers outside the European Union

Meta and Google may process your messages outside the European Economic Area. Both are certified under the EU-US Data Privacy Framework, the European Commission decision that covers that kind of transfer since July 2023. You can check each company's certification and its terms at dataprivacyframework.gov, or in WhatsApp's and Google's privacy policies. This isn't a guarantee we give ourselves: it's a consequence of using those services as a contact channel.

Your rights

You can exercise these rights over your data at any time:

To exercise them, write to hola@tenemosweb.es stating which one you want to exercise. We'll reply ourselves, within a month at most, and it costs you nothing.

Access

Find out what data we hold on you and what we do with it.

Rectification

Correct anything that's wrong or incomplete.

Erasure

Have us delete it once it's no longer needed.

Objection

Object to us processing it for reasons relating to your particular situation.

Restriction

Have us keep it but stop using it while a complaint is resolved.

Portability

Receive it in a commonly used format so you can take it elsewhere.

Complaining to the supervisory authority

If you think we haven't handled your request properly, you can complain to the Agencia Española de Protección de Datos (AEPD, Spain's data protection authority), C/ Jorge Juan, 6, 28001 Madrid, at www.aepd.es. If you'd like, write to us first: it's usually sorted out in one email.

Cookies

This website doesn't install any cookies, of its own or from third parties: not for analytics, advertising or social media. It also doesn't store anything in the browser's local storage. The movement you see when scrolling or hovering over a button is done by code that runs in your browser and leaves no trace between visits or between pages. The fonts are included in the website itself, so they're not requested from external servers like Google Fonts either.

Since it doesn't install any device to store or retrieve data, not even the technical ones that article 22.2 of the LSSI exempts from consent, we don't need to ask your permission, which is why you won't see a cookie banner. If we ever add analytics or advertising in future, we'd ask you before turning it on.