Contents
1. Data Controller2. Data We Collect3. Purposes & Legal Basis4. Data Retention5. Third Parties6. International Transfers7. Your Rights8. Cookies9. Security10. Minors11. Policy Changes
This policy complies with the EU General Data Protection Regulation (GDPR) and Spanish data protection law (LOPDGDD).
Summary: Connecting The Dots SLU takes your privacy seriously. We collect only the data necessary to provide our services and respond to your enquiries. We do not sell your personal data to third parties. This policy explains what we collect, why, and what your rights are.
01
Data Controller
The data controller responsible for your personal data is:
Company
Connecting The Dots SLU
Legal Form
Sociedad Limitada Unipersonal
Registered in
Spain
02
Data We Collect
We collect personal data in the following situations:
Contact form and enquiries:
- First and last name
- Company name
- Email address
- Phone number (optional)
- Project description you provide voluntarily
Website browsing (automatically):
- IP address and approximate location
- Browser type and version
- Pages visited and time spent
- Referral source
- Cookie identifiers (see Section 8)
We do not collect sensitive personal data (health, religion, political affiliation, etc.) through our website.
03
Purposes & Legal Basis
We process your personal data for the following purposes and on the following legal bases:
- Responding to enquiries and contact form submissions — Legal basis: legitimate interest and pre-contractual measures (Art. 6.1.b GDPR)
- Managing client relationships and delivering services — Legal basis: performance of a contract (Art. 6.1.b GDPR)
- Sending commercial communications about our services — Legal basis: legitimate interest (Art. 6.1.f GDPR)
- Sending newsletters or marketing emails to subscribers — Legal basis: consent (Art. 6.1.a GDPR)
- Website analytics and improvement — Legal basis: legitimate interest (Art. 6.1.f GDPR) and/or consent where required
- Compliance with legal obligations — Legal basis: legal obligation (Art. 6.1.c GDPR)
04
Data Retention
We retain your personal data for as long as necessary for the purposes described, and in accordance with applicable legal obligations:
- Contact enquiries (non-clients): up to 2 years from last contact, unless you request deletion sooner
- Client data: for the duration of the commercial relationship plus the legally required retention periods (generally 5–6 years under Spanish commercial and tax law)
- Newsletter subscribers: until you unsubscribe
- Analytics data: as determined by our analytics provider settings (typically 14–26 months)
After the applicable retention period, data is securely deleted or anonymised.
05
Third Parties & Data Processors
We do not sell, rent, or share your personal data with third parties for their own marketing purposes.
We may share your data with trusted third-party service providers who assist us in operating our website and delivering our services. These may include:
- Hosting and infrastructure providers (e.g. server and website hosting)
- Email and communication platforms (e.g. for sending responses to enquiries)
- CRM and project management tools used internally to manage client relationships
- Analytics providers (e.g. Google Analytics or equivalent)
- Payment processors (where applicable for invoicing)
All third-party processors are bound by data processing agreements and are required to process data only as instructed and in accordance with GDPR.
We may also disclose your data to public authorities or courts where required by law.
06
International Data Transfers
Some of our third-party service providers may be located outside the European Economic Area (EEA). Where this is the case, we ensure that appropriate safeguards are in place in accordance with GDPR, including:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Transfers to countries with an adequate level of protection as recognised by the European Commission
- Other appropriate transfer mechanisms under GDPR Chapter V
You can request information about the specific safeguards applicable to any transfer by contacting us at the address in Section 12.
07
Your Rights
Under GDPR and applicable Spanish data protection law, you have the following rights regarding your personal data:
- Right of access — to obtain confirmation of whether we process your data and to receive a copy
- Right to rectification — to have inaccurate or incomplete data corrected
- Right to erasure (“right to be forgotten”) — to request deletion of your data in certain circumstances
- Right to restriction — to limit the processing of your data in certain circumstances
- Right to data portability — to receive your data in a structured, machine-readable format
- Right to object — to object to processing based on legitimate interests or for direct marketing purposes
- Right to withdraw consent — where processing is based on consent, to withdraw it at any time
To exercise any of these rights, please contact us at hello@connectingthedots.es. We will respond within one month of receiving your request.
If you are not satisfied with our response, you have the right to lodge a complaint with the Spanish Data Protection Authority (AEPD) at www.aepd.es.
09
Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures are reviewed and updated regularly.
However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your data, we cannot guarantee absolute security.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and, where required, notify affected individuals without undue delay.
10
Minors
Our website and services are directed exclusively at business professionals and companies. We do not knowingly collect personal data from individuals under the age of 18.
If you believe we have inadvertently collected data from a minor, please contact us immediately at hello@connectingthedots.es and we will take steps to delete it promptly.
11
Policy Changes
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.
When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify you by email or through a notice on our website.
We encourage you to review this policy periodically. Your continued use of our website after changes are posted constitutes your acceptance of the updated policy.
