Privacy Policy

1. Introduction

This Privacy Policy describes how Keino Uelze ("I", "me", "my", "the Provider"), a freelance IT professional based in Spain, collects, uses, processes, and protects the personal data of visitors and clients ("you", "your") through the website https://www.cue4net.com (the "Website"), particularly via the contact form.

I am committed to protecting your privacy and ensuring compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Spanish Organic Law 3/2018 on Data Protection and Guarantee of Digital Rights (LOPDGDD).

This policy primarily addresses English-speaking business clients globally.

2. Data Controller

The controller responsible for the processing of your personal data is:

• Name: Keino Uelze
• Registered Address: Lagar Perez Buenavista N° 144, 29716 Canillas de Aceituno, Malaga, Spain
• Tax ID (NIF/NIE): Y5308403V
• Email: keino@cue4net.com
• Website: https://www.cue4net.com

3. Personal Data Collected

I collect the following personal data when you voluntarily submit it through the Website's contact form:

• Full Name: To identify you.
• Email Address: To communicate with you.
• Company Name: To understand your business context.
• Phone Number (Optional): For alternative communication if provided.
• Contact Purpose: To categorize and prioritize your inquiry.
• Message Content: To understand the details of your request or inquiry.

I may also collect technical data automatically (e.g., IP address, browser type) for website security and analytics, processed in an aggregated or anonymized form where possible.

4. Purpose of Data Processing

Your personal data is processed for the following purposes:

• Communication: To respond to your inquiries, requests for information, or service proposals submitted via the contact form.
• Service Provision: To take steps at your request prior to entering into a contract or to fulfill contractual obligations if you become a client.
• Service Improvement: To analyze feedback and understand client needs to enhance my services (often using aggregated or anonymized data).
• Automated Processing: Potentially to trigger automated message filtering or initial responses to manage inquiries efficiently.
• Legal Compliance: To comply with applicable legal and regulatory obligations in Spain.

5. Legal Basis for Processing

The legal bases for processing your personal data under GDPR and LOPDGDD are:

• Consent (Art. 6(1)(a) GDPR): Your explicit consent given when submitting the contact form. You can withdraw your consent at any time.
• Contractual Necessity (Art. 6(1)(b) GDPR): Processing necessary to take steps at your request before entering into a contract or for the performance of a contract with you.
• Legitimate Interests (Art. 6(1)(f) GDPR): Processing necessary for my legitimate interests, such as improving services or ensuring website security, provided these interests are not overridden by your fundamental rights and freedoms.
• Legal Obligation (Art. 6(1)(c) GDPR): Processing necessary to comply with Spanish legal requirements.

6. Data Storage, Security, and Location

• Storage: Your personal data submitted via the contact form is stored securely in a PostgreSQL database.
• Security: I implement appropriate technical and organizational measures (e.g., access controls, encryption where feasible) to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Access to the database is restricted.
• Location: Data is primarily processed and stored within the European Economic Area (EEA). If any processing involves transfer outside the EEA, I will ensure appropriate safeguards are in place (e.g., Standard Contractual Clauses).

7. Data Retention

I will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Typically:

• Contact form submissions are retained for the duration needed to address the inquiry and for a reasonable period afterward for follow-up or record-keeping (e.g., 1-2 years), unless a longer period is required by law or for establishing, exercising, or defending legal claims.
• Client data is retained for the duration of the contractual relationship and as required by Spanish law (e.g., commercial and tax regulations often require 6-10 years).

Once data is no longer needed, it will be securely deleted or anonymized.

8. Cookies and Website Analytics (Google Analytics)

This Website uses cookies and similar technologies to enhance user experience, analyze website traffic, and improve our services.

• What are Cookies? Cookies are small text files stored on your device (computer, tablet, smartphone) when you visit a website. They allow the website to remember your actions and preferences over a period of time.
• Google Analytics: We use Google Analytics, a web analytics service provided by Google Ireland Limited ("Google"). Google Analytics uses cookies to collect information about how visitors use our Website. This information includes:
  • Your IP address (which may be anonymized by Google)
  • Pages visited on our site
  • Time spent on pages
  • Links clicked
  • Browser type and version
  • Operating system
  • Referring website
• Purpose: We use this information to understand website traffic patterns, identify popular content, diagnose technical issues, and generally improve the Website and our service offerings. The data collected is typically aggregated and does not personally identify you directly, although IP addresses can be considered personal data.
• Legal Basis: The processing of data collected via Google Analytics cookies is based on our Legitimate Interests (Art. 6(1)(f) GDPR) in understanding and improving our website performance and user experience.
• Data Transfer: Information generated by the cookies about your use of the website may be transmitted to and stored by Google on servers in the United States or other countries outside the European Economic Area (EEA). Google complies with data transfer frameworks like the EU-U.S. Data Privacy Framework or uses Standard Contractual Clauses to ensure an adequate level of data protection. For more information, please review Google's Privacy Policy: https://policies.google.com/privacy
• Data Retention: Google Analytics retains data for a specific period as configured in our account settings, after which it is automatically deleted.
• Managing Cookies & Opting Out:
  • Most web browsers allow you to control cookies through their settings preferences. You can block or delete cookies already stored on your device. However, blocking essential cookies might affect the functionality of the Website.
  • You can opt-out of Google Analytics tracking specifically by installing the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout

9. Your Data Protection Rights

Under GDPR and LOPDGDD, you have the following rights regarding your personal data:

• Right of Access: To request copies of your personal data.
• Right to Rectification: To request correction of inaccurate or incomplete data.
• Right to Erasure ('Right to be Forgotten'): To request deletion of your personal data under certain conditions.
• Right to Restriction of Processing: To request limitation of how your data is processed under certain conditions.
• Right to Object to Processing: To object to processing based on legitimate interests under certain conditions.
• Right to Data Portability: To request transfer of your data to another organization, or to you, in a structured, commonly used, machine-readable format, under certain conditions.
• Right to Withdraw Consent: To withdraw your consent at any time where processing is based on consent.

To exercise any of these rights, please contact me using the details provided in Section 2 (Data Controller). I will respond to your request in accordance with applicable data protection laws. You may be asked to verify your identity.

10. Complaints

If you believe your data protection rights have been infringed, you have the right to lodge a complaint with the competent supervisory authority:

• Agencia Española de Protección de Datos (AEPD)
• Website: https://www.aepd.es
• Address: C/ Jorge Juan, 6, 28001-Madrid, Spain

However, I encourage you to contact me first to resolve any concerns.

11. Third-Party Links

The Website may contain links to third-party websites. This Privacy Policy does not apply to those sites. Please review their respective privacy policies.

12. Changes to this Privacy Policy

I may update this Privacy Policy periodically to reflect changes in my practices or for legal reasons. Any updates will be posted on this page with a revised "Last Updated" date.

13. Contact Information

For any questions or concerns regarding this Privacy Policy or the processing of your personal data, please contact me:

• Email: legal@cue4net.com
• Via Post: Keino Uelze, Calle Pizarras 38 (Bar Miguel), 29712 Vinuela, Malaga, Spain