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Privacy Policy

Last updated: 15 October 2026

This is a courtesy translation. In case of any discrepancy, the Spanish version prevails.

1. Data controller

This policy applies to the website gemeloscode.es and describes how we process personal data under Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on Personal Data Protection and Digital Rights (LOPDGDD).

  • Identity: Vladyslav Dolnyi (Gemelos Code)
  • Tax ID (NIF/NIE): Y7168281T
  • Postal address: Calle Madrid 22, Escalera Derecha 3º Izquierda, 28921 Alcorcón, Madrid, España
  • Email: info@gemeloscode.es

2. What data we collect and how

The main way this site collects personal data is through the contact form. The data you may provide is:

  • Required: name, email address, enquiry subject and message.
  • Optional: company and phone number.
  • Technical data: your IP address is processed transiently to limit submission rate and prevent abuse. It is stored only as a cryptographic hash for 30 seconds and is never linked to the message content. The web server also keeps access logs (IP, date, requested page and browser) to keep the service secure; these are deleted automatically within 14 days at most.

Beyond the form, and only if you accept it in the cookie notice, the site measures how it is used with Plerdy (section 9). Any other data you give us (for example by email or during a project) is processed under this same policy.

3. Purpose and legal basis

We process your data for the following purposes:

  • To handle your enquiry and get back to you: answer it, prepare a quote or arrange a meeting. Legal basis: your consent (Art. 6(1)(a) GDPR), given by ticking the acceptance box when submitting the form, and pre-contractual steps taken at your request (Art. 6(1)(b) GDPR).
  • To prevent abuse and keep the site secure (rate limiting, bot filtering, access logs). Legal basis: the controller's legitimate interest in the security of the service (Art. 6(1)(f) GDPR).
  • To measure and improve how the site is used with Plerdy (clicks, scrolling and recordings of visits), only if you accept it. Legal basis: your consent (Art. 6(1)(a) GDPR and Art. 22.2 LSSI-CE), which you can withdraw at any time from “Cookies” at the foot of every page.

We do not use your data to send unsolicited marketing or for advertising, and no automated decisions with legal effects are made about you.

4. Recipients and international transfers

Messages sent through the form are delivered to a private Telegram group accessible only to the owner. Telegram FZ-LLC (Dubai, UAE) and Telegram Messenger Inc. act as messaging service providers; their servers for European users are located in the Netherlands. Using Telegram means your data may be processed by a provider established outside the European Economic Area. That transfer relies on your explicit, informed consent (Art. 49(1)(a) GDPR), given when you accept this policy, and on the need to respond to your request (Art. 49(1)(b) GDPR). Telegram's privacy policy is available at telegram.org/privacy.

If you accept analytics, browsing data is processed by Plerdy (plerdy.com) as a processor, on our behalf and only to measure how the site is used. How Plerdy handles it, including where it is stored, is explained in its privacy policy: plerdy.com/privacy-policy.

The website is hosted on our own server located in the European Union. We do not share your data with any other third party unless legally required.

5. Retention period

We keep form data for as long as needed to handle your enquiry and at most 12 months from the last contact, unless a contractual relationship begins, in which case data is kept for its duration plus the applicable statutory limitation periods (generally 5 years for contractual matters and 4 years for tax matters in Spain).

The analytics data Plerdy keeps in your browser expires within 30 minutes to 60 days, except the visitor identifier, which remains until you withdraw consent (we then delete it) or clear your browser data. Data received by Plerdy is kept under its own privacy policy. Your analytics choice is kept for 12 months.

If you ask us to erase your data before then, we will do so without undue delay unless we are legally required to keep it.

6. Your rights

You may exercise the following rights at any time:

  • Access: know which of your data we process.
  • Rectification: correct inaccurate or incomplete data.
  • Erasure: ask us to delete your data.
  • Objection: object to processing based on legitimate interest.
  • Restriction: ask us to restrict processing in certain cases.
  • Portability: receive your data in a structured, commonly used format.
  • Withdraw consent at any time, without affecting the lawfulness of prior processing.

To exercise them, write to info@gemeloscode.es or to the postal address in section 1, stating the right you wish to exercise. We may ask you to verify your identity. We will reply within one month.

If you believe the processing does not comply with the law, you have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD), C/ Jorge Juan 6, 28001 Madrid, www.aepd.es.

7. Security

We apply appropriate technical and organisational measures to protect your data: communication with the site is encrypted over HTTPS, access to the server and the Telegram channel is restricted to the owner, and no copies of messages are stored on the web server.

8. Minors

This site is aimed at businesses and professionals. We do not knowingly collect data from anyone under 14. If you become aware that a minor has given us data, let us know and we will delete it.

10. Changes to this policy

We may update this policy to reflect legal or service changes. The version in force is always the one published on this page, with its update date.

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Cookies and analytics

What we see

  • Clicks, scrolling and the path through the pages
  • Recordings of visits, without what you type into forms

What we don’t do

  • Use it for advertising
  • Sell your data

You can change your mind at any time from “Cookies” at the foot of every page. Privacy policy