Introduction

At Gizbar Consulting S.L. (“we“, “us“, or “our“), we are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard personal data when you visit our website gizbar.tech (the “Site”) or use our services. It also describes your rights and choices regarding your personal data and how you can contact us about our privacy practices. We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and other applicable data protection laws, and we strive to be transparent about our practices.

By using our Site or services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described here, please do not use the Site or provide us with your information.

Information We Collect

We may collect various types of information from you, either directly provided by you or automatically collected through your interaction with our Site:

• Information You Provide to Us: When you contact us through a web form (such as our contact or inquiry form), send us an email, or communicate with us by other means, you may provide personal data. This can include your name, email address, telephone number, company/organization name, and any other information you choose to share in your message. For example, if you request information about our services or request a consultation, we will collect the details needed to contact you and fulfill your request. If you enter into a service agreement with us (as a client), we will also collect information necessary to perform our contractual obligations – such as billing details, business contact information, and any content or data you provide to use our services.

• Information We Collect Automatically: When you visit our Site, we automatically collect certain technical information about your device and usage of the Site. This includes your IP address, browser type and version, operating system, referring website, pages you view, the date and time of each visit, and other browsing data. We collect this information through cookies and similar tracking technologies. Cookies are small text files that are placed on your device to help the website remember your preferences and provide a better user experience. They allow us to recognize your browser and capture and remember certain information – for example, to keep you logged in (if applicable), understand how you use our Site, and improve our content and offerings. For more details on how we use cookies, see the Cookies and Tracking Technologies section below.

• Information from Third Parties: We generally collect personal data directly from you. We do not routinely purchase or obtain personal data from third-party data brokers. However, in some cases, we might receive information about you from third-party sources: for instance, if you are a corporate customer and we are providing services to your employer, they might give us your contact information as an authorized user. Or if you interact with our social media pages or other partners, those platforms might share basic information with us according to their policies (e.g. your public profile info or username). We will treat any information obtained from third parties in accordance with this Privacy Policy and applicable law.

We do not intentionally collect any sensitive personal data (such as government ID numbers, financial account details, information about health, ethnicity, religious beliefs, or sex life) through our Site. Please refrain from providing such sensitive information in any free-text fields or communications with us. We also do not knowingly collect personal data from children. Our Site and services are not directed to individuals under the age of 18, and we will delete any personal data that is inadvertently collected from a minor if we become aware of it.

How We Use Your Information

We use personal data for the following purposes, in accordance with applicable law:

• To Provide and Improve Services: We process your personal data to operate our website and deliver our services. For example, if you fill out a contact form or request a service proposal, we will use your information to respond to your inquiry or fulfill your requests. If you become a client, we use your data to perform our contractual obligations, such as providing consulting services, customer support, and administering your account.

• To Communicate with You: We may use contact information (like your email or phone number) to communicate with you about your inquiries, orders, or use of our services. This includes sending administrative or transactional communications, such as confirmations, invoices, technical notices, updates, security alerts, and support messages. We may also send you information about new features or services that you have opted to receive.

• For Marketing (with Consent or Legitimate Interest): We may use your email or other contact details to send you newsletters, industry updates, or information about our services that may be of interest to you. We will only do so in compliance with applicable spam and privacy laws – for example, if you are an EU resident who is not yet our customer, we will only send you marketing emails if you have opted-in to receive them. You can always opt out of marketing communications by using the unsubscribe link in our emails or contacting us directly. We will not spam you or contact you for marketing if you have asked us not to.

• For Legal Compliance and Protection: We may process personal data as required to comply with applicable laws, regulations, and court orders (for example, keeping proper records for tax or accounting purposes, or responding to lawful requests by public authorities). Additionally, if necessary, we will use and disclose personal data to enforce our Terms of Use, to detect or prevent fraud, security, or technical issues, or to protect the rights, property, and safety of our company, our users, or others. This may include retaining certain information and logging activities to be able to investigate any security incidents or violations.

• To Personalize and Enhance User Experience: We use cookies and similar technologies to remember your preferences (e.g., language settings) and to gather information about how visitors use our Site. This helps us analyze web traffic and usage patterns so we can improve the Site’s design, features, and content. For instance, understanding which pages are most frequently visited or where users encounter errors helps us optimize our online presence. (See below for more on cookies.)

• Other Purposes: If we intend to use your personal data for any purpose that is not compatible with the original purpose for which it was collected, we will obtain your consent or inform you as required by law.

Legal Bases for Processing Personal Data

We always ensure that we have a valid legal basis to process your personal data. Under the GDPR (for users in the European Economic Area and equivalent jurisdictions), our processing is justified by one or more of the following legal bases:

• Performance of a Contract: When we need to process your data to enter into or fulfill a contract with you. For example, when you become a client and we provide consulting services, we process your information to perform that contract.

• Your Consent: Where you have given us clear consent to process your personal data for a specific purpose. For instance, if you subscribe to an email newsletter or agree to receive marketing communications, we rely on your consent. You have the right to withdraw your consent at any time, which will not affect the lawfulness of processing before withdrawal.

• Legitimate Interests: We may process your data as necessary for our legitimate business interests, provided that those interests are not overridden by your data protection rights. For example, it is in our interest to understand how users interact with our Site (through analytics) to improve our services, and to communicate with our existing customers about upgrades or related services. We will always consider your rights and expectations and will not process personal data for activities where our interests are outweighed by the impact on your privacy.

• Legal Obligation: If we are subject to a legal obligation that requires processing of personal data (such as retaining records for compliance with tax law, or disclosing information to law enforcement under a valid order), we will process data on this basis.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our Site to collect information automatically. Cookies are small data files stored on your browser or device. They may be set by us (first-party cookies) or by third-party services we use (third-party cookies). Overall, cookies help us provide a better website experience to you by remembering your preferences and enabling certain features.

How we use cookies:

• Essential Cookies: Some cookies are necessary for the Site to function properly. For example, they may be required to enable core site features like security and network management, or to remember your cookie consent preferences. You cannot opt out of these cookies, as the Site cannot operate without them.

• Analytics and Performance Cookies: We use these to collect information about how visitors use our Site (such as which pages are visited most often and if users get error messages). This data is aggregated and does not directly identify you. It helps us improve the way our Site works, for instance by ensuring users find what they are looking for easily. We may use third-party analytics tools (for example, Google Analytics or similar) that set their own cookies. Any third-party analytics provider is prohibited from using the collected data for purposes other than helping us improve our website and business.

• Functionality Cookies: These cookies remember choices you make (such as your language or region) and provide enhanced, more personalized features. They may also be used to provide services you’ve asked for, like live chat support or remembering form inputs.

• Targeting/Marketing Cookies: At present, we do not use advertising cookies or engage in behavioral advertising on our Site. We do not serve third-party ads that track you across different sites. If this policy changes in the future, we will update this Privacy Policy and obtain any necessary consent.

Your choices: When you first visit our Site, you will be presented with a cookie notice or banner that allows you to accept or reject non-essential cookies. You can also control or delete cookies through your browser settings. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies or alert you when a cookie is being placed on your device. Please note that if you disable cookies entirely, some parts of the Site may not function properly. For example, you might not be able to use certain features or your preferences may not be remembered.

For more information on cookies and how to manage them, you can visit www.allaboutcookies.org (an external website). By continuing to use our Site without disabling cookies via your browser or opting out via our cookie banner, you consent to our use of cookies as described here.

Disclosure of Your Information

We treat your personal data with care and confidentiality. We do not sell your personal information to third parties. However, we may share or disclose your information in the following situations, as necessary for the purposes described above:

• Service Providers: We employ trusted third-party companies and individuals to perform functions on our behalf and help us provide our services (e.g., IT hosting and maintenance, cloud storage, analytics providers, email communication services, customer support tools). These service providers will have access to your personal data only to the extent necessary to perform their tasks and are contractually obligated to protect it and use it only for providing services to us. We require all our processors to comply with data protection requirements.

• Business Partners: In some cases, we may partner with other companies to deliver a service or solution. For example, if our service offering involves a technology integration or reselling a third-party service, we might need to share certain client information with that partner to fulfill the service. In such cases, we will only share the data that is necessary and will ensure appropriate confidentiality agreements are in place. (If you were referred to us by an authorized partner or you sign up through a partner program, we might also share status updates with that partner as needed, but we will not share your personal data with any third-party for their own independent marketing without your consent.)

• Legal Requirements and Protection: We may disclose personal data if required to do so by law or in response to valid requests by public authorities (for example, a court order, subpoena, or government demand). We may also disclose information if we believe in good faith that such action is necessary to comply with a legal obligation, to protect and defend our rights or property, to prevent fraud, to act in urgent circumstances to protect the personal safety of users or the public, or to protect against legal liability.

• Business Transfers: If we are involved in a merger, acquisition, sale of assets, reorganization, or similar transaction, your personal data may be among the transferred assets. Should such a transfer occur, we will ensure the recipient of the data commits to respect your personal data in a manner consistent with this Privacy Policy. We will notify you (for example, via a prominent notice on our Site or by email) of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data as a result of the transfer.

Other than the situations above, you will be notified when your personal information may be shared with third parties, and you will have the opportunity to consent to or opt-out of the sharing if required by law.

International Data Transfers

Gizbar Consulting S.L. is based in Spain and, as such, your data will be stored and processed within Spain or other countries in the European Economic Area (EEA). However, in the course of providing our services and operating our business, we may need to transfer your personal data to third parties (such as service providers) or partners in other countries, including countries outside of the EEA. For example, if we use a cloud hosting provider or an email service whose servers are located in another country, or if we collaborate with a partner company located outside Europe, your data might be transferred to that jurisdiction.

When we transfer personal data outside of the country of origin, we take steps to ensure that appropriate safeguards are in place to protect your information. If you are in the EEA or a region with similar data transfer restrictions, this means that when your personal data is transferred to a country that the European Commission has not determined to have an adequate level of data protection, we will use lawful transfer mechanisms to protect your data. Typically, this involves relying on Standard Contractual Clauses (SCCs) approved by the European Commission, which contractually oblige the recipient to protect your data according to EU standards. We may also rely on other safeguards such as an EU Commission adequacy decision (if the country is recognized as having adequate protection) or obtain your explicit consent for the transfer, where permitted by law. We additionally follow any relevant guidance from the European Data Protection Board (EDPB) regarding international transfers and implement supplementary measures if necessary.

You can contact us for more information about the safeguards we have in place for international data transfers. Despite any transfers, your personal data will continue to be protected as described in this Privacy Policy.

Data Security

We take the security of your personal data seriously. We have implemented appropriate technical and organizational measures to protect your information from unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit (e.g., using SSL/TLS for our website), access controls to limit who in our organization can access personal data, and security protocols to prevent unauthorized intrusion. We also regularly review our information collection, storage, and processing practices to guard against unauthorized access or use.

While we strive to protect your personal data, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee absolute security. You are also responsible for taking reasonable steps to protect your information, such as keeping any account credentials confidential and using secure networks to access our Site. In the event of a data breach that affects your personal data, we will notify you and the relevant authorities as required by law.

We undertake to implement precautions and maintain safeguards designed to ensure the security, integrity, and confidentiality of personal data. If you have reason to believe that your interaction with us or your information is no longer secure, please immediately notify us (see Contact Us section below).

Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

• If you are a prospective customer (for example, you contacted us but did not yet enter into a contract), we may retain the information you provided for a reasonable period in order to follow up on your request and keep records of our communications. If you ask us to delete your information, we will do so, provided we have no ongoing lawful reason to keep it.

• If you become a customer, we will retain your personal data for the duration of the business relationship and thereafter as necessary for legitimate business purposes (such as maintaining records of services provided) or as required by law. For instance, we may retain contract information and invoices for a number of years to comply with tax and financial regulations.

• We also retain personal data as needed to comply with our legal obligations, resolve disputes, and enforce our agreements. The exact retention period for specific data may vary depending on the context and purpose. When personal data is no longer needed, we will ensure it is either securely deleted or anonymized (so that it can no longer be associated with you).

Your Rights and Choices

As an individual whose personal data we process, you have certain rights under privacy laws, especially if you are in the European Union or a similar jurisdiction. We are committed to respecting your rights and ensuring you can exercise them. Subject to applicable law and certain exceptions, these rights may include:

• Right to Access: You have the right to request confirmation of whether we are processing your personal data, and if so, to request a copy of the personal data we hold about you, along with information about how we use and share it. We will provide this in a commonly used electronic form (unless you request otherwise).

• Right to Rectification: If any of your personal data that we hold is inaccurate or incomplete, you have the right to request that we correct or update it. We encourage you to keep your information with us up-to-date.

• Right to Erasure: You can request that we delete your personal data in certain circumstances, for example if it is no longer necessary for the purposes for which it was collected, or if you withdraw consent and we have no other legal basis to continue processing. This is sometimes referred to as the “right to be forgotten.” Please note that this right is not absolute – we may need to retain certain information as required by law or for legitimate business purposes (we will inform you if so).

• Right to Restriction of Processing: You have the right to request that we limit the processing of your personal data under certain conditions, such as while we are verifying the accuracy of your data or reviewing an objection you have raised.

• Right to Data Portability: For data that you have provided to us and that we process by automated means based on your consent or a contract with you, you have the right to request a copy in a structured, commonly used, machine-readable format. You also have the right to request that we transmit that data to another controller where technically feasible.

• Right to Object: You have the right to object to our processing of your personal data when we do so based on legitimate interests, including profiling based on our legitimate interests. You may also object at any time to the processing of your personal data for direct marketing purposes. If you object, we will cease the processing unless we have compelling legitimate grounds overriding your interests or if needed for legal claims.

• Right not to be Subject to Automated Decisions: We do not make any purely automated decisions (with no human involvement) that have legal or similarly significant effects on individuals. However, if we ever did, you would have the right not to be subject to a decision based solely on automated processing, and to request human review.

• Right to Withdraw Consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Once you withdraw consent, we will stop the specific processing that was based on consent. However, withdrawal will not affect the lawfulness of processing prior to the withdrawal, and it will not affect processing that is done on other legal bases.

• Right to Information: You have the right to be informed in a concise, transparent, intelligible, and easily accessible form about how your data is collected and used. We aim to provide that information through this Privacy Policy and any related notices.

These are the key data subject rights under the GDPR. Please note there are conditions and limitations to each of these rights. For example, if your request to erase data conflicts with a legal obligation for us to keep certain data, we may not be able to fulfill that request, but we would inform you of the reasons.

Exercising Your Rights: You can exercise any of your rights by contacting us (see the Contact Us section below). We may need to verify your identity before processing your request, to ensure that we do not disclose data to the wrong person or make changes improperly. We will respond to your request as soon as possible, and in any event within the time frame required by law (generally within one month, with the possibility to extend by two further months in certain complex cases). There is no fee for making a request, though if your requests are manifestly unfounded or excessive (for example, repetitive) we may charge a reasonable fee or refuse to act on the request, as permitted by law.

If you feel that we have not addressed your concerns satisfactorily, you have the right to lodge a complaint with a supervisory data protection authority. For example, if you are in Spain, you can contact the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD). If you are in another EU member state, you can find your data protection authority’s contact details on the European Data Protection Board website or via local government resources. We would, however, appreciate the chance to address your concerns before you approach a regulator, so please consider reaching out to us first.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. If we make material changes to how we handle your personal data, we will provide prominent notice either on our Site or by other appropriate means (e.g., by email, if we have your contact information) to inform you prior to the change becoming effective. The “Last Updated” date at the top of this Policy indicates when it was last revised.

We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your information. Your continued use of our Site or services after any modifications to this Privacy Policy will signify your acknowledgment of the modifications and your agreement to abide by the updated terms.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or about how we handle your personal data, please do not hesitate to contact us:

• Gizbar Consulting S.L.
• Company Number: B22819205
• Address: C. del Balandro, 39, Barajas, 28042 Madrid, Spain
• Email: contact@gizbar.tech

Please include “Privacy Inquiry” in the subject line of your email or correspondence, as applicable. We will respond to your inquiries as soon as reasonably possible.

By contacting us, you can also exercise your data protection rights or request further information about our data processing. We are here to help and committed to resolving any privacy concerns you may have.

Thank you for taking the time to read our Privacy Policy. We value your trust and are dedicated to safeguarding your personal information.