Privacy Policy

1 Data controller

In accordance with the GDPR (EU) 2016/679 and applicable national data protection law, the controller of the personal data collected through this website is:

2 Data we collect

2.1 Contact form

• First and last name.
• Email address.
• Phone number (optional).
• Subject and message content.
• IP address and browser User-Agent (for anti-spam security).

2.2 Contractual relationship (clients)

• Identification data: name, surnames, ID/tax number, company name.
• Professional contact data: email, phone, postal address.
• Financial data: bank details for invoicing and payment management.
• Professional data: job title, department, company.

2.3 Management panel (software users)

When Genloox develops or manages platforms for its clients that include user accounts, only the minimum data necessary for authentication and use of the service is processed (email, name, hashed password, role, access log). In these cases Genloox acts as Data Processor (see clause 10).

2.4 Browsing data (analytics)

• Pages visited, session time, device and browser.
• Anonymised IP address.
• Conversion data (CTA clicks, form submissions).

This data is collected via analytics cookies after obtaining consent (see clause 7).

2.5 Data we do NOT collect

Genloox does not collect special categories of data (health, political ideology, religious beliefs, ethnic origin, biometric data, etc.) through its usual channels. If a specific project requires processing such data, we will inform you and obtain the additional safeguards required by the GDPR.

3 Purposes and legal bases

4 Retention periods

Personal data will be retained for the minimum period necessary for each purpose:

After these periods, data will be deleted or irreversibly anonymised.

5 Recipients and international transfers

5.1 Internal recipients

Only Genloox staff with a legitimate need to access data in order to provide the contracted service will have access to your data.

5.2 Data processors (suppliers)

Genloox may share data with third-party providers acting as data processors, with whom the appropriate data processing agreement (art. 28 GDPR) has been signed. These may include, depending on the project:

• Hosting and server providers (e.g. Hostinger, OVH, AWS, DigitalOcean).
• Web analytics tools (e.g. Google Analytics with IP anonymisation enabled).
• Transactional email platforms (e.g. own SMTP, Mailgun).
• Payment gateways (e.g. Stripe, PayPal) for payment processing.
• Project management and internal communication tools restricted to the Genloox team.

5.3 International transfers

Some providers may be located outside the European Economic Area (EEA). In such cases, Genloox ensures that transfers are made with appropriate GDPR safeguards: European Commission adequacy decisions, standard contractual clauses or recognised certification frameworks.

5.4 No sale of data

Genloox never sells, rents or transfers personal data to third parties for their own commercial purposes.

6 Your rights

Under the GDPR, you may exercise the following rights at any time:

6.1 How to exercise your rights

You can exercise any of these rights by sending a request to genlooxtech@gmail.com, stating your full name, the right you wish to exercise and, if possible, a copy of your identity document. We will respond within a maximum of one month from receipt (extendable by two more months in complex cases).

6.2 Complaint to the supervisory authority

If you believe that the processing of your data does not comply with the GDPR, you have the right to lodge a complaint with the competent supervisory authority. In Spain: www.aepd.es.

7 Cookies and similar technologies

The Genloox website uses first-party and third-party cookies. The types used are described below:

When you first access the website, a consent banner is shown in accordance with applicable regulations. You can manage or revoke your consent at any time from the site cookie settings or from your browser preferences.

For more information on how to disable cookies in major browsers, visit the help pages of Chrome, Firefox, Safari or Edge.

8 Data security

Genloox applies appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including:

• Encryption of communications via TLS/HTTPS across all web environments.
• Password storage using secure hash algorithms (bcrypt/Argon2).
• Data access restricted by roles and the principle of least privilege.
• Regular backups and disaster recovery procedures.
• Access monitoring and anomaly detection in systems.
• Regular security updates for software and dependencies.
• Periodic team training on security and privacy best practices.

8.1 Data breach notification

In the event of a security breach that poses a risk to the rights and freedoms of data subjects, Genloox will notify the supervisory authority within a maximum of 72 hours of becoming aware of it, and affected individuals without undue delay, in accordance with art. 33 and 34 GDPR.

9 Children's data

Genloox services are aimed at businesses and professionals. Genloox does not knowingly collect personal data from children under 14. If we detect that we have collected data from a child without verifiable parental consent, we will delete it immediately.

If you are a parent or guardian and believe your child has provided us with personal data, please write to us at genlooxtech@gmail.com.

10 Data processing agreement (Genloox clients)

When Genloox develops or maintains digital platforms for its clients involving the processing of personal data of third parties (end users, the client's customers, employees, etc.), Genloox acts as Data Processor and the contracting client as Data Controller.

In such cases:

• A Data Processing Agreement in accordance with art. 28 GDPR will be signed prior to the start of the project, setting out the controller's instructions, applicable security measures, authorised sub-processors and procedures for breaches and rights requests.
• Genloox will only process data in accordance with the documented instructions of the controller (client) and will not use it for its own purposes.
• Genloox will assist the controller in fulfilling its GDPR obligations (responding to rights requests, impact assessments, breach notifications).
• Upon termination of the contract, Genloox will return or destroy the personal data processed on behalf of the client, unless legally required to retain it.

11 Social media

Genloox maintains profiles on various social media platforms (LinkedIn, Instagram, etc.). The processing of data of people who interact with those profiles (followers, comments, direct messages) is subject to the privacy policies of each platform, which are joint controllers with Genloox.

Genloox uses information from its social media profiles exclusively to:

• Respond to enquiries and messages received through those platforms.
• Publish content about Genloox services and projects.
• Statistical analysis of publication reach using the native analytics tools of each network.

We do not collect or export follower data outside the platforms themselves, except in the case of direct conversions (e.g. a contact who writes via LinkedIn and with whom a business relationship begins, at which point the purposes in clause 3 apply).

12 Policy changes

Genloox reserves the right to update this Privacy Policy to reflect regulatory changes, case law or changes in its own activities. Any changes will be published on this page with the new update date.

For substantial changes affecting consent-based processing, Genloox will notify data subjects by email or via a prominent notice on the website and will request renewal of consent where necessary.

We recommend you review this page periodically. The version in force is the one published at genloox.com/privacy with the last updated date shown at the top of the document.

13 Contact & DPO

For any query, rights request or complaint relating to the processing of your personal data, you may contact Genloox through the following channels: