[TEMPLATE — REVIEW BEFORE FINAL PUBLICATION. THIS IS NOT LEGAL ADVICE.]

1. DATA CONTROLLER

Controller: Miguel Ángel Suárez Balboa.

Spanish Tax ID (NIF): 54094930B.

Address: c/ Ruiz 11, Telde (Las Palmas), Spain.

Email: migui.expressive@outlook.com.

Activity: professional photography services and digital delivery of photographic material.

2. APPLICABLE LAW

The processing of personal data is carried out in accordance with Regulation (EU) 2016/679 (GDPR), Spanish Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD) and other applicable Spanish regulations.

3. DATA WE PROCESS

- Contact data provided through forms or by email (name, email, phone).

- Contracting and billing data when services or products are purchased.

- Browsing and usage data of the site (cookies, identifiers, IP address, browser, device, pages viewed).

- Images and audiovisual material generated during contracted sessions, under the terms agreed with the client.

4. PURPOSES AND LEGAL BASES

4.1. Handling enquiries and information requests — basis: consent of the data subject (art. 6.1.a GDPR).

4.2. Managing the contracting, provision and billing of services — basis: performance of a contract (art. 6.1.b GDPR).

4.3. Compliance with legal, accounting and tax obligations — basis: legal obligation (art. 6.1.c GDPR).

4.4. Sending the Provider’s own commercial communications, where applicable — basis: consent (art. 6.1.a GDPR).

4.5. Audience analysis and improvement of the website through cookies and similar technologies — basis: consent (art. 6.1.a GDPR), obtained through the cookie banner.

5. DATA RETENTION

Data will be kept for the duration of the contractual relationship and thereafter for the legally required periods (in particular, tax and commercial periods). Delivered images will be retained for [PLACEHOLDER: indicate period].

6. RECIPIENTS

Data will not be transferred to third parties except as legally required. The following processors or technology providers are used to deliver the service:

- Wfolio (website and gallery platform).

- Email provider [PLACEHOLDER].

- Payment gateway [PLACEHOLDER].

- Google Ireland Ltd. (Google Analytics 4 and Google Tag Manager).

- Pinterest Europe Ltd. (Pinterest Pixel).

Some of these providers may involve international data transfers outside the EEA, in which case the safeguards provided for in Chapter V of the GDPR (European Commission Standard Contractual Clauses) shall apply.

7. COOKIES AND TRACKING TECHNOLOGIES

This site uses first-party and third-party cookies. You can review and change your preferences through the cookie banner. In particular, we use the following tools, which will only be activated if you give your consent:

a) Google Tag Manager (GTM) — provider: Google Ireland Ltd.

Purpose: a technical container that allows the centralised management and deployment of the site’s measurement and marketing tags (including GA4 and the Pinterest Pixel). GTM, by itself, does not collect personal data for analytics or advertising purposes, but is the tool through which the other tags are loaded.

b) Google Analytics 4 (GA4) — provider: Google Ireland Ltd.

Purpose: statistical analysis of website usage (page views, sessions, traffic source, device, user behaviour and conversions), with the aim of measuring the audience and improving the content and the user experience. GA4 uses identifiers and cookies to distinguish users and sessions.

c) Pinterest Pixel — provider: Pinterest Europe Ltd.

Purpose: measuring the effectiveness of advertising campaigns on Pinterest, recording conversions (e.g. contacts or purchases coming from ads), building audiences for remarketing and showing personalised advertising on the Pinterest platform. The pixel uses cookies and identifiers that may be processed outside the EEA by Pinterest.

You may withdraw your consent at any time from the site’s cookie preferences panel or from your browser settings.

8. RIGHTS OF DATA SUBJECTS

You have the right to access, rectify and erase your data, to request the restriction of or object to the processing, as well as to data portability and not to be subject to automated decisions. To exercise these rights, write to migui.expressive@outlook.com indicating the right you wish to exercise and attaching a copy of an identification document.

You may also lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) if you consider that the processing does not comply with the regulations.

9. SECURITY

Reasonable technical and organisational measures are applied to ensure the confidentiality, integrity and availability of the personal data processed.

10. CHANGES

This Privacy Policy may be updated to adapt to regulatory changes or changes to the services. The version in force will always be the one published on this website.

11. CONTACT

For any query about this Privacy Policy: migui.expressive@outlook.com.