Privacy Policy — Cleverina

Cleverina ("we", "us", "our") is operated by Alexander Starostin as an autónomo registered in Spain. This Privacy Policy explains how we collect, use, share and safeguard personal data when you visit cleverina.com or engage our services. We comply with the EU General Data Protection Regulation (GDPR) and Spanish data protection law (LOPDGDD).

Data controller

Alexander Starostin (Cleverina), Spain. Contact: contact@cleverina.com.

Data we collect

Information you submit through our contact form (name, work email, company, role, area of interest, message).
Email correspondence and meeting notes when you engage with us directly.
Standard server logs (IP address, user agent, timestamps) for security and analytics.
Anonymous usage analytics through Google Analytics 4 (page views, referrer, device class).

Legal basis

We process personal data under one of the following legal bases: your explicit consent, performance of a contract, our legitimate interest in operating the website and responding to enquiries, or compliance with a legal obligation.

How we use your data

To respond to consultation requests and questions you submit.
To deliver, invoice and improve the services you engage us for.
To maintain website security and detect abuse.
To produce aggregated, non-identifying usage statistics.

We do not sell personal data, ever.

Sharing & processors

We share personal data only with trusted processors required to run the business: Netlify (website hosting and form submissions), Google (Analytics 4), Microsoft 365 (email and collaboration). Each operates under its own DPA and provides appropriate safeguards for any international transfers.

Retention

Contact-form submissions are retained for up to 24 months. Client records are kept for the duration of the engagement plus the retention period required by Spanish tax law (typically 6 years).

Your rights

Under the GDPR you have the right to access, rectify, erase, restrict or object to processing, and to data portability. You can withdraw consent at any time. To exercise any of these rights, email contact@cleverina.com. You may also lodge a complaint with the Spanish supervisory authority, the Agencia Española de Protección de Datos (AEPD).

Security

We apply the same governance-first security practices we recommend to clients: identity-centric access controls, MFA on all administrative systems, encryption in transit, and least-privilege data handling.

Changes

We may update this policy from time to time. The "Last updated" date above reflects the most recent revision.