Data controller
- Controller
- Gabriel Florencio Calvo (FCG Systems)
- Tax ID (NIF)
- 49236244Y
- Address
- Huelva, Spain
- hola@fcgsystems.es
We haven’t appointed a data protection officer because we aren’t required to. For any privacy question, write to the email above.
What data we process
We only process the data you send us through the contact form or by email:
- Contact details: name, work email and, if you provide it, company.
- Enquiry details: where you’d like to start and the message you write.
- Technical submission data: date and time, IP address and browser (user agent), kept as proof of your consent and to prevent abuse.
We don’t ask for special categories of data. Please don’t include them in your message. To know which pages are visited we use our own cookie-free analytics (Umami, hosted on our server): it measures visits in aggregate, builds no profiles and does not let us identify you.
Purposes and legal basis
| Purpose | Legal basis |
|---|---|
| Replying to your contact request and continuing the conversation you start. | Your consent, given when you submit the form (art. 6.1.a GDPR). |
| Preparing a proposal if you ask for one. | Pre-contractual steps taken at your request (art. 6.1.b GDPR). |
| Assessing your application if you email it to us from the careers page. | Your consent, given when you send us your application (art. 6.1.a GDPR). |
| Protecting the form against spam and abusive submissions, and keeping proof of consent. | Legitimate interest in the security of the service and in being able to demonstrate consent (art. 6.1.f GDPR). |
We don’t use your data to send you marketing communications and we don’t make automated decisions that affect you.
Retention
- If your enquiry doesn’t lead to a business relationship, we delete your data within 12 months of the last contact.
- If you send us a job application, we keep it for up to 12 months for hiring processes and then delete it.
- If you become a client, we keep it for the duration of the relationship and then for the periods required by law (for example tax and commercial obligations).
- You can ask us to delete it earlier at any time, unless we are legally required to keep it.
Recipients and processors
We don’t share your data with third parties unless required by law. To run the service we use providers acting as data processors, under contract and with safeguards in line with article 28 GDPR:
- A hosting provider (server) located in the European Union, where incoming messages are stored.
- Messaging and email providers we use to be notified of each new enquiry.
If any of these providers processes data outside the European Economic Area, it will do so with appropriate safeguards, such as a European Commission adequacy decision or standard contractual clauses.
Your rights
You can exercise your rights of access, rectification, erasure, objection, restriction of processing and portability at any time, and withdraw your consent, by writing to hola@fcgsystems.es and stating which right you want to exercise. If we have reasonable doubts about your identity, we may ask for additional information to confirm it.
Withdrawing consent doesn’t affect the lawfulness of prior processing. We’ll reply within one month, which may be extended in the cases provided for by the GDPR.
If you believe we haven’t handled your data properly, you can file a complaint with the Spanish Data Protection Agency (www.aepd.es) or the supervisory authority where you live.
Security
The website is always served over HTTPS. Messages are stored on a server with restricted access, credentials are kept in a password manager and technical logs don’t include your message or your email.
Changes to this policy
We may update this policy to reflect legal or service changes. The date of the last review is shown at the top of the page.