Privacy policy

Data controller

Controller: Josep Castells de la Ascensión, self-employed (autónomo), trading as Togent.

NIF: 47861458E.

Address: Av. Robert Graupera, 74, 43580 Deltebre (Tarragona, Spain).

Contact: hola@togent.io.

Contact form

The following are collected: first name and surname, company, job title, email address, country, type of company and how you heard about us, together with the page from which you reach the form. The purpose is to answer the enquiry, prepare the call and, where applicable, assess a possible professional engagement.

Legal basis: taking steps prior to entering into a contract at the request of the data subject (Art. 6(1)(b) GDPR). Writing to us is your request; there is no need to tick any box, and this data is not used for anything else.

Retention: up to one year from the last contact or, if the engagement goes ahead, for the duration of the professional relationship and the statutory retention periods for tax purposes.

Call booking

If you book a call in the calendar, your name, your email address, the topic you want to discuss and the chosen time are collected, together with the page from which you book. The purpose is to confirm the appointment, send you the video call link and prepare the call.

Legal basis: taking steps prior to entering into a contract at the request of the data subject (Art. 6(1)(b) GDPR).

Retention: up to one year from the call or, if the engagement goes ahead, for the duration of the professional relationship and the statutory retention periods for tax purposes.

Web analytics

Cloudflare Web Analytics: only loaded if you accept analytics. It does not use cookies or store anything on your device and does not identify visitors individually; it collects aggregated data on pages visited, country and device type. Legal basis: your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time via "Cookie settings", at the foot of every page.

Google Analytics 4: only loaded if you accept analytics cookies. It collects the pages you visit, how you arrived and technical data about your browser and device, linked to a random identifier stored in a cookie. Advertising and ad personalisation are disabled. Legal basis: your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time via "Cookie settings", at the foot of every page.

Retention in Google Analytics: 2 months, the shortest period the tool allows.

Who else processes this data

Google Cloud EMEA Limited (Ireland), through Google Cloud and Firebase: it hosts this site (Firebase Hosting, which serves it from its global network), the server that receives the contact form and bookings (Cloud Run, in Belgium) and the database that stores them, with its backups (in Madrid and in Belgium, EU).

Cloudflare, the domain's DNS and, only if you give your consent, web analytics. This may involve transfers to the United States, covered by the EU-U.S. Data Privacy Framework.

Google Ireland Limited, web analytics (Google Analytics 4), only if you give your consent. This may involve transfers to the United States, covered by the EU-U.S. Data Privacy Framework, under which Google is certified.

Zoho Corporation B.V. (the Netherlands), with servers in the EU: delivery of the emails that confirm bookings and of the internal notices for each form received.

Email for hola@togent.io: Cloudflare (Email Routing) receives the messages and forwards them to a Gmail mailbox, provided by Google Ireland Limited. This may involve transfers to the United States, covered by the EU-U.S. Data Privacy Framework.

Where a provider involves a transfer of data outside the European Economic Area, that transfer is covered by the standard contractual clauses approved by the European Commission or by adequacy decisions in force.

No data is disclosed or sold to third parties for commercial purposes.

Your rights

You can exercise your rights of access, rectification, erasure, objection, restriction of processing and portability by writing to hola@togent.io and proving your identity.

You can also lodge a complaint with the Agencia Española de Protección de Datos (www.aepd.es) if you consider that the processing does not comply with the applicable regulations.

Minors

This site is aimed at professionals and businesses. It is not intended for minors and no data is knowingly collected from persons under 14 years of age.

Security

Reasonable technical and organisational measures are applied to protect the data: encryption in transit (HTTPS), restricted access to the infrastructure and separation of each client's data in the systems that host it.