1. INTRODUCTION
This Privacy Policy explains how barmenteros FX (“barmenteros FX”, “we”, “us”, “our”) collects, uses, stores, and protects personal data when you (“User”, “Client”, “you”, “your”) access our website, contact us, or use our Services or Products.
We process personal data in accordance with:
- Regulation (EU) 2016/679 (General Data Protection Regulation — GDPR)
- Ley Orgánica 3/2018 (LOPDGDD) — Spanish Data Protection Law
- Law 34/2002 (LSSI-CE) on e-commerce and digital services
By using our website or contacting us, you accept this Privacy Policy.
2. DATA CONTROLLER
The Data Controller is:
barmenteros FX
Avenida Principe Salman, 6, 5th
29603 Marbella (Malaga) — Spain
Email: [email protected]
NIF: 74640188J
3. PERSONAL DATA WE COLLECT
We may collect and process the following categories of data:
3.1 Data you provide voluntarily
- Name and surname
- Email address
- Phone number
- Trading-project descriptions or technical specifications
- Files required for development (indicators, scripts, documents, code samples)
- Payment confirmation or billing information
- Messages sent via contact forms, email, WhatsApp, Telegram
- Testimonials or feedback you voluntarily submit
3.2 Data collected automatically
When visiting our website, we may collect:
- IP address
- Browser type and version
- Device type
- Operating system
- Time zone
- Language settings
- Referring URLs
- Pages visited and time spent
- Mouse events (for analytics tools such as Microsoft Clarity)
- Server logs
3.3 Cookies and tracking data
We use cookies to:
- Improve website performance
- Understand usage patterns
- Remember preferences
- Perform analytics
Specific details are provided in our Cookies Policy.
4. PURPOSES OF PROCESSING
Your data is processed for the following purposes:
4.1 To provide our Services
- Responding to requests
- Preparing quotations
- Delivering custom software
- Communicating during development
- Providing technical support
4.2 To execute contracts
- Creating and delivering Deliverables
- Processing payments
- Managing project milestones
4.3 For legitimate business interests
- Improving our website
- Enhancing user experience
- Internal analytics, performance monitoring, and optimization
- Preventing fraud and abuse
4.4 To comply with legal obligations
- Maintaining accounting records
- Complying with tax regulations
- Responding to lawful requests by authorities
4.5 Marketing communications
We may send occasional updates about:
- New services
- Technical articles
- Announcements
You can unsubscribe at any time.
5. LEGAL BASIS FOR PROCESSING
Under GDPR, we rely on one or more of the following legal bases:
- Performance of a contract: when responding to requests, quotations, and development work.
- Legitimate interests: analytics, website improvement, security, client management.
- Consent: when you voluntarily provide data through forms or subscribe to communications.
- Legal obligations: accounting, tax, or regulatory requirements.
6. DATA RETENTION
We retain data only as long as necessary for the purposes described:
- Project-related communication: up to 6 years (Spanish commercial law)
- Billing and tax documents: 5 years (Spanish Tax Agency requirement)
- Marketing emails: until the User unsubscribes
- Analytics data: typically 12–36 months depending on tool settings
- Cookies: defined in Cookies Policy
Once data is no longer needed, it is securely deleted or anonymized.
7. DATA SHARING AND THIRD PARTIES
We do not sell, trade, or rent your personal data.
We may share data with:
7.1 Service providers (“processors”)
Such as:
- Hosting providers (e.g., SiteGround, AWS)
- Email service providers
- Analytics tools (Google Analytics, Microsoft Clarity)
- Cloud storage (if used for project files)
Processors only access data required to perform their tasks and must comply with GDPR.
7.2 Legal compliance
We may share data with:
- Courts
- Law enforcement
- Tax authorities
When required by applicable law.
7.3 International data transfers
Some processors may be located outside the EU.
In such cases, we ensure appropriate safeguards such as:
- Standard Contractual Clauses (SCCs)
- Adequacy decisions
- GDPR-compliant contractual terms
If such safeguards cannot be ensured, we will not transfer personal data.
8. SECURITY MEASURES
We implement appropriate technical and organizational security measures, including:
- Encryption technologies (SSL/TLS)
- Secure password policies
- Access-restricted hosting
- Controlled retention periods
- Regular monitoring of hosting infrastructure
- Separate storage of sensitive project files
- No storage of payment card data (handled by third-party processors)
No online data transmission can be 100% secure.
9. YOUR RIGHTS UNDER GDPR
You may exercise any of the following rights:
9.1 Right of access
Request a copy of your personal data.
9.2 Right to rectification
Request correction of inaccurate or incomplete data.
9.3 Right to erasure (“right to be forgotten”)
Request deletion of your data, except where law requires retention.
9.4 Right to restriction of processing
Request temporary suspension of processing.
9.5 Right to data portability
Request export of your data in a structured format.
9.6 Right to object
Object to processing based on legitimate interests.
9.7 Right to withdraw consent
Withdraw consent at any time without affecting prior processing.
9.8 Right to file a complaint
You may file a complaint with the Spanish Data Protection Authority (AEPD).
10. CHILDREN’S PRIVACY
Our services are not directed to minors under 18 years.
We do not knowingly collect data from minors.
If you believe we have unintentionally collected such data, contact us and we will delete it.
11. EXTERNAL LINKS
Our website may contain links to external sites.
We are not responsible for:
- Their privacy practices
- Their content
- Their data-handling procedures
12. COOKIES
The use of cookies is described in detail in our Cookies Policy, which is an integral part of this Privacy Policy.
13. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time.
Changes take effect when published.
Continued use of our website or services constitutes acceptance of updated policies.
14. CONTACT INFORMATION
For privacy-related inquiries or data-protection requests:
barmenteros FX
Avenida Principe Salman, 6, 5th
29603 Marbella (Malaga) — Spain
Email: [email protected]
NIF: 74640188J