Privacy policy

1. Data controller

Owner: Sergei Novodatskii, self-employed professional (autónomo) trading as DobleAgencIA. NIE: Z0105385G. Address: Calle Manuel Galián 13, 03182 Torrevieja (Alicante), España. Email: novodatskiy@gmail.com. Phone and WhatsApp: +34 613 619 302.

We are not required to appoint a Data Protection Officer; for privacy questions write to the email above.

2. Data we collect and how

• Contact data you give us in the brief, on WhatsApp, Telegram or by email: name, company or website, phone, email and your message.
• Project data: business type, services you need, rough budget and timing.
• Browsing data (pages viewed, device, traffic source, advertising identifiers) via cookies, only if you accept them.
• Billing data if you buy a service: name or company name, tax ID and address.

3. Purposes

• Reply to your request and prepare a proposal or quote.
• Deliver the service and talk to you during the project.
• Meet accounting and tax obligations.
• Analyse site usage to improve it (with your consent).
• Measure and show ads on Google and Meta (Facebook, Instagram) (with your consent).

4. Legal bases

• Consent (Art. 6.1.a GDPR): brief, analytics and advertising cookies. You can withdraw it at any time.
• Pre-contract steps and contract performance (Art. 6.1.b GDPR): quotes and service delivery.
• Legal obligation (Art. 6.1.c GDPR): invoicing and tax.
• Legitimate interest (Art. 6.1.f GDPR): site security and defence against claims.

5. Retention

• Enquiries without a contract: up to 24 months from the last contact.
• Clients: for the relationship, then 6 years for commercial and tax law and 5 years for possible civil claims.
• Cookies: as set out in the Cookie policy.

After that, data is deleted or anonymised.

6. Recipients and international transfers

We do not sell your data. Only providers acting as processors on our behalf receive it: web hosting, Telegram (internal delivery of briefs), WhatsApp (Meta Platforms Ireland), Google Ireland (Analytics, Ads, Google Fonts) and Meta Platforms Ireland (Pixel). Also our tax adviser and public authorities when the law requires it.

Some providers may process data outside the EEA. GDPR safeguards then apply: an adequacy decision (such as the EU-US Data Privacy Framework) or the European Commission's standard contractual clauses.

7. Your rights

Access, rectification, erasure, objection, restriction and portability, withdrawing consent, and not being subject to decisions based solely on automated processing.

8. How to exercise your rights

Write to novodatskiy@gmail.com stating the right, your name and a reply address. If we have doubts about your identity we may ask for proof. We reply within one month (extendable by two in complex cases). It is free unless requests are manifestly unfounded or excessive.

9. Complaints to the supervisory authority

If you think we have not handled your rights properly, you can complain to the Spanish Data Protection Agency (AEPD, C/ Jorge Juan, 6, 28001 Madrid), www.aepd.es.

10. Security

HTTPS encryption, access to data limited to the owner, strong passwords and backups. If a breach puts your rights at risk, we will notify the AEPD within 72 hours and, where required, the people affected.

11. Minors

Our services are for businesses and professionals. We do not knowingly collect data from children under 14.

12. Changes

We may update this policy and publish the current version here with its date. If the change is significant we will tell you if we have your contact details.

Last updated: 26 October 2026.

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