Privacy Policy · Nicolás Castro
1. Data Controller Identification
This Privacy Policy governs the processing of personal data collected through the website nicogcastro.com by the Data Controller:
- Data Controller: Nicolás Castro
- Professional Status: Independent Web Practitioner & Digital Strategist
- Professional Domicile: Spain (EU) / Costa Rica
- Tax Identification (NIF/NIE): Available upon qualified commercial request
- Direct Contact & Privacy Inquiries: privacy@nicogcastro.com or hello@nicogcastro.com
As an independent practitioner operating across Spain and Costa Rica, I am deeply committed to data minimization, transparency, and strict adherence to European and international privacy standards.
2. Data Collected & Processing Purposes
Personal data is only collected when you voluntarily choose to interact with this website. I do not engage in surveillance capitalism, behavioral profiling, or the sale of personal information. The specific purposes for data processing comprise:
- Contact Form Inquiries: Processing your name, email address, company name, scope, timeline, and project message when you submit a project inquiry through the contact form or send a direct email communication.
- Professional Project Evaluation: Reviewing project briefs, architectural requirements, and business context to provide accurate estimates, scopes of work, and project feasibility.
- Client Communication & Contractual Execution: Ongoing correspondence, scheduling discovery sessions, and executing professional design and development agreements.
3. Lawful Basis for Processing
Data processing activities are conducted strictly within legitimate legal frameworks recognized by the European Union General Data Protection Regulation (EU GDPR Regulation 2016/679) and Costa Rica's Law on the Protection of the Person regarding the Processing of their Personal Data (Law 8968):
- Consent (GDPR Art. 6(1)(a) & Costa Rica Law 8968 Art. 5): When you submit a project inquiry via the contact form, you provide explicit, affirmative consent for your information to be processed for the purpose of evaluating and answering your inquiry.
- Legitimate Interest (GDPR Art. 6(1)(f)): Processing is necessary for the legitimate interest of responding to commercial inquiries, maintaining professional correspondence, and delivering requested project evaluations.
- Contractual Performance (GDPR Art. 6(1)(b)): Where an inquiry leads to a formal engagement, processing is necessary to execute the contract and deliver tailored web practitioner services.
4. Data Retention Periods
Personal data is retained only for the duration necessary to satisfy the purposes for which it was originally collected:
- General Inquiries & Correspondence: Inquiries submitted via the contact form that do not result in a commercial contract are retained for up to 12 months to ensure conversational context and commercial continuity, after which they are permanently deleted.
- Client Invoices & Accounting Records: Where a commercial engagement ensues, billing, payment, and tax documentation is retained for 5 years in accordance with statutory accounting and tax compliance obligations under Spanish law.
5. Data Subject Rights (GDPR & Law 8968)
Under EU GDPR (Articles 15–21) and Costa Rica Law 8968 (Article 7), you possess enforceable legal rights regarding your personal information:
- Right of Access (Art. 15): Request confirmation and copies of personal data held about you.
- Right to Rectification (Art. 16): Request correction of inaccurate, outdated, or incomplete data.
- Right to Erasure / Right to be Forgotten (Art. 17): Request deletion of your personal data where retention is no longer legally mandated.
- Right to Restriction of Processing (Art. 18): Request limits on how your data is processed under specific legal conditions.
- Right to Data Portability (Art. 20): Receive your personal data in a structured, commonly used, and machine-readable format.
- Right to Objection (Art. 21): Object at any time to data processing grounded on legitimate interests.
To exercise any of these rights, email privacy@nicogcastro.com or hello@nicogcastro.com. Requests are answered promptly and without undue delay, within a maximum of 30 calendar days.
6. Stateless Processors & Web3Forms
To minimize exposure and safeguard visitor privacy, this website utilizes minimal, carefully audited third-party service providers:
- Web3Forms (Form Dispatch Processor): The website uses Web3Forms as a stateless email dispatch gateway for the contact form. Web3Forms operates as a pure pipeline: it converts your form submission into an encrypted email, delivers it to my inbox, and does not store or monetize submissions in a database. There is zero persistent storage of your contact information on third-party intermediary servers.
- Cloudflare Pages (Hosting & Edge Delivery): The site is deployed statically on Cloudflare's edge network, ensuring high security, TLS encryption, and resilience against unauthorized access.
7. Cookieless Analytics (Plausible)
I believe your browsing behavior belongs to you. This website utilizes Plausible Analytics, an open-source, privacy-first website measurement platform designed to respect digital boundaries:
- Cookieless Operation: Plausible operates entirely without cookies, persistent local storage identifiers, or unique device fingerprints.
- Zero Personal Data: No personally identifiable information (PII), IP addresses, or cross-site tracking data is collected or stored. All measurements are aggregated and fully anonymized.
- EU-Hosted & GDPR Compliant: All analytic data is hosted on servers located within the European Union, fully compliant with GDPR, CCPA, and PECR without requiring an intrusive cookie consent banner.
8. Supervisory Authority Recourse
If you consider that your personal data has been processed in violation of applicable data protection legislation, you have the right to lodge a formal complaint with the competent supervisory authority:
- Spain (EU): Agencia Española de Protección de Datos (AEPD) — C/ Jorge Juan, 6, 28001 Madrid (www.aepd.es).
- Costa Rica: Agencia de Protección de Datos de los Habitantes (PRODHAB) — San José, Costa Rica (www.prodhab.go.cr).