Privacy Policy

1. Data controller

The controller responsible for the processing of your personal data is VALFIGUER LLC, with registered address at 407 Lincoln Rd STE 708, Miami Beach, FL 33139. For any privacy matter you can reach us at legal@valfiguer.com.

2. Data we collect

We only collect the personal data we need. Depending on how you use the Site, this may include:

• Contact data you provide voluntarily — such as your name, email address and the content of your message — when you write to us or use a contact form.
• Technical and usage data — such as IP address, device and browser type, pages visited and interactions — collected automatically through cookies and similar technologies. The analytics data described in section 4 is only collected if you give your consent.
• Any other information you choose to send us in the course of a communication or business relationship.

We do not knowingly collect data from children, and we do not carry out automated decision-making that produces legal effects on you.

3. Purposes and legal basis

We process your personal data for the following purposes and on the following legal bases (Article 6 of the EU General Data Protection Regulation, the “GDPR”):

• To respond to your enquiries and manage our communication with you — based on your consent and/or on the steps taken at your request prior to entering into a relationship (Art. 6(1)(a) and (b) GDPR).
• To operate, secure and maintain the Site, including the security of our infrastructure and the prevention of abuse — based on our legitimate interest in running a secure and reliable website (Art. 6(1)(f) GDPR).
• To measure aggregate use of the Site through analytics cookies — based on your consent, which you can withdraw at any time (Art. 6(1)(a) GDPR). This processing is described in detail in section 4.
• To comply with legal obligations to which we are subject — based on Art. 6(1)(c) GDPR.

4. Cookies and similar technologies

The Site uses strictly necessary cookies in order to function. These do not require your consent and are not used to profile you or for advertising purposes.

The Site also uses Google Analytics 4, a web analytics service provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), acting as a processor on our behalf and under our instructions. This processing is as follows:

• Purpose: to measure aggregate use of the Site — page views, approximate traffic sources and navigation paths — so that we can understand which content is useful and improve the Site. We do not use it for advertising, for profiling, or for automated decision-making about you.
• Legal basis: your consent (Art. 6(1)(a) GDPR). You can give or withdraw it at any time from the Site’s own cookie banner, and also by deleting the cookies in your browser. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.
• Cookies used: Google Analytics 4 sets the “_ga” cookie and a “_ga_” cookie followed by the property identifier, with a maximum lifetime of two years, holding a pseudonymous identifier for your browser. Your IP address is used to derive an approximate location — country or city — and is not stored in the reports.
• International transfer: the data is processed by Google LLC in the United States. Google LLC is certified under the EU-U.S. Data Privacy Framework, covered by the European Commission’s adequacy decision of 10 July 2023, which provides the basis for this transfer; Google also applies the Standard Contractual Clauses as an additional safeguard.
• Retention: event-level and user-level analytics data is kept in Google Analytics for a maximum of fourteen months from collection, after which it is deleted and only aggregate statistics that cannot identify you remain.

If you do not give your consent, or if you withdraw it, no analytics cookie is set and no data is sent to Google Analytics. The Site keeps working as normal, using strictly necessary cookies only.

5. Third parties and processors

We may share personal data with trusted service providers who process it on our behalf and under our instructions — for example hosting, email and analytics providers — bound by appropriate confidentiality and data-protection obligations.

We may also disclose data where required by law, to protect our rights, or in connection with a corporate transaction within the Valfiguer group. We never sell your personal data.

6. International data transfers

VALFIGUER LLC is established in the United States. Where personal data is transferred outside your country — including from the European Economic Area to the United States — we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses or an equivalent recognised mechanism, to ensure your data remains protected.

7. Data retention

We keep personal data only for as long as necessary for the purposes for which it was collected, to comply with our legal obligations, and to resolve disputes or enforce our agreements.

When data is no longer needed, we delete it or anonymise it securely.

8. Your rights

Depending on your location, you have rights over your personal data. Under the GDPR these include the rights to:

• Access the personal data we hold about you and obtain a copy of it.
• Rectify inaccurate or incomplete data.
• Erase your data (“right to be forgotten”) where applicable.
• Restrict or object to certain processing, including processing based on our legitimate interest.
• Data portability, where the processing is based on consent or a contract and carried out by automated means.
• Withdraw consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.

If you are a California resident, the CCPA/CPRA gives you the right to know what personal information we collect, to request its deletion, and to opt out of any “sale” or “sharing” of personal information — which we do not carry out. We will never discriminate against you for exercising your rights.

To exercise any of these rights, contact us at legal@valfiguer.com. You also have the right to lodge a complaint with your local data-protection authority.

9. Changes to this Policy

We may update this Privacy Policy from time to time. The current version, together with its date, is always published on this page, and any material change will be highlighted where appropriate.