Privacy Policy

At Flap Agency LLC (hereinafter, "Flap Agency", "we" or "the company") we are committed to protecting your privacy and personal data. This Privacy Policy describes how we collect, use, store and protect the personal information you provide to us through our website flapconsulting.com.

This policy has been prepared in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and applicable data protection legislation.

Through our contact form, we collect the following personal data:

• Identification data: first and last name
• Contact data: email address and phone number
• Professional data: company name, company size and business sector
• Information about your inquiry: description of the challenge or need you wish to address

We also automatically collect certain data through cookies and similar technologies. For more information, please see our Cookie Policy.

In addition to the data you give us when using the website, we process business contact data of companies and of the individuals who represent them, obtained without any prior request on their part. This section complies with Article 14 of the GDPR.

Where we obtain it

• The Official Gazette of the Commercial Registry (BORME), whose reuse is covered by Law 37/2007 and the BOE licence.
• The companies' own corporate websites, when they publish contact details.
• Publicly accessible professional directories and registries.
• Business contact data enrichment providers, which locate or verify corporate addresses.

In each communication we send, we indicate which of these sources your data comes from.

What data it is

Name and surname, job title, company, business email address, business phone when public, and public professional profile. We do not process personal data of a private nature or special categories.

Purpose and legal basis

Purpose: to present our professional services to companies that, given their activity, may need them.

Legal basis: legitimate interest (Art. 6.1.f GDPR), under the terms of Art. 19 of the LOPDGDD for business contact data. We have carried out and documented a written balancing test weighing that interest against your rights, and you may request a summary at the address below.

Retention: business contact data is kept for as long as the communication may be of interest and for a maximum of 12 months from the last contact, unless a commercial relationship exists. If you object, your address is kept indefinitely on an exclusion list for the sole purpose of not contacting you again, which is a measure necessary to honour your own objection.

Who we share it with

• Technology providers acting as processors under an Art. 28 GDPR contract: email delivery platform, database hosting and commercial management system.
• We do not sell or transfer data to third parties for their own purposes.

Transfers outside the European Economic Area

The controller is established in the United States and some providers are too, so your data is processed outside the EEA. These transfers rely on the standard contractual clauses approved by the European Commission and on any applicable supplementary measures. You may request a copy of these safeguards.

Your rights

Access, rectification, erasure, restriction, portability and objection.

Objection to direct marketing: you may object at any time and without giving reasons (Art. 21.2 GDPR). It is an absolute right: as soon as you object, we stop processing your data for that purpose, immediately and permanently.

How to exercise them

• To stop receiving communications: bajas@flapconsulting.com
• For any other right: info@flapconsulting.com

Just write to us. We do not require a form or an identity document when the email allows us to identify you with reasonable certainty.

You may also lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) if you consider that we have not addressed your request.

We use your personal data for the following purposes:

• Responding to your inquiries: answering your information requests and resolving your questions.
• Sending commercial proposals: preparing and sending personalized quotes in response to your requests.
• Commercial communications: sending newsletters, information about our services and news, provided you have given your prior consent.

The processing of your personal data is based on the following legal bases:

• User consent: by submitting the contact form, you give your explicit consent for the processing of your data for the purposes indicated.
• Legitimate interest: for sending commercial communications to clients and to those who have contacted us through the form, related to services similar to those they have requested or engaged, based on our legitimate interest as a company. The processing of business contact data obtained by other means is governed by the section «Data you did not provide to us».

You can withdraw your consent at any time by contacting us at info@flapconsulting.com.

Your personal data will be processed exclusively by Flap Agency LLC and is stored in our internal database managed through Supabase, with servers located in the European Union.

We do not share your personal data with third parties, except when legally required or when strictly necessary for the provision of the requested service, in which case we will inform you beforehand.

We do not transfer personal data to the United States or other countries outside the European Economic Area (EEA). Your data is stored and processed on servers located within the European Union, thus ensuring GDPR compliance.

We will retain your personal data for the duration of the business relationship and, once terminated, for an additional period of 5 years to address any legal responsibilities arising from the processing.

After this period, your data will be securely deleted from our systems.

In accordance with the GDPR, you have the following rights regarding your personal data:

• Right of access: to know what personal data we process about you.
• Right of rectification: to request the correction of inaccurate or incomplete data.
• Right of erasure (right to be forgotten): to request the deletion of your data when no longer necessary.
• Right to restriction of processing: to request the restriction of processing in certain circumstances.
• Right to data portability: to receive your data in a structured, commonly used format.
• Right to object: to object to the processing of your data, especially for direct marketing purposes.
• Right not to be subject to automated decisions: not to be subject to decisions based solely on automated processing.

To exercise any of these rights, you can contact us by sending an email to info@flapconsulting.com, indicating the right you wish to exercise. We do not require a form or a copy of your identity document when the email allows us to identify you with reasonable certainty.

You also have the right to file a complaint with the competent supervisory authority for data protection if you believe that the processing of your data does not comply with current regulations.

Our website uses cookies and tracking technologies to improve user experience and analyze traffic. We use the following tools:

• Google Analytics: to analyze website usage and improve our services.
• Meta Pixel (Facebook): to measure the effectiveness of our advertising campaigns.
• LinkedIn Insight Tag: for conversion tracking and remarketing.

For detailed information about the cookies we use and how to manage them, please see our Cookie Policy.

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure or destruction. These measures include:

• Data encryption in transit using HTTPS/TLS protocol
• Data encryption at rest in our database
• Strict access control to personal data
• Regular backups
• Ongoing training of our team on data protection

We reserve the right to modify this Privacy Policy at any time. Any changes will be posted on this page with the last updated date. We recommend that you periodically review this policy to stay informed about how we protect your data.

If you have any questions about this Privacy Policy or about the processing of your personal data, you can contact us at: