Privacy Policy

At 23HARMONY TECH SOCIEDAD LIMITADA, trading as Alcara Partners (hereinafter "Alcara Partners"), we are committed to protecting the personal data of our users and clients. This Privacy Policy describes how we collect, use and protect your personal information, in compliance with EU Regulation 2016/679 General Data Protection Regulation (GDPR) and Spanish Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).

1. Data controller

2. Purposes of processing

We process your personal data for the following purposes:

• Responding to information requests, queries and commercial proposals submitted through Website forms.
• Managing the contractual relationship with clients and providing professional services.
• Sending commercial communications about our services, content and resources, subject to prior consent or pre-existing professional relationship.
• Processing and delivering downloadable resources (friction calculator, digital journal, guides) requested by the user.
• Managing newsletter subscriptions and email sequences.
• Complying with applicable legal, accounting, tax and administrative obligations.
• Analysing Website usage through analytics tools to improve our services.

3. Legal basis

The legal basis for processing your data depends on the specific purpose:

• Consent: for sending commercial communications, newsletter subscription and resource downloads.
• Performance of a contract: for the provision of contracted professional services.
• Legitimate interest: for responding to your queries and improving our services through Website analytics.
• Compliance with legal obligations: for accounting, tax and administrative management.

4. Data we process

Depending on the case, the data we process may include:

• Identifying data: name, surname, professional title.
• Contact data: email address, phone number.
• Professional data: company name, sector, revenue, number of employees.
• Information about your company voluntarily provided in forms and requests.
• Browsing data obtained through cookies (see our Cookies Policy).

5. Retention period

Your data will be retained for the time necessary to fulfil the purpose for which it was collected and to determine any responsibilities that may arise from such purpose and the processing of the data. For commercial communications, until you withdraw your consent. In the case of a contractual relationship, for the duration of the contract and applicable legal periods (typically 6 years for tax and accounting purposes).

6. Recipients and transfers

Your data may be communicated to the following categories of recipients:

• Technology service providers (web hosting, cloud infrastructure, email marketing and CRM tools) acting as data processors.
• Tax, accounting and legal advisors for compliance with legal obligations.
• Public authorities and competent bodies, where required by current regulations.

Some of our technology providers may be located outside the European Economic Area. In such cases, we ensure that international transfers are made only to countries with an adequate level of protection or under appropriate safeguards provided for in the GDPR (standard contractual clauses approved by the European Commission).

7. Your rights

As the data subject, you have the following rights:

• Access: to know what data of yours we process.
• Rectification: to correct inaccurate or incomplete data.
• Erasure: to request the deletion of your data when it is no longer necessary.
• Restriction of processing: to limit how we use your data in certain circumstances.
• Objection: to object to the processing of your data.
• Portability: to receive your data in a structured, commonly used format.
• Withdraw consent: at any time, without affecting the lawfulness of prior processing.

To exercise any of these rights, you can contact us at contact@alcarapartners.com or by post to the address indicated in section 1, attaching a copy of your ID or equivalent document to verify your identity.

You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) if you consider that the processing of your data does not comply with current regulations: www.aepd.es.

8. Security measures

We have implemented the technical and organisational measures necessary to guarantee the security of your personal data and to prevent its alteration, loss, unauthorised processing or access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed. These measures include, among others: encryption in transit (SSL/TLS), role-based access control, periodic backups and security reviews.

9. Cookies

For more information about cookie usage on our Website, see our Cookies Policy.

10. Modifications

We reserve the right to modify this Privacy Policy to adapt it to legislative or jurisprudential changes or to professional practice. In such cases, we will announce changes with appropriate notice through the Website.