# Privacy policy

> How Gradual handles your personal data: controller, purposes, legal basis, retention, recipients and how to exercise your rights under the EU GDPR.

URL: https://gradual.pro/en/privacy

Updated: 2026-09-29

## Data controller

[RAZÓN SOCIAL], tax ID (NIF) [NIF], [DOMICILIO], Spain. Contact: empieza@gradual.pro.

We are a Spanish company and process personal data under the EU General Data Protection Regulation (GDPR) and Spanish data protection law, whichever country you visit us from.

## What data we process and why

- Assessment form data (name, email or phone and message): to reply to your request and prepare the call.
- Email and results from the free tools: to send you the report you asked for.
- Aggregated browsing data, collected without cookies (Cloudflare Web Analytics): to know which pages are visited.

## Legal basis

Your consent when you submit the form and, where a commercial relationship exists, performance of the contract.

## Retention

We keep contact data for as long as the relationship lasts and, at most, 24 months after the last contact if no relationship follows.

## Recipients

We do not sell or share your data with third parties. We use providers acting as data processors: Cloudflare (hosting), Resend (email delivery) and Cal.com (call booking), with appropriate safeguards for international transfers.

## Your rights

You can exercise your rights of access, rectification, erasure, objection, restriction and portability by writing to empieza@gradual.pro. If you believe we have not handled your request properly, you can lodge a complaint with the Spanish Data Protection Agency (aepd.es) or with the supervisory authority in your own country.
