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ORDRE

FROM BUSINESS TO BRAND

FROM BARCELONA TO THE WORLD

Privacy Policy

PRIVACY POLICY

Last updated: [date]

This Privacy Policy governs the processing of personal data of individuals who visit this website, contact the ORDRE project, or subscribe to its newsletter.

1. Data Controller

Until ORDRE is formally incorporated as a legal entity, the data controller for the personal data collected through this website is:

If ORDRE is later incorporated as a company, this policy will be updated accordingly to reflect the new identity of the data controller.

2. What data we process

We may process the following categories of personal data:

  • Identification and contact data voluntarily provided by the user, such as name and email address.
  • Data sent by the user through forms, email, or other contact channels.
  • Data related to newsletter subscription.
  • Technical browsing data, such as IP address, device type, browser, or basic website usage information, where applicable.

3. Purposes of processing

Personal data may be processed for the following purposes:

  • Responding to inquiries, requests, or messages sent by the user.
  • Managing relationships with individuals interested in ORDRE’s services, content, or activities.
  • Managing newsletter subscriptions and sending newsletters.
  • Improving the operation, security, and performance of the website.
  • Complying with applicable legal obligations.

4. Legal basis for processing

The legal bases that justify the processing of personal data are:

  • The user’s consent, where the user voluntarily subscribes to the newsletter or submits personal data through forms or contact channels.
  • The application of pre-contractual measures, where the user contacts us to explore a possible professional or service-related relationship.
  • Compliance with legal obligations, where necessary.
  • Legitimate interest, where necessary to ensure website security, prevent misuse, or protect the rights and interests of the data controller, always within the limits established by applicable law.

5. Newsletter and Substack

ORDRE offers a newsletter currently managed through Substack, a publishing and email distribution platform.

When a user subscribes to the newsletter, their data — mainly their email address and, where applicable, their name — may be processed for the purpose of sending content, updates, reflections, news, and, where applicable, communications related to ORDRE’s professional activity.

The legal basis for this processing is the user’s consent, which may be withdrawn at any time through the unsubscribe link included in each communication or by contacting the data controller directly.

Substack acts as the technological provider of the newsletter. The processing of data through Substack may involve access to, hosting of, or processing of data by such provider in accordance with its own terms and privacy policy.

For more information on how Substack processes personal data, users may consult its privacy policy: [link to Substack privacy policy].

6. Recipients and service providers

As a general rule, personal data will not be disclosed to third parties, except:

  • where required by law,
  • where necessary for the provision of services by providers acting on behalf of the data controller,
  • or where the user has expressly consented to such disclosure.

Technology providers may include web hosting, email, analytics, or newsletter management services, including Substack.

7. International data transfers

Some technology providers used by this website or by the newsletter may be located outside the European Economic Area or may process data from outside that territory.

Where this occurs, the data controller will adopt the measures required under applicable law to ensure an adequate level of protection of personal data, including, where appropriate, the implementation of suitable safeguards in accordance with the GDPR.

8. Data retention period

Personal data will be retained for as long as necessary to fulfil the purpose for which it was collected and, thereafter, for the periods required by law.

In particular:

  • contact data related to inquiries or requests will be retained for as long as necessary to respond and follow up,
  • newsletter-related data will be retained for as long as the individual remains subscribed or until consent is withdrawn,
  • certain data may be retained in a blocked form for as long as legal liabilities may arise.

9. Data subject rights

Any individual has the right to:

  • access their personal data,
  • request rectification of inaccurate data,
  • request erasure when, among other reasons, the data is no longer necessary,
  • request restriction of processing,
  • object to processing in certain circumstances,
  • request data portability, where applicable,
  • withdraw consent at any time, without affecting the lawfulness of processing carried out before such withdrawal.

To exercise these rights, a request may be sent to: [contact email], specifying the right to be exercised and, where necessary, providing proof of identity.

If the individual believes their rights have not been properly addressed, they may lodge a complaint with the Spanish Data Protection Agency (AEPD) or with the competent supervisory authority in their jurisdiction.

10. Data security

The data controller adopts reasonable technical and organisational measures to protect personal data against loss, alteration, unauthorised access, or unlawful processing, taking into account the nature of the data and the associated risks.

11. Minors

This website and newsletter are not specifically directed at minors. If a minor provides personal data without the necessary authorisation from their parents or legal guardians, such parents or guardians may contact the data controller to request its deletion.

12. Changes to this policy

This Privacy Policy may be updated to reflect legal, technical, or organisational changes. In the event of any modification, the updated version will be published on this same page.