Privacy Policy

Last updated: August 2026. This English version is provided for convenience; the Spanish version is the original legal text.

1. Data controller

In accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD), the controller of your personal data is María del Carmen Gurruchaga, trading as Pin Flow Lab, Antziola 30, Hernani, Spain. Contact: info@pinflowlab.com.

2. Data we collect

Depending on how you interact with Pin Flow Lab, we may process:

3. Purposes

We use data only for purposes connected to the action you take: delivering a requested diagnosis, managing an email-course subscription and related communications, receiving and responding to service applications, handling privacy or unsubscribe requests, complying with legal obligations and maintaining the security and operation of the website.

Completing the free diagnosis does not by itself automatically enrol you in the marketing list for the mini-course.

4. Legal bases

5. Retention

We retain data only for as long as necessary for the purpose for which it was collected and, where relevant, for periods required by law. Diagnosis recipients may temporarily appear in transactional email logs. Audit and workflow applications are received in the Pin Flow Lab mailbox. Mini-course data is kept while the subscription remains active or until you unsubscribe, subject to any minimum records required for legal or security purposes.

6. Service providers

We use technology providers that may process data on behalf of Pin Flow Lab:

We do not sell your personal data or provide it to third parties for their own commercial use.

7. International transfers

Some providers may deliver part of their services from outside the European Economic Area. Where an international transfer occurs, safeguards required by the GDPR will be used, such as adequacy decisions, the Data Privacy Framework where applicable, or Standard Contractual Clauses approved by the European Commission.

8. Your rights

You may request access, rectification, erasure, objection, restriction, portability where applicable, and withdrawal of consent at any time for processing based on consent. To exercise your rights, email info@pinflowlab.com and clearly state the right you wish to exercise.

If you believe processing does not comply with data-protection law, you may lodge a complaint with the Spanish Data Protection Agency (AEPD).

9. Changes

This policy may be updated when Pin Flow Lab features, providers or legal obligations change. The version published on this page is the current version.