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Privacy Policy

Last updated: 27 April 2026

This Privacy Policy describes how Magic Clusters ("we", "the Controller") collects, uses and protects personal data gathered through the website magic-clusters.com and related services, in compliance with the European Union General Data Protection Regulation 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD).

1 · Data Controller

Trade name: Magic Clusters

Sole proprietor (autónoma): M.L. Asprilla A.

Location: Madrid, Spain

Contact email: info@magic-clusters.com

Website: magic-clusters.com

Data Protection Officer (DPO): no DPO has been appointed since the conditions of Art. 37 GDPR do not apply. For any data-protection query, contact info@magic-clusters.com directly.

The Spanish Tax ID and full registered address are included on every issued invoice and are available on formal request by email.

2 · Data we collect

2.1 Contact form data

Name
Email
Product of interest
Message (optional)

2.2 Customer data (subscribers)

Account email
Billing data (handled by Stripe; we do not store card numbers on our servers)
Subscription and payment history (handled by Stripe)

2.3 Automatic technical data

IP address and user-agent (server logs, 30-day retention)
Anonymised analytics from Google Analytics (ID G-TW47RGH0LD)
reCAPTCHA v3 token for anti-spam
Functional cookies (session, language preference)

2.4 Data we do NOT collect

We do not knowingly collect data from minors.
We do not sell personal data to third parties.
We do not engage in cross-context behavioural advertising.

3 · Purpose and legal basis

Handling enquiries (contact form): consent given when submitting the form.
Service provision (subscriptions): performance of contract.
Billing and tax obligations: compliance with legal obligations.
Site analytics: legitimate interest in service improvement (anonymised aggregated data).
Marketing communications: only with explicit opt-in, revocable at any time.

4 · Data processors (third parties)

We share strictly necessary data with the following providers, all under signed contracts and GDPR-equivalent safeguards:

Cloudflare, Inc. (USA) — hosting (Cloudflare Pages), CDN, WAF, Email Routing, DNS.
Stripe Payments Europe, Ltd. (Ireland) and Stripe, Inc. (USA) — payment processing and billing.
Google LLC (USA) — anonymised Analytics, reCAPTCHA v3, Gmail SMTP for outgoing domain email.
Formspree, Inc. (USA) — contact form delivery.

5 · Data retention

Contact-form data: 12 months from last interaction unless converted into a contractual relationship.
Customer data: during the term of the subscription plus statutory periods after cancellation (6 years under Spanish Commerce Code; 4 years under Spanish General Tax Law).
Server / technical logs: 30 days.
Analytics data: aggregated and anonymised, no individual retention.

6 · Your rights

Under GDPR and LOPDGDD you have the right to:

Access your data
Rectify inaccurate data
Erasure ("right to be forgotten")
Restrict processing
Object to processing
Data portability
Withdraw consent at any time
Not be subject to automated decisions with legal effects

Automated decision-making and profiling: Magic Clusters does not carry out profiling or automated decision-making producing legal effects on the user or similarly significant effects (Art. 22 GDPR). Analytics cookies (Google Analytics) process aggregated, anonymised data only, with no individual profiling.

To exercise any of these rights, email info@magic-clusters.com stating the right exercised and attaching a copy of an identity document. We will respond within one month.

If you believe processing does not comply with regulations, you may file a complaint with the Spanish Data Protection Agency (www.aepd.es) or your local data protection authority.

7 · Cookies

Magic Clusters uses strictly necessary cookies for site operation (session, language preference) and third-party cookies for analytics (Google Analytics with anonymised IP) and anti-spam (Google reCAPTCHA v3). You can manage your consent from the site banner or re-open it at any time. More detail in the Cookies Policy.

8 · International transfers

Some of our processors (Cloudflare, Stripe, Google, Formspree) are established in the United States. Such transfers are governed by the EU Standard Contractual Clauses approved by the European Commission and/or the EU-US Data Privacy Framework, ensuring a level of protection equivalent to GDPR.

9 · Security

We apply reasonable technical and organisational measures to protect personal data: HTTPS/TLS encryption in transit, two-factor authentication on all services, principle of least privilege, periodic vendor review. No system is 100% secure and we cannot guarantee absolute security.

10 · Children’s privacy

Our services are intended for adults (18 years or older). We do not knowingly collect data from minors. If you believe a minor has provided us data, contact info@magic-clusters.com and we will delete it.

11 · Changes to this Policy

We may update this Privacy Policy to reflect legislative or service changes. Updates are published on this page along with the date of last revision. Material changes will be communicated to subscribers by email when appropriate.

12 · Contact

Questions, concerns or requests regarding this Policy or your personal data: info@magic-clusters.com.