Privacy policy
Last updated: [FECHA DE PUBLICACIÓN]
Courtesy translation. In the event of any discrepancy, the Spanish version prevails.
This policy explains what personal data the website grupoiveluma.com collects, what it is used for and what rights you have over it.
1. Data controller
- Controller: IVELUMA S.R.L. (NIT [NIT])
- Address: Calle 88, n.º 5101, Apto. 7, between Avenida 51 and Avenida 51A, Marianao, Havana, Cuba
- Email for privacy matters: [email protected]
2. What data we collect
We only collect the data you voluntarily send us through the contact form or by email:
- Name (required).
- Email address (required).
- Message (required).
- Company and phone number (optional).
In addition, for technical and security reasons, our hosting provider logs the IP address and basic connection data of visitors to the site.
We do not use analytics, advertising or user profiling. We do not collect special categories of data; please do not include them in your message.
3. What we use your data for and on what legal basis
| Purpose | Legal basis |
|---|---|
| Replying to your enquiry or request | Your consent when submitting the form and, if you request information about our services, the taking of pre-contractual steps at your request |
| Keeping the site secure (technical logs) | Legitimate interest in protecting the website against abuse |
We do not use your data to send you advertising or for automated decision-making.
4. How long we keep it
- Enquiries: for as long as necessary to handle them and, afterwards, for a maximum of 12 months, unless a business relationship begins, in which case they will be kept for its duration and for the applicable statutory periods.
- Technical logs: the periods applied by the hosting provider, usually a few days.
5. Who we share your data with
We do not sell or transfer your data to third parties. Only the providers we need for the website and email to work have access to it; they act on our behalf and under contract:
| Provider | Service | Location |
|---|---|---|
| Cloudflare, Inc. | Website hosting and security | USA |
| Google LLC (Google Workspace) | Corporate email | USA |
We may also disclose data to the authorities when required by law.
6. International transfers
IVELUMA S.R.L. is based in Cuba and its technology providers are in the United States. Therefore, if you are in the European Union, your data will be transferred outside the European Economic Area:
- To the United States: to providers that adhere to the EU-U.S. Data Privacy Framework or that offer the standard contractual clauses approved by the European Commission.
- To Cuba: where our team reads and answers enquiries. This transfer is necessary to handle the request you send us.
7. Your rights
You may at any time exercise your rights of access, rectification, erasure, objection, restriction of processing and portability, and withdraw your consent, by writing to [email protected] with the subject “Data protection”. We will reply within one month.
If you believe we have not handled your request properly, you may lodge a complaint with the data protection authority of your country. In Spain, this is the Agencia Española de Protección de Datos (www.aepd.es).
8. Minors
This site is aimed at businesses and professionals. We do not knowingly collect data from children under 14.
9. Security
We apply reasonable technical and organisational measures to protect your data: encrypted connection (HTTPS), restricted access to corporate email and two-step verification on accounts.
10. Applicable regulations
This policy has been drafted in accordance with Law 149/2022 on Personal Data Protection of the Republic of Cuba and, for users in the European Union, Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD).
11. Changes to this policy
We may update this policy if our services or the regulations change. The current version is always the one published on this page, with its update date.