Privacy policy for clients

Last updated: 14 October 2026

Español

This policy explains how I process the personal data of clients and prospects when preparing proposals, signing contracts and invoicing. The policy for the pepaguilo.com website is published there.

Controller

Jose Alberto Aguilo Escamez, self-employed Salesforce Marketing Cloud consultant, based in Palma de Mallorca. Contact: pep@aguilo.cloud.

Data I process

Purposes and legal basis

Retention

Processors

These providers process data on my behalf, only to provide their service to me, under a data processing agreement (Article 28 GDPR) except where noted below the table:

ProviderEntityDataLocationTransfer
VercelVercel Inc. (US)Requests and data in transit for proposals, signing and internal accountingEU (Dublin)standard contractual clauses (to the US)
UpstashUpstash, Inc. (US)Prospects, proposals and signature dataEU (Ireland)the EU-US Data Privacy Framework and standard contractual clauses (to the US)
CloudflareCloudflare, Inc. (US)Encrypted backups of the proposal and signature databaseEUthe EU-US Data Privacy Framework and standard contractual clauses (to the US)
GitHubGitHub, Inc. (US)The backup during the seconds it takes to encrypt itUSthe EU-US Data Privacy Framework and standard contractual clauses (to the US)
HoldedHolded Technologies S.L. (Spain)Client company tax details, pro forma invoices and invoicesEUNo transfer
SupabaseSupabase Pte. Ltd. (Singapore)Invoices, payments and expensesEU (Ireland)standard contractual clauses (to Singapore)
Toggl TrackToggl OÜ (Estonia)Hours spent per client and projectEUNo transfer
ResendPlus Five Five, Inc. (US)Notice of each signature, with the signer's detailsUSthe EU-US Data Privacy Framework and standard contractual clauses (to the US)
Google WorkspaceGoogle Ireland Limited (Ireland)Client emails, contracts and invoicesEU and USthe EU-US Data Privacy Framework and standard contractual clauses (to the US)
AnthropicAnthropic Ireland, Limited (Ireland)Company, contact person and context of prospects, and invoices in internal accounting. Never the signer's detailsUSstandard contractual clauses (to the US)

GitHub, Inc. (US) has no data processing agreement under Article 28 GDPR: it processes the data under its terms of service and privacy statement, relying on the EU-US Data Privacy Framework and standard contractual clauses, and only for processing backups for a few seconds before they are encrypted.

International transfers

Some processors are established outside the European Economic Area or access the data from there, which is an international transfer: Vercel, Upstash, Cloudflare, GitHub, Resend, Google Workspace and Anthropic to the US; Supabase to Singapore. These transfers rely on the standard contractual clauses approved by the European Commission (Article 46(2)(c) GDPR) and, for Upstash, Cloudflare, GitHub, Resend and Google Workspace, also on the Commission's adequacy decision on the EU-US Data Privacy Framework.

Disclosures

I do not disclose your data to third parties unless required by law (for example, to the Spanish Tax Agency).

Your rights

You can exercise your rights of access, rectification, erasure, objection, portability and restriction by writing to pep@aguilo.cloud. If you are not satisfied with the answer, you can lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).