Privacy notice

This site collects your email address if you subscribe, and whatever you choose to send in a message. It sets no cookies and runs no analytics or trackers. Reading it needs no account and no personal details.

Who is responsible

The controller, meaning the person who decides how your data is used, is Zaro Gonzalez, an individual in Madrid, Spain, who writes and publishes this site under the name Valtor Partners. Valtor Partners is a publishing name, not a company. There is no data protection officer. For anything in this notice, write to zaro@valtorpartners.com.

What is collected, and why

If you subscribe by email

What

Your email address. The form sends nothing else.

Why

To send you new analysis and notes, at most once a week. It is used for nothing else.

Legal basis

Your consent (GDPR article 6(1)(a)), given when you submit the form.

Kept

Until you unsubscribe or the list is closed, then deleted.

If you write in

What

Through the contact form: your name, email address, organisation if you give one, and your message. By email: whatever you send.

Why

To read and answer you, and to correct published work when you point out an error.

Legal basis

Legitimate interest (article 6(1)(f)) in answering people who write and in fixing mistakes.

Kept

Up to two years after the last exchange, then deleted. A message that led to a published correction may be kept as the record of that correction.

A correction is credited to the person who reported it only if they ask to be named.

Technical records, for every visitor

What

Netlify, which hosts the site, logs each request: IP address, browser type, the page asked for, the referring page and the time. It also records the sender's IP address with each form submission.

Why

To deliver the site, keep it secure and filter spam out of the forms.

Legal basis

Legitimate interest (article 6(1)(f)) in running a site that works and is secure. These records are not used to identify or follow readers.

Kept

For periods Netlify sets. Its data processing agreement gives 90 days for logs held online and one year for archived logs.

Nothing on this site makes automated decisions about you or builds a profile of you.

Who handles it

Netlify, Inc., of San Francisco, hosts the site, keeps its logs and stores what the forms send. It acts as a processor: under its data processing agreement it may use the data only to provide its service, not for its own purposes. Netlify relies on sub-processors of its own, among them Amazon Web Services and Google Cloud for infrastructure and Akismet, run by Automattic, Inc., to filter spam from form submissions. Netlify publishes the full list.

Spacemail, the email service of Spaceship, Inc., hosts the mailbox behind zaro@valtorpartners.com, so it holds the emails you send to that address.

No mailing-list service is used. If one is ever added, it will be named here before it receives a single address. Nothing is sold or shared with anyone else, unless a court or authority lawfully requires it.

Where it goes

Netlify and the sub-processors named above are in the United States, so the data described here leaves the European Union. Netlify is certified under the EU–US Data Privacy Framework, which the European Commission found to give adequate protection in its decision of 10 July 2023. If that framework stops applying, Netlify's agreement falls back on the Commission's standard contractual clauses.

Your rights

You can ask for a copy of the data held about you, and have it corrected or deleted. You can ask for its use to be restricted, object to its use, and have it in a portable form. Where you gave consent, you can withdraw it at any time; that does not affect what was done before.

To do any of this, write to zaro@valtorpartners.com, if you can from the address concerned. There is no form to fill in and no charge. You will have an answer within one month.

If you think your data has been mishandled, you can complain to the Spanish data protection authority, the Agencia Española de Protección de Datos, or to the authority in the EU country where you live or work.

Unsubscribing

Reply to any of the emails, or write to zaro@valtorpartners.com, and say you want to stop. One message is enough. Your address is taken off the list and deleted from Netlify's form records as soon as the message is read, and within a month at most.

Cookies and trackers

There are none. The site sets no cookies, runs no analytics, and carries no advertising, social-media buttons or tracking scripts, which is why there is no cookie banner.

Every file a page needs, including its typefaces, is served from this site, so reading it sends no request to anyone else.

Links to sources lead to other sites, which have their own privacy practices.

Changes

If what the site collects changes, this page changes first, and the date at the top with it.