Privacy Policy

This Privacy Policy explains how Kevin Gowan, operating as a Sole Proprietor in Spain, collects, uses, discloses, and protects your personal data when you visit and interact with [YourWebsite.com] (the “Website”). This Website is built with WordPress and hosted by Strato AG. It also uses Google Analytics. This Privacy Policy complies with the EU General Data Protection Regulation (GDPR) and Spanish data protection law (LOPDGDD).

1. Data Controller

Name: Kevin Gowan
Business Type: Sole Proprietor (Autónomo)
Address: Calle Hierbabuena 5 La Zubia, Granada 18140
Email: info@true-vantage.com
Phone: +34 618908897

 

2. What Data We Collect

We may collect the following personal data:

  • Contact Information: Name, email address, phone number (if provided via contact forms).

  • Technical and Usage Data: IP address, browser type, operating system, pages visited, session duration, referring URLs.

  • Cookies and Tracking Data: Collected via tools such as Google Analytics and WordPress plugins.

 

3. Hosting and CMS Information

This website is hosted by:

Strato AG
Paseo de la Castellana 95, 28ª planta
28046 Madrid, Spain
https://www.strato.es/

All data is stored on servers located within the European Union. Strato AG acts as a data processor under a Data Processing Agreement (DPA) in accordance with Article 28 GDPR.

The Website is built using WordPress, which may store cookies and metadata locally for functionality, security, and performance.

 

4. Use of Google Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited (“Google”), to analyze how users interact with our Website. Google Analytics uses cookies to collect information such as:

  • IP address (anonymized)

  • Pages visited

  • Time spent on pages

  • User behavior patterns

IP Anonymization: We use Google Analytics with IP anonymization enabled (_anonymizeIp()), so that your IP address is truncated within the EU/EEA.

Legal Basis: Your data is processed based on your consent (Art. 6(1)(a) GDPR), which you give via the cookie banner when first visiting the site.

Opt-Out: You can opt out of Google Analytics tracking by:

Data Sharing: Google may share data with third parties where required by law or where those third parties process data on Google’s behalf. For more information, see Google’s privacy policy: https://policies.google.com/privacy

 

5. Purposes of Processing

We process your data to:

  • Operate and maintain the Website

  • Respond to your inquiries or messages

  • Improve Website performance and user experience

  • Analyze Website usage (via Google Analytics)

  • Comply with legal obligations

 

6. Legal Bases for Processing

We rely on the following legal bases under the GDPR:

  • Consent (Art. 6(1)(a)) – for analytics and non-essential cookies

  • Contractual necessity (Art. 6(1)(b)) – for contact forms or service provision

  • Legal obligation (Art. 6(1)(c))

  • Legitimate interests (Art. 6(1)(f)) – for website security and administration

 

7. Cookies

Our Website uses cookies to:

  • Provide essential website functionality

  • Analyze website traffic via Google Analytics

  • Improve performance and usability

For more information, please refer to our separate Cookie Policy.

8. Data Retention

We retain your personal data only as long as necessary for the purposes outlined or as required by law. Analytics data is retained for [e.g. 14 months] before automatic deletion.

 

9. Data Sharing

We do not sell or rent your personal data. We may share it with:

  • Strato AG (our hosting provider)

  • Google (for analytics, with anonymization)

  • Legal authorities if required

All third-party services used comply with the GDPR.

 

10. International Data Transfers

Google Analytics may transfer anonymized data outside the EU. Google relies on Standard Contractual Clauses (SCCs) and other appropriate safeguards.

 

11. Your Data Protection Rights

Under GDPR, you may:

  • Request access to your personal data

  • Request rectification or deletion

  • Request restriction of processing

  • Object to data processing

  • Request data portability

  • Withdraw consent at any time

To exercise any of these rights, contact us at: info@true-vantage.com

You also have the right to lodge a complaint with the Spanish Data Protection Authority (AEPD): https://www.aepd.es

 

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will always be posted on this page with the revised effective date.