Privacy policy

Version 1.3 · effective from 20 October 2026

1. Data controller

Iuliia Medynskaia, self-employed (trabajadora autónoma), NIE Y9629280E, registered address: C/ Del Abeto 10/2, 46190 Riba-roja de Túria, Valencia, Spain. Contact for data protection matters: sunclubbusiness@gmail.com.

2. What data we process and why

Through the form on this site we collect your name, contact details (telephone, WhatsApp or email) and, if you choose to add one, a free-text description of your business. We use these details to respond to your enquiry about appearing in the magazine and to prepare a proposal for you (legal basis: Art. 6(1)(b) GDPR – steps taken at your request prior to entering into a contract).

If you tick the optional communications box, we will use your contact details to send you news and offers (legal basis: your consent, Art. 6(1)(a) GDPR). Ticking this box is entirely optional and does not affect how we deal with your enquiry.

Alongside your enquiry we record the date, time, IP address and the version of the consent wording shown to you, so that we can demonstrate consent (Art. 7 GDPR).

3. Cookies and statistics

We keep our own anonymised visit statistics (page, referrer, language); these involve no cookies, and your IP address is not stored with them.

Only if you click “Accept” in the banner is Google Analytics 4 turned on. It sets the cookies _ga and _ga_… for up to 2 years, and visit data are processed by Google Ireland Limited and Google LLC (USA). The legal basis is your consent (Art. 6(1)(a) GDPR). Until you click “Accept”, not a single request is sent to Google. The Meta (Facebook, Instagram) advertising tag is not active on this site. If we turn it on, it will also run only with your consent, and we will update this policy beforehand.

“Accept” also turns on Google Ads, the tool we use to advertise SunClub on Google. It remembers that you visited the site so that we can show you our ads in Google Search, on YouTube and on Google partner sites, and it measures how many enquiries come from advertising. It sets the cookie _gcl_au (up to 90 days), and Google may add its own on its domains (for example IDE and NID, up to 13 months). Data are processed by Google Ireland Limited and Google LLC (USA). The legal basis is your consent (Art. 6(1)(a) GDPR).

The same “Accept” button turns on Microsoft Clarity, which shows us how the site is read: heatmaps of clicks and scrolling and recordings of visits (how a page is scrolled and where people click). What you type into form fields is not recorded. Clarity sets the cookies _clck (up to 1 year) and _clsk (1 day), and Microsoft may add its own MUID and CLID (up to 1 year). Data are processed by Microsoft Ireland Operations Limited and Microsoft Corporation (USA). The legal basis is the same: your consent (Art. 6(1)(a) GDPR). Until you click “Accept”, not a single request is sent to Microsoft.

You can withdraw consent at any time with the “Cookie settings” link at the bottom of every page. Only the internal administration panel uses a single technical cookie.

4. Recipients

Data are stored on servers operated by Hetzner Online GmbH (Germany, EU) under a data processing agreement (DPA). If you have clicked “Accept”, Google (Analytics and Ads) and Microsoft (Clarity) receive visit data, including in the USA, under the EU-U.S. Data Privacy Framework. Apart from that, no transfers take place outside the EU. We do not sell or pass your data to third parties for their own purposes.

5. Retention period

Enquiries are kept for 24 months after our last contact with you and are then deleted or anonymised. Data used for communications are kept until you withdraw your consent.

6. Your rights

• to access your data and obtain a copy;
• to rectify inaccurate data;
• to have your data erased (the ‘right to be forgotten’);
• to restrict processing, or to object to it;
• to data portability;
• to withdraw consent at any time (without retroactive effect).

Write to sunclubbusiness@gmail.com – we will respond within one month. You may also lodge a complaint with the Spanish supervisory authority, the Agencia Española de Protección de Datos (www.aepd.es).

7. What information is required

We need your name and contact details to respond to your enquiry; without them the form cannot be submitted. Everything else is optional.

8. Consent wording

Consent to processing (v1.0): ‘I consent to the processing of my personal data – privacy policy’.
Consent to communications (v1.0): ‘I would like to receive news and offers from the magazine’.