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Privacy Policy

1. Data controller

Beluga Linguistics, S.L. ("BELUGA"), Tax ID (NIF) B84621457. Registered office: C/ Mayor 61, 05515 La Almohalla (Piedrahíta), Ávila, Spain. Based in: C. de Ríos Rosas, 42, 28003 Madrid, Spain. Registered in the Commercial Registry of Ávila (Registro Mercantil de Ávila), Volume 189, Book 147, Folio 162, Section 8, Sheet AV-7536. Data protection contact: privacy@belugalinguistics.com.

BELUGA has not appointed a Data Protection Officer because it is not required to under Article 37 GDPR or Article 34 of Spanish Organic Law 3/2018 (LOPDGDD). For any data protection matter, write to privacy@belugalinguistics.com.

This Privacy Policy explains how we process the personal data of people who visit https://belugalinguistics.com (the "Website"), contact us, or subscribe to our communications.

2. Purposes, legal bases and retention periods

a) Enquiries and quote requests (contact forms, e-mail).
Data: name, e-mail, company, position, country, message and any information you send us.
Purpose: to answer your enquiry and, where applicable, prepare a quote.
Legal basis: taking steps at your request prior to entering into a contract (art. 6.1.b GDPR) and, for general enquiries, our legitimate interest in answering them (art. 6.1.f GDPR).
Retention: while we handle your enquiry and for up to 12 months after our last contact if no contract follows. If you become a client, section (b) applies.

b) Clients and suppliers (contact persons).
Data: identification and professional contact details of the people who work for our clients and suppliers, and billing data.
Purpose: to manage the contractual relationship, invoicing and accounting.
Legal basis: performance of the contract (art. 6.1.b GDPR); legitimate interest in keeping professional contact data (art. 6.1.f GDPR and art. 19 LOPDGDD); compliance with legal obligations (art. 6.1.c GDPR).
Retention: for the duration of the relationship and then for 6 years (art. 30 of the Spanish Commercial Code), which covers the 4-year tax limitation period (art. 66 of the General Tax Law). During that time the data are blocked (art. 32 LOPDGDD) and only used to meet legal obligations or to deal with claims.

c) Linguists and job applicants (form "Join our team" / linguist registration).
Data: identification data, CV, languages, professional background and rates.
Purpose: to include you in our selection processes for current and future projects and positions.
Legal basis: your consent (art. 6.1.a GDPR), which you can withdraw at any time.
Retention: 12 months from receipt, unless you withdraw consent earlier or a collaboration begins.

d) Newsletter and commercial communications.
Data: name and e-mail.
Purpose: to send you news, content and information about our services by e-mail.
Legal basis: your consent (art. 6.1.a GDPR and art. 21 of Spanish Law 34/2002, LSSI).
Retention: until you unsubscribe (link in every e-mail or by writing to privacy@belugalinguistics.com). Afterwards, your data are blocked for 3 years to deal with possible liabilities and then deleted. Contacts who have not interacted with any of our communications for 24 months are deleted.

e) Web analytics and campaign measurement (cookies).
Data: online identifiers, IP address, device and browser data, pages visited, and, if you fill in a form, the link between your browsing on the Website and your contact record in our CRM.
Purpose: to measure and improve the use of the Website and to measure our LinkedIn campaigns.
Legal basis: your consent (art. 6.1.a GDPR and art. 22.2 LSSI), given through the cookie banner.
Retention: according to the durations in our Cookie Policy. Google Analytics event data are kept for up to 14 months.
Google Analytics 4 uses Google Consent Mode. If you do not consent to analytics cookies, Google Analytics does not store cookies on your device, but it may receive cookieless signals without identifiers (for example, that a page was viewed) to produce aggregated statistics.

f) B2B prospecting.
When BELUGA contacts professionals whose data we did not obtain from them (for example from LinkedIn or professional databases):
Data: name, position, company, professional e-mail.
Source: professional social networks (such as LinkedIn) and professional databases.
Purpose: to offer our services to companies whose activity may need them.
Legal basis: legitimate interest (art. 6.1.f GDPR; recital 47). You can object at any time.
Retention: up to 12 months without a reply, then deleted.

Providing the data marked as mandatory in each form is necessary to deal with your request; if you do not provide them, we cannot deal with it. We do not make decisions based solely on automated processing, including profiling, that produce legal effects on you or similarly significantly affect you.

3. Recipients

We do not sell your data. We share data only with:

  • Service providers (processors) who act on our behalf under a data processing agreement: HubSpot, Inc. (CRM, forms, e-mail and website hosting, with Cloudflare, Inc. as content delivery network); Google Ireland Limited / Google LLC (Google Workspace e-mail and storage, Google Analytics 4).
  • LinkedIn Ireland Unlimited Company, which receives data through the LinkedIn Insight Tag only if you consent to marketing cookies, and processes them as an independent controller under its privacy policy (https://www.linkedin.com/legal/privacy-policy).
  • Google (YouTube), when you play an embedded video, under Google's privacy policy (https://policies.google.com/privacy).
  • Public authorities, courts and tax authorities, when required by law.

4. International transfers

Some of these providers, or companies of their group, process data in the United States. These transfers rely on:

  • the European Commission's adequacy decision for the EU-U.S. Data Privacy Framework (Implementing Decision (EU) 2023/1795 of 10 July 2023), for organisations certified under it: HubSpot, Inc., Google LLC and LinkedIn Corporation are listed as active participants at https://www.dataprivacyframework.gov; and
  • where the Framework does not apply, the Standard Contractual Clauses approved by the European Commission (Implementing Decision (EU) 2021/914), included in each provider's data processing terms.

You can request more information about these safeguards at privacy@belugalinguistics.com.

5. Your rights

You can exercise your rights of access, rectification, erasure, objection, restriction of processing and data portability, and withdraw any consent you have given at any time, by writing to privacy@belugalinguistics.com or by post to C. de Ríos Rosas, 42, 28003 Madrid, Spain, with the subject "Data Protection". If we have reasonable doubts about your identity, we may ask you for additional information to confirm it. We will reply within one month, which may be extended by two further months in complex cases.

If you consider that your rights have not been respected, you can lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, C/ Jorge Juan 6, 28001 Madrid, https://www.aepd.es).

6. Minors

The Website is aimed at businesses and professionals and is not intended for persons under 14. We do not knowingly collect their data.

7. Security

We apply appropriate technical and organisational measures to protect personal data, within the framework of our ISO/IEC 27001 information security management system.

8. Changes

We may update this Privacy Policy to reflect legal or operational changes. We will publish any new version on this page. If changes are significant, we will inform you by appropriate means.

9. Language

This Privacy Policy is available in Spanish and English. In case of discrepancy, the Spanish version prevails.