Privacy Policy
Last updated: March 18, 2026
1. Data Controller
In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (GDPR), we inform you that the contact details of the data controller are:
- Name: Raúl Torner Martinell
- Email: hola@tornem.net
- Tax ID (NIF): 20476900-T
- Address: Avda. Fco. Baila Tosca, 69. 12500, Vinaròs, Castellón (Spain)
- Website: https://tornem.net
2. Purposes of Processing
We collect, process, and store personal information from users for the following purposes:
2.1 Contact Form
When you complete the contact form available on our website, we collect your data with the main objective of:
- Responding to your inquiry or request for information
- Establishing commercial communication related to our services
- Maintaining a record of communication for archival and follow-up purposes
2.2 Google Analytics
We use Google Analytics to:
- Analyze website usage and user behavior
- Improve user experience and the quality of our services
- Obtain statistics and metrics about traffic and content interaction
3. Data Collected
Depending on your interaction with our website, we may collect the following personal data:
3.1 Contact Form
- Full name
- Surnames
- Email address
- Phone number
- Inquiry or subject of the request
- GDPR consent (checkbox accepting this policy)
3.2 Website Navigation
When you browse our website, we collect information about:
- IP address
- Operating system and browser used
- Pages visited
- Duration of visit
- Referrers (websites from which you accessed our site)
This information is collected in anonymized form through Google Analytics.
4. Legal Basis
The processing of your data is based on:
- Contract execution or pre-contractual measures: When you complete the contact form and request information about our services.
- Consent: You have given your explicit consent by accepting this privacy policy on our website.
- Legitimate interest: Analyzing website usage and improving our services (Google Analytics).
5. Data Recipients
Your personal data may be shared with the following recipients:
5.1 Service Providers
- Hostinger (hosting and email): Provider that hosts our website and manages our email services. Your data is stored on Hostinger servers within the EU.
5.2 Analytics Tools
- Google Analytics: Google, Inc. (or Google Ireland Limited depending on your location) will use the data to analyze user behavior. Data is transferred to Google servers in the United States. You can review Google’s privacy policy at https://policies.google.com/privacy.
5.3 Anti-Bot Protection
- Cloudflare Turnstile: Used to protect the contact form against bots and unauthorized access. You can review Cloudflare’s privacy policy at https://www.cloudflare.com/privacypolicy/.
Important: These third parties act as data processors and undertake to process your data only according to our instructions and in accordance with this policy.
6. International Transfers
Some of your data may be transferred outside the European Economic Area (EEA), specifically to the United States, in the case of:
- Google Analytics: Google America, Inc. processes data on its US-based servers. We have in place Standard Contractual Clauses (SCC) as required by the GDPR to ensure an adequate level of protection.
7. Data Retention Period
Your personal data will be retained for as long as necessary to fulfill the purposes specified in this policy:
- Contact form: Data will be retained for a period of 3 years from the last contact, or until you request deletion.
- Google Analytics: Data will be retained in accordance with Google Analytics’ retention policy (default: 14 months from the last event).
After this period, your data will be deleted or anonymized, unless the law requires otherwise.
8. User Rights
In accordance with Articles 15 to 22 of the GDPR, you have the right to:
- Right of access: Request access to the personal data we have collected about you.
- Right to rectification: Request correction of inaccurate or incomplete data.
- Right to erasure: Request deletion of your personal data (“right to be forgotten”).
- Right to restrict processing: Request that we limit the use of your data.
- Right to data portability: Request that your data be transferred to another data controller in a structured, commonly used, and machine-readable format.
- Right to object: Object to the processing of your personal data.
- Right not to be subject to automated decision-making: Not to be subject to decisions based solely on automated processing that produce legal effects or significantly affect you.
To exercise any of these rights, you can submit a request via email to hola@tornem.net with a copy of your identity document.
9. Data Security
We have implemented appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction, including:
- Secure storage on protected servers
- Use of encryption in data transmission (HTTPS)
- Restricted access to authorized personnel only
- Privacy and security policies for third-party providers
However, no security system is impenetrable. We recommend that you keep your passwords secure and do not share sensitive personal information through unsecured channels.
10. Changes to this Policy
We reserve the right to modify this privacy policy at any time. Changes will take effect immediately upon publication on our website. We recommend that you review this policy periodically to stay informed about how we protect your personal data.
11. Complaints to the Supervisory Authority
If you believe that the processing of your personal data violates your rights under the GDPR, you may lodge a complaint with the competent supervisory authority:
- Supervisory Authority (Spain): Spanish Data Protection Authority (AEPD)
- Website: https://www.aepd.es
- Email: avpd@aepd.es
- Phone: +34 912 663 517
12. Contact
If you have questions about this privacy policy or wish to exercise your rights, you can contact us at:
- Email: hola@tornem.net
- Website: https://tornem.net