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Privacy Policy

Last updated: October 2026

This Privacy Policy governs the processing of personal data collected through the RESPAIN website by ALEKSANDR KUZMENKO (RESPAIN) in strict compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation - GDPR) and the Spanish Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).

1. Data Controller

Data Controller: ALEKSANDR KUZMENKO (RESPAIN)
Legal Status: Self-employed individual (Autónomo, Spain)
Tax Identification (NIF / NIE / VAT): ES Z3883295A (861524)
Professional Address: Calle Felipe Herrero Arias, 2, P03, 03013 Alicante, España
Direct Email: alex.kuzmenko33@gmail.com

2. Categories of Personal Data Collected

We collect and process only the minimal personal data necessary to handle your inquiries and deliver immigration advisory services:

  • Contact Information: Full name, email address, telephone number, and preferred messaging channels (e.g., WhatsApp, Telegram).
  • Inquiry Details: Selected immigration program (Spain, Austria, Poland, Hungary, or B2B Partnership) and background case details provided voluntarily by the user in web forms.
  • Technical Browsing Data: Anonymized IP addresses, device identifiers, browser type, timestamps, and server request logs required for cybersecurity and system stability.

We do not collect or request special categories of sensitive personal data (such as health, biometric, political, or religious data pursuant to Article 9 of the GDPR) through website contact forms.

3. Legal Bases and Purposes of Processing

Personal data is processed under the following lawful bases pursuant to Article 6 of the GDPR:

  • Consent (Art. 6.1.a GDPR): When you voluntarily submit a request through our consultation or partnership forms, or when you explicitly accept analytical cookies.
  • Pre-contractual Measures (Art. 6.1.b GDPR): To assess preliminary eligibility, evaluate citizenship and residency grounds, and draft personalized legal representation proposals upon your request.
  • Legal Obligations (Art. 6.1.c GDPR): To satisfy statutory bookkeeping, fiscal, tax reporting, and administrative compliance obligations under Spanish law.
  • Legitimate Interest (Art. 6.1.f GDPR): To maintain digital security, prevent automated spam, verify bot activity via Google reCAPTCHA v3, and protect server infrastructure against unauthorized access.

4. Data Retention

We retain personal information strictly for the duration required to accomplish the purposes for which it was gathered:

  • Pre-contractual Inquiries: Retained for the duration of communication and up to 12 months after the last interaction, unless formal contractual representation is initiated or consent is revoked earlier.
  • Contractual and Fiscal Documentation: If a service agreement is executed, statutory records are retained for 4 years pursuant to the Spanish General Tax Act (Ley General Tributaria) and 5 years for general contractual claims under Article 1964 of the Spanish Civil Code.
  • Analytics Data: Anonymized or aggregated in accordance with cookie expiration periods (up to 13 months).

5. Recipients and International Transfers

We do not sell, rent, or monetize your personal data. Disclosures are limited exclusively to:

  • Accredited legal counsel, sworn official translators (Traductores Jurados), and authorized case coordinators directly involved in managing your dossier under binding confidentiality obligations.
  • Technical service providers (such as secure web hosting and transactional email infrastructure) operating under Data Processing Agreements (Art. 28 GDPR).

Any potential transfer of personal data outside the European Economic Area (EEA) is carried out strictly under European Commission Standard Contractual Clauses (SCC) or with countries recognized as providing an adequate level of data protection.

6. Your Rights Under GDPR and LOPDGDD

Under European and Spanish regulations, data subjects are entitled to exercise the following rights (ARCO-POL):

  • Right of Access: Confirm whether your data is being processed and obtain a copy.
  • Right to Rectification: Request correction of inaccurate, outdated, or incomplete data.
  • Right to Erasure ("Right to be Forgotten"): Request deletion of your data when it is no longer required for initial collection purposes.
  • Right to Restriction: Request temporary restriction of processing in statutory circumstances defined by law.
  • Right to Data Portability: Receive your provided data in a structured, commonly used, machine-readable format.
  • Right to Object & Revoke Consent: Object to processing at any time and withdraw consent without affecting the lawfulness of processing based on consent prior to withdrawal.

To exercise any of these rights, please submit a written request accompanied by proof of identity to our dedicated data privacy email: alex.kuzmenko33@gmail.com or by post to our registered address in Alicante.

If you believe that your personal data has been handled in breach of current regulations, you hold the legal right to file a complaint with the competent supervisory authority: the Spanish Data Protection Agency (Agencia Española de Protección de Datos — AEPD, Calle Jorge Juan, 6, 28001 Madrid, www.aepd.es).

7. Cookie Usage

Our website employs technical cookies essential for secure navigation, as well as optional analytics cookies subject to your prior informed consent. For complete information on managing cookies, please read our Cookie Policy.