Last updated: 14 January 2026
Privacy Policy
At Initialofferingmn S.L. (‘Initialofferingmn’, ‘we’) we handle personal data with respect, under one principle: ask for the minimum, explain the maximum. This policy describes how we collect, use and protect personal data on this website, in compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Spanish Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).
1. Data controller
Controller: Initialofferingmn S.L., Tax ID B-87654321, registered office at Calle Velázquez 86, 4th floor, 28006 Madrid (Spain). Contact: privacidad@initialofferingmn.com. Registered with the Madrid Commercial Registry (Volume 38421, Folio 112, Sheet M-682341).
2. What data we process
We only process the data you choose to provide via the contact form (name, email and message), plus minimum technical data needed for the site to work (security logs, truncated IP address and, if you allow it, cookie identifiers). We do not request health data, financial data or data from minors.
3. Why we use it
We use the data exclusively to: (a) reply to your editorial enquiry; (b) keep the site operational and secure; (c) meet applicable legal obligations; (d) if you allow it via the cookie banner, measure use of the site and display ads that respect your consent.
4. Legal basis
The legal bases are: explicit consent given when sending the form or accepting cookies, legitimate interest in keeping the site secure, and compliance with legal obligations. You may withdraw consent at any time without affecting the lawfulness of previous processing.
5. How long we keep the data
Contact messages are kept for 18 months from the last interaction, unless the law requires a different period. Technical security logs are kept for 12 months. Cookie preferences are stored locally in your browser for 12 months or until you change them.
6. Who we share data with
We do not sell data. Some providers may process data on our behalf: EU-based web hosting, email service, and — only with your consent — Google measurement and advertising tools (gtag.js, Google Ads). In any case, we require processing agreements compliant with Art. 28 GDPR.
7. International transfers
When you allow measurement or advertising cookies, part of the data may be processed outside the European Economic Area, mainly in the United States, under the EU-U.S. Data Privacy Framework and the Standard Contractual Clauses approved by the European Commission.
8. Your rights
You may exercise at any time the rights of access, rectification, erasure, objection, restriction and portability by writing to privacidad@initialofferingmn.com. If you believe we have not handled your request properly, you may file a complaint with the Spanish Data Protection Agency (www.aepd.es).
9. Security
We apply reasonable technical and organisational measures: TLS encryption, access controls, backups and periodic reviews. Absolute security does not exist, but we work with criteria proportionate to the actual risk of the processing.
10. Changes to this policy
We may update this policy to reflect legal or operational changes. We recommend you review it periodically. The update date is shown at the top.