Madariaga SAS ("Madariaga", "we", "us") operates the website madariaga.com.ar and is responsible for the processing of personal data collected through it. This Policy describes what data we collect, how we use it, and what your rights are.
This policy complies with Argentine Personal Data Protection Law 25.326 and is compatible with the General Data Protection Regulation (GDPR, EU 2016/679) for users located in the European Economic Area.
1. Data Controller
2. Data We Collect
We collect only data that you actively provide to us:
- Contact form: name, email, company, what you need, the message and, if you wish, timing and a reference budget. We also keep the page you arrived from (for example, a link with UTM parameters) to learn which channel works.
- Technical debt checklist: we record the page visit as an aggregated Umami event. We do not request personal data to access the resource.
- Meeting booking: the data you enter in the scheduler (Cal.com): name, email, company and what you want to discuss.
- Direct communications: if you email or message us on WhatsApp, we retain that correspondence.
We do not collect sensitive data (health, political views, religion, ethnic origin, etc.). We do not intentionally collect data from individuals under 16 years of age.
We measure visits with Umami, an analytics service that uses no cookies and does not store your IP address. It records, in aggregate, which pages are visited, the country, the device type and the browser, and clicks on buttons such as "Book 20 min". It does not build individual profiles and it respects your browser's "Do Not Track" signal.
The form uses Cloudflare Turnstile to tell people from automated programs. Turnstile analyzes technical browser signals (for example, the IP address) only for that check.
3. Purpose and Legal Basis for Processing
| Purpose | Legal basis (AR Law 25.326) | Legal basis (GDPR) |
|---|---|---|
| Responding to your inquiry or contact message | Data subject consent (art. 5) | Legitimate interest / contract performance (art. 6.1.b) |
| Statistical web traffic analysis (Umami, cookie-free) | Legitimate interest | Legitimate interest (art. 6.1.f) |
| Preventing automated form submissions (anti-spam) | Legitimate interest | Legitimate interest (art. 6.1.f) |
| Compliance with legal obligations | Legal obligation | Legal obligation (art. 6.1.c) |
Commercial communications: we do not send newsletters or periodic promotional emails. You can ask us to delete your data at any time by writing to hola@madariaga.com.ar.
4. Data Retention
- Contact inquiries: up to 2 years from the last communication, unless an active business relationship exists.
- Analytics data: aggregated and free of personal data.
5. International Data Transfers
- Google (Google LLC, USA): we store inquiries in a Google spreadsheet. Google is certified under the EU-US Data Privacy Framework.
- Cal.com (Cal.com, Inc., USA): meeting scheduler. It processes the data you enter when booking and sends the confirmations.
- Cloudflare, Inc. (USA): anti-spam verification of the form (Turnstile).
- Email provider (SMTP): messages are sent via our configured SMTP provider, which may process data on servers outside Argentina.
- Umami (analytics): processes aggregated data that does not identify you.
In all cases, we require recipients to provide protection equivalent to that required under Law 25.326 and, where applicable, the GDPR.
6. Your Rights
- Access: request what data we hold about you.
- Rectification: correct inaccurate or incomplete data.
- Erasure ("right to be forgotten"): request deletion of your data when it is no longer necessary.
- Objection: object to processing based on legitimate interest.
- Portability (GDPR): receive your data in a structured, machine-readable format.
- Restriction (GDPR): request that we restrict processing in certain circumstances.
- Withdrawal of consent: at any time, without retroactive effect.
To exercise any of these rights, contact us at hola@madariaga.com.ar. We will respond within 30 business days. If you believe your request was not handled correctly, you may lodge a complaint with the Agencia de Acceso a la Información Pública (AAIP) of Argentina, or if you are in the EU, with your local data protection authority.
7. Cookies
This site does not use analytics or marketing cookies, which is why it shows no cookie banner. To remember which page you arrived from until you send an inquiry, it uses the browser's session storage, which is cleared when you close the tab. The anti-spam service (Turnstile) may use technical browser storage for its check. You can clear that storage from your browser settings.
8. Security
We implement reasonable technical and organizational measures to protect your data against unauthorized access, loss, or disclosure. Communication with our site uses HTTPS/TLS encryption. However, no internet transmission system is 100% secure.
9. Changes to This Policy
We may update this policy periodically. When we do, we will update the "last updated" date at the top of this page. We recommend reviewing it occasionally. Material changes will be communicated by email if we have your address.
10. Contact
Madariaga SAS
Buenos Aires, Argentina
hola@madariaga.com.ar