Privacy Policy

41elements
Last updated: March 2026

1. Introduction

41elements ("we", "us", or "our") is committed to protecting and respecting your privacy. This

Privacy Policy explains how we collect, use, disclose, and safeguard your personal data in

accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the

Spanish Organic Law 3/2018 on the Protection of Personal Data ("LOPDGDD").

Please read this policy carefully. By using our services,

2. Data Controller

The data controller responsible for your personal data is:

41elements

Registered address: Madrid, Spain

Email: privacy@41elements.com

If you have any questions about this policy or our data practices, please contact us at the

address above.

3. Personal Data We Collect

We may collect and process the following categories of personal data:

3.1 Data You Provide Directly

• Full name and contact details (email address, phone number)

• Company name and job title

• Billing and payment information

• Communications you send us (emails, support requests, feedback)

• Account credentials (username, password hash)

3.2 Data We Collect Automatically

• IP address and approximate geolocation

• Browser type, version, and operating system

• Pages visited, time spent, and navigation paths

• Referral source and search terms

• Device identifiers and cookie data

3.3 Data from Third Parties

• Information from analytics platforms (e.g. Google Analytics)

• Information from payment processors (e.g. Stripe)

• Social login data if you choose to authenticate via third-party providers

4. Legal Basis for Processing

We process your personal data on the following legal grounds under Article 6 GDPR:

4.1 Contractual Necessity (Art. 6(1)(b))

To provide, operate, and maintain our services as agreed under our Terms of Service,

including account management, billing, and customer support.

4.2 Legitimate Interests (Art. 6(1)(f))

To improve our products and services, prevent fraud and abuse, maintain security, and

conduct analytics — where our interests are not overridden by your rights.

4.3 Consent (Art. 6(1)(a))

For marketing communications, non-essential cookies, and any other processing where we

have asked for and received your explicit consent. You may withdraw consent at any time.

4.4 Legal Obligation (Art. 6(1)(c))

Where we are required to retain or disclose data to comply with applicable law, regulation, or

legal proceedings.

5. How We Use Your Data

We use the personal data we collect for the following purposes:

• Providing, maintaining, and improving our services and applications

• Creating and managing your user account

• Processing transactions and sending related documentation

• Communicating with you regarding your account, updates, or support requests

• Sending marketing and promotional communications (with your consent)

• Analysing usage to improve user experience and product development

• Detecting, preventing, and addressing fraud, abuse, and security incidents

• Complying with legal obligations and enforcing our Terms of Service

6. Data Sharing and Disclosure

We do not sell, rent, or trade your personal data. We may share your data with trusted third

parties in the following circumstances:

6.1 Service Providers

We engage trusted third-party companies to perform functions on our behalf, including

hosting, payment processing, analytics, and email delivery. These processors are

contractually bound to handle data only as we instruct and in compliance with GDPR.

6.2 Legal Requirements

We may disclose your data if required to do so by law, court order, or governmental

authority, or to protect the rights, property, or safety of 41elements, our users, or the public.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be

transferred to the acquiring entity. We will notify you

7. International Data Transfers

Some of our third-party service providers may be located outside the European Economic

Area (EEA). Where we transfer personal data to countries not deemed adequate by the

European Commission, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission

• Adequacy decisions for the relevant recipient country

• Binding Corporate Rules where applicable

8. Data Retention

We retain personal data only for as long as necessary for the purposes described in this

policy, or as required by law. Retention periods are determined by:

• The duration of your contractual relationship with us

• Legal obligations to retain records (e.g. tax and accounting requirements under

Spanish law — typically 5 to 7 years)

• Legitimate business needs such as resolving disputes or enforcing agreements

When data is no longer needed, we securely delete or anonymise it.

9. Your Rights Under GDPR

As a data subject, you have the following rights under the GDPR:

9.1 Right of Access (Art. 15)

You may request a copy of the personal data we hold about you and information about how

it is processed.

9.2 Right to Rectification (Art. 16)

You may request that we correct any inaccurate or incomplete personal data.

9.3 Right to Erasure (Art. 17)

You may request deletion of your personal data where it is no longer necessary for its

original purpose, where you withdraw consent, or where processing is unlawful.

9.4 Right to Restrict Processing (Art. 18)

You may request that we limit the processing of your data under certain circumstances.

9.5 Right to Data Portability (Art. 20)

You may request a structured, machine-readable copy of your personal data to transfer to

another controller.

9.6 Right to Object (Art. 21)

You may object to processing based on legitimate interests or for direct marketing purposes,

at any time.

9.7 Rights Related to Automated Decision-Making (Art. 22)

You have the right not to be subject to solely automated decisions that produce significant

legal or similarly significant effects.

To exercise any of these rights, please contact us at privacy@41elements.com. We will

respond within 30 days. You will not be charged a fee for exercising your rights unless

requests are manifestly unfounded or excessive.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience, analyse site

traffic, and personalise content. Our cookies are categorised as follows:

• Strictly necessary cookies: Required for the operation of our services. These cannot

be disabled.

• Analytical/performance cookies: Help us understand how visitors interact with our

website.

• Functionality cookies: Allow us to remember your preferences and settings.

• Targeting/advertising cookies: Used to deliver relevant advertisements (only with

your consent).

You may manage your cookie preferences at any time via our Cookie Settings panel or

through your browser settings. Note that disabling certain cookies may affect the

functionality of our services.

11. Data Security

We implement appropriate technical and organisational measures to protect your personal

data against unauthorised access, alteration, disclosure, or destruction. These include:

• Encryption of data in transit (TLS/SSL) and at rest

• Access controls and authentication mechanisms

• Regular security assessments and vulnerability testing

• Employee training on data protection and security practices

In the event of a personal data breach that poses a risk to your rights and freedoms, we will

notify the relevant supervisory authority (AEPD) within 72 hours and inform you without

undue delay where required.


12. Children's Privacy

Our services are not directed to individuals under the age of 16. We do not knowingly collect

personal data from children. If we become aware that we have collected data from a child

without verified parental consent, we will delete it promptly. If you believe we have

inadvertently collected such data, please contact us immediately.


Where we are required to retain or disclose data to comply with applicable law, regulation, or

13. Right to Lodge a Complaint

If you believe we have processed your personal data unlawfully or in breach of this policy,

you have the right to lodge a complaint with the Spanish Data Protection Authority:

Agencia Espanola de Proteccion de Datos (AEPD)

Website: www.aepd.es

Address: C/ Jorge Juan, 6, 28001 Madrid, Spain

We would, however, appreciate the opportunity to address your concerns directly before you

contact the supervisory authority.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices,

technology, or legal requirements. When we make material changes, we will notify you by

email or by posting a prominent notice on our website, and update the "Last updated" date at the top of this document.

We encourage you to review this policy periodically.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or our data

practices, please contact us:

41elements

Email: privacy@41elements.com

Address: Madrid, Spain

We are committed to resolving