Welcome to the website of www.elisaesteve.com ("we," "us," or "our"). We provide high-level executive marketing advisory services as a Fractional Chief Marketing Officer (CMO). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website www.elisaesteve.com (the "Site") or contact us via our web forms.

We process personal data in strict compliance with the European Union General Data Protection Regulation (EU GDPR), the Spanish Organic Law on Data Protection and Guarantee of Digital Rights (LOPDGDD), the UK GDPR, the UK Data (Use and Access) Act 2025, and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and the Consumer Privacy Protection Act (CPPA/Bill C-27).

1. Data Controller

For the purposes of European, UK and Canadian data protection laws, the data controller is:

• Company/Individual Name: Elisabeth Esteve Jiménez

• Tax Identification Number: 28634365D

• Physical Fiscal Address: Calle laguna de las canteras, 6. Chiclana de la Frontera (11130), Cádiz. Spain

• Contact Email: Hello@elisaesteve.com

2. Personal Data We Collect

We collect information that you proactively provide to us, as well as data collected automatically through our website architecture:

• Voluntary Data: When filling out contact, consultation, or discovery call forms, you provide your name, professional email address, phone number, company name, LinkedIn profile, website URL, and details regarding your marketing challenges.

• Automated Data: When navigating our Site, we automatically collect technical identifiers via standard log files, including your IP address, browser type, operating system, referring URLs, pages viewed, geographic region, and access timestamps. Analytics data is only processed if explicit consent is granted.

3. Legal Bases and Purposes of Processing

Under EU/UK GDPR Article 6 and PIPEDA consent principles, we process your personal data using the following legal grounds:

• Consent: To send marketing newsletters or respond to custom queries. This includes the use of non-essential cookies for traffic analysis. You can withdraw your consent at any time.

• Contractual Necessity: To take necessary steps at your request prior to entering into a formal Fractional CMO service agreement (e.g., booking a consultation or scoping an engagement).

• Legitimate Interests: To analyze website performance, optimize user experience, secure our website from cyber threats, and establish professional B2B communications.

4. Cookies and Tracking Technologies

Our Site utilizes cookies to ensure functionality and analyze metrics. In accordance with AEPD (Spain) and UK ICO guidelines, here is the detailed list of cookies used:

A. Necessary Cookies (Always Active)

• Cookie Name: framer_session

• Provider: Framer

• Purpose: Essential for site security, performance, and ensuring the website displays correctly.

• Expiry: Session (deleted when you close the browser).

B. Statistics & Analytics Cookies (Require Consent)

• Cookie Name: _ga

• Provider: Google Analytics

• Purpose: Used to distinguish unique users and analyze site traffic patterns anonymously.

• Expiry: 2 years.

• Cookie Name: _ga_<ID>

• Provider: Google Analytics

• Purpose: Used to maintain session state and track page views for internal reporting.

• Expiry: 2 years.

Management of Consent:

• EU, Spain, and UK Visitors: All non-essential cookies are blocked by default. They will only fire if you click "Accept All". We provide a "Reject All" option with equal visual prominence.

• Canadian Visitors: In accordance with Bill C-27, we require express consent for tracking technologies.

• Withdrawal: You can modify settings at any time via the "Cookie Settings" button in our footer or by clearing your browser cache.

5. Data Sharing and Third-Party Processors

We do not sell, rent, or trade your personal data. We share data only with trusted infrastructure providers necessary to run our business, operating under strict Data Processing Agreements (DPAs):

• Hosting & Design: Hostinger International Ltd. (Cyprus/EU) and Framer B.V. (Netherlands/EU).

• Scheduling & CRM: Google Workspace, Calendly, and HubSpot. All processors operate under signed Data Processing Agreements (DPAs).

6. International Data Transfers

Because our business operates from Spain, data collected from UK and Canadian users will be stored within the European Union.

• Adequacy: Transfers are protected by EU-UK and EU-Canada Adequacy Decisions.

• Third Countries: For tools processing data in the US (e.g., Google), we enforce EU Standard Contractual Clauses (SCCs) and utilize Google Consent Mode v2 to ensure privacy-compliant signaling.

7. Data Retention

We retain your personal data only as long as necessary to fulfill the purposes outlined in this policy, manage our ongoing client relationships, or comply with statutory financial and legal retention periods under Spanish tax law. General contact inquiries are automatically deleted after 24 months if no contractual engagement occurs.

8. Your Legal Rights (GDPR & PIPEDA)

You possess comprehensive rights regarding your personal information:

• Access and Portability: The right to request copies of your personal data in a structured, machine-readable format.

• Rectification: The right to demand correction of inaccurate or incomplete data.

• Erasure ("Right to be Forgotten"): The right to request deletion of your personal data under certain legal conditions.

• Restriction and Objection: The right to restrict processing or object to our processing based on legitimate interests.

• Withdraw Consent: The right to revoke consent at any time for data processing built upon your initial permission.

To exercise any of these rights, contact us directly at hello@elisaesteve.com.

• If you are an EU/Spanish resident and feel your rights were violated, you have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD).

• UK residents may contact the Information Commissioner’s Office (ICO).

• Canadian residents may contact the Office of the Privacy Commissioner of Canada (OPC).