Legal
Privacy Policy
The short version
This website does not use cookies, does not run analytics, and does not track you. You can read every page of it without giving us anything.
We only hold personal data about you if you choose to hand it over: by emailing us, by filling in the project enquiry form, or by booking a call. We use it to answer you and to prepare a proposal, and we do not sell it or use it for advertising.
1. Who is responsible for your data
Horizon Symmetry is the trading name of the company below, which is the data controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679, the GDPR) and Spanish Organic Law 3/2018 (LOPDGDD).
- Company
- Zencup, S.L., trading as Horizon Symmetry
- Tax ID
- CIF B22569602
- Registered office
- Calle de Lagasca 63, 4A, 28001 Madrid, Spain
- Registry
- Registro Mercantil de Madrid
- horizonsymmetrystudio@gmail.com
We have not appointed a Data Protection Officer, because we are not required to. Write to the address above with anything to do with your data and it reaches the people who can act on it.
2. When you simply visit the site
No cookies, no analytics, no tracking
We set no cookies on this website. We store nothing in your browser: no local storage, no session storage, no device identifiers. We run no analytics product, no advertising pixel, and no session recording. There is no profiling and no automated decision-making anywhere on this site.
That is also why you are not asked to accept anything when you arrive. There is no consent banner because there is nothing on your device to consent to. See our Cookie Policy for the detail.
Server logs
The site is hosted by Vercel. Like any web host, Vercel records technical information about requests it serves, which can include your IP address, the page requested, the time of the request, and your browser and device type. These logs exist so the site can be delivered, kept available, and protected from abuse. We do not use them to build a picture of you, and we do not link them to any other information.
Legal basis: our legitimate interest in operating and securing the website (Article 6(1)(f) GDPR).
Third parties your browser contacts
The animated scene on the home page is served from outside our own domain. Loading it means your browser makes a request to the providers below, and a request always carries your IP address and browser details to whoever answers it. None of them set cookies on this site, and none of them receive your name, your email, or anything you type.
- Unicorn Studio, which renders the home page scene, together with jsDelivr and Google Cloud Storage, which deliver its code and its image files.
Legal basis: our legitimate interest in presenting the site as designed (Article 6(1)(f) GDPR).
3. When you get in touch
If you email us, we receive your email address, your name if you sign it, and whatever you write. Our mail runs on Google Workspace.
The project enquiry form
The "Start a project" button leads to our onboarding funnel at apply.horizonsymmetry.com. If you complete it, we receive:
- your name and email address, which are required in order to reply to you;
- your phone or WhatsApp number, so we can arrange a conversation;
- your company name or website, if you give one, which is optional;
- anything you write in the free-text box, which is optional;
- your answers to the multiple-choice questions about what you are building, what stage you are at, what you want to achieve, and how quickly you want to move.
We ask for these because they are what we need to reply with something useful rather than a generic answer. Please do not put special category data (health, beliefs, political opinions and the like) in the free-text box. We do not need it and we do not want to hold it.
Purpose: to answer your enquiry, to assess whether we are a
fit, and to prepare a proposal.
Legal basis: taking steps at your request before entering
into a contract (Article 6(1)(b) GDPR).
Booking a call
The last step of the funnel offers a calendar. Choosing a slot creates a booking with Cal.com, which is a separate service, and passes it your name, email, chosen time and any note you add. Cal.com then handles your data under its own privacy policy as well as ours. Booking a call is optional and you can finish the funnel without it.
Legal basis: taking steps at your request before entering into a contract (Article 6(1)(b) GDPR).
If you become a client
Once we work together we hold what the engagement needs: contact details, the material you send us, and the billing and invoicing records Spanish tax and commercial law requires us to keep.
Legal basis: performance of our contract with you (Article 6(1)(b) GDPR) and compliance with our legal obligations (Article 6(1)(c) GDPR) for the accounting records.
4. What we never do
- We do not sell your personal data, and we never have.
- We do not share it with advertisers or data brokers.
- We do not add you to a marketing list because you filled in the enquiry form. If we ever run a newsletter you will have to ask for it.
- We do not make decisions about you by automated means.
5. Who processes it on our behalf
We use a small number of established providers to run the site and the enquiry funnel. They act on our instructions under a data processing agreement, and they may not use your data for their own purposes.
| Provider | What it does | Where |
|---|---|---|
| Vercel Inc. | Hosts the website and its request logs | United States |
| Formspree Inc. | Receives the enquiry form and forwards it to our inbox | United States |
| Google Ireland Ltd. and Google LLC | Google Workspace, our email | Ireland and United States |
| Cal.com Inc. | Handles call bookings, if you choose to make one | United States |
| Unicorn Studio | Renders the animated scene on the home page | United States |
We may also disclose data where the law requires it, for example to a court, a tax authority or a supervisory authority acting within its powers.
6. Transfers outside the European Economic Area
Several of the providers above are established in the United States, so your data may be processed there. Those transfers are covered either by the European Commission's Standard Contractual Clauses, or by the provider's certification under the EU to US Data Privacy Framework, together with the additional safeguards those mechanisms require. You can ask us for details of the mechanism relied on by any particular provider.
7. How long we keep it
- Enquiries that do not become projects: up to 24 months from your last contact with us, so we can pick the conversation back up if you return. Then deleted.
- Client records: for the life of the engagement and then for the period Spanish law requires. Commercial books and supporting documents are kept for 6 years under the Código de Comercio, and invoicing records for 4 years under the Ley General Tributaria.
- Email: kept while the correspondence is still live, then archived and periodically cleared.
- Server logs: retained for a short period by our host under its own retention schedule, and not archived by us.
8. How it is protected
The site is served over HTTPS throughout. Access to the enquiry inbox and to client material is limited to the people at Horizon Symmetry who need it for the work in hand. No system is perfect, and we do not claim ours is, but we keep the number of places your data sits as small as we can, which is why the list of providers above is as short as it is.
9. Your rights
Under the GDPR you have the right to:
- Access the personal data we hold about you, and get a copy of it.
- Rectify anything inaccurate or incomplete.
- Erase it, where we have no overriding reason to keep it.
- Restrict how we process it while a dispute about it is resolved.
- Object to processing we carry out on the basis of legitimate interest.
- Portability, meaning a copy in a structured, machine-readable format.
- Withdraw consent at any time, where consent was the basis. This does not undo processing carried out before you withdrew it.
To exercise any of these, email horizonsymmetrystudio@gmail.com. We will respond within one month, and we will tell you if we need longer. Asking costs nothing. We may ask you to confirm your identity first, so that we are not handing your data to somebody else.
If you think we have handled your data badly, please tell us first and give us the chance to fix it. You also have the right to complain directly to the Spanish supervisory authority, the Agencia Española de Protección de Datos (aepd.es), C/ Jorge Juan 6, 28001 Madrid, or to the authority in the EU country where you live.
10. Children
This site and our services are aimed at businesses and at adults. We do not knowingly collect data from anyone under 14, the age of digital consent in Spain. If you believe a child has sent us personal data, tell us and we will delete it.
11. Changes to this policy
If we add anything that changes what we collect or who receives it, we will update this page and move the date at the top. Where the change is significant and we hold your contact details, we will tell you directly.