This policy explains, without dressing it up, what personal data this site handles and what it does with it. It has been drafted in line with Regulation (EU) 2016/679 (GDPR) and Spain's Organic Law 3/2018 on Personal Data Protection (LOPDGDD).
1. Data controller
- Controller: Juan José Villanueva Borrego
- Residence: El Puerto de Santa María, Cádiz (Spain)
- Privacy contact: legal@elpuerto.ai
- Website: elpuerto.ai
As a personal, non-commercial project with no economic activity, there is no legal obligation to appoint a Data Protection Officer (DPO). All requests are handled directly by the controller at the address above.
2. First, what we do not do
This site is designed to minimise the processing of personal data. Specifically:
- We do not use first-party or third-party cookies. No technical, analytics or advertising cookies. That is why you will not see a consent banner: there is nothing to consent to. Any cookie warning shown by your browser was not placed by this site.
- We do not use Google Analytics, Meta Pixel, Hotjar, Clarity or any profiling-based tracking.
- We do not build user profiles, cross-site tracking or behavioural advertising.
- We do not share, sell or transfer data to third parties for commercial purposes.
- We do not collect data from children. The content of this site is not aimed at persons under the age of 14 and no data is solicited from that age group.
3. What data we process and why
a) Newsletter subscription
If you voluntarily subscribe to the weekly edition, we ask for your email address and, optionally, your name. These are stored along with the subscription date and the record of your consent in a local database on the site's server.
- Purpose: to send you the weekly newsletter with a selection of content from the site and, occasionally, communications about the project itself.
- Legal basis: your explicit consent (art. 6(1)(a) GDPR), which you can withdraw at any time via the unsubscribe link in every email or by writing to legal@elpuerto.ai.
- Retention: while you remain subscribed. When you unsubscribe we delete your address and name. If you never confirm, the request is deleted after 30 days. The send log (address and edition) is kept for 60 days, only to avoid sending the same edition twice. Database backups may keep your address and name for up to 14 days after you unsubscribe; after that they are gone from all of them.
b) Messages you send us
If you contact us by email (for example, to report an error, exercise your rights or ask a question), we process your email address and the contents of your message solely to reply.
- Legal basis: your own act of contacting us (legitimate interest in managing communications, art. 6(1)(f) GDPR).
- Retention: for as long as needed to handle your enquiry and meet any applicable legal obligations, after which messages are archived or deleted.
c) Technical server data
The server hosting the site logs basic technical information (IP address, request timestamp, requested URL, browser type) for the sole purpose of keeping the service running, ensuring security and preventing abuse. This information is not linked to identified individuals and is not used for behavioural analysis.
The site is hosted by DigitalOcean, on a server in Amsterdam (European Union); DigitalOcean acts as data processor. Web server logs are kept for 14 days and then deleted automatically.
d) Correction reports
If you use the corrections form, we keep the article it refers to, the text of your report and, only if you provide it, your contact details. They are stored in the site server's database.
- Purpose: checking the report, correcting the content where needed and, if you left a contact, asking you for clarification.
- Legal basis: legitimate interest in keeping published content accurate (art. 6(1)(f) GDPR). Contact details are optional.
- Publication: the public corrections log describes the change made; it never publishes your contact details.
4. Cookie-free audience measurement
To understand, in aggregate, which content resonates, the site uses Plausible Analytics, a European service specifically designed not to collect personal data:
- No cookies, no localStorage, no browser fingerprinting.
- No IP address storage. A daily identifier is generated from a hash that prevents tracking the same visitor across days.
- Data is processed on servers located in the European Union.
- The script is downloaded from
plausible.io, so their servers receive your IP address as part of the technical request; according to Plausible, they do not store it.
Plausible acts as a data processor (art. 28 GDPR). The legal basis is the controller's legitimate interest in knowing aggregate usage statistics (art. 6(1)(f) GDPR), balanced against your rights and freedoms: since the service does not identify visitors or build profiles, the privacy impact is minimal. You can object by writing to legal@elpuerto.ai.
5. Newsletter delivery
Technical delivery of the newsletter is handled by Resend, a transactional email provider. Resend receives your email address and the newsletter content solely to deliver it to your inbox.
To prepare each send, a computer controlled by the site owner reads the subscriber list from the server over an encrypted connection and records which addresses received each edition, so nobody gets it twice.
- Role: data processor (art. 28 GDPR).
- Location: United States. This involves an international transfer of data outside the European Economic Area.
- Safeguards: the transfer relies on Standard Contractual Clauses approved by the European Commission (Decision 2021/914) and, where applicable, on the EU-U.S. Data Privacy Framework.
6. Web fonts
The site's typefaces (Outfit, Lato and Newsreader) are served from the site's own servers, not from Google Fonts or any other third-party CDN. No third party receives your IP address just because the fonts load. The fonts are published under the SIL Open Font License.
7. Your rights
You may exercise the following rights granted by the GDPR at any time:
- Access: to know what data of yours we process and obtain a copy.
- Rectification: to correct inaccurate or incomplete data.
- Erasure (right to be forgotten): to request the deletion of your data.
- Objection: to object to processing based on legitimate interest.
- Restriction: to request restricted processing while a claim is verified.
- Portability: to receive your data in a structured, machine-readable format.
- Withdrawal of consent: at any time, without affecting the lawfulness of prior processing.
To exercise any of these rights, write to legal@elpuerto.ai stating which right you wish to exercise. We will reply within the one-month period set by the GDPR, or within the extended two-month period if the request is particularly complex (in which case we will notify you). We may ask you to prove your identity if there are reasonable doubts about who is making the request.
8. Complaints to the supervisory authority
If you believe the processing of your data does not comply with applicable law, or if you are dissatisfied with the controller's response, you have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD): www.aepd.es. The AEPD is the supervisory authority with jurisdiction in Spain.
9. Security
We apply reasonable technical and organisational measures to protect the data: TLS encryption across all site traffic and restricted access to the site's database. No system is invulnerable, but the volume and sensitivity of data processed here is deliberately low, precisely to minimise the impact of any incident.
The server's database is backed up every night. Backups are kept on the server itself and on a computer belonging to the owner, with restricted access, and each one is deleted after 14 days. They are used only to restore the site after a failure or a mistake. If you ask us to erase your data, it disappears from the backups as they expire, within 14 days at most.
10. Changes to this policy
This policy may be updated when the tools, providers or applicable rules change. The date of the most recent revision appears at the top of the document. Where relevant, significant changes will be communicated to newsletter subscribers.
Questions about this policy or your data? Write to legal@elpuerto.ai.