Privacy Policy

Effective Date: 23Oct25

1.INTRODUCTION

D'lom Co. ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, and protect your information when you visit our website www.dlom.co or use our services.

This policy complies with the EU General Data Protection Regulation (GDPR) and Spanish data protection laws.

2. DATA CONTROLLER

D'lom Co.

Email: eva@dlom.co

Location: Madrid, Spain

3. WHAT DATA WE COLLECT

We may collect and process the following personal data:

Information you provide directly:

● Name and contact details (email, phone number)

● Professional information (job title, company, industry)

● Communication preferences

● Information provided in contact forms, consultation bookings, or email correspondence

● Payment information (processed securely through third-party payment processors)

Information collected automatically:

● IP address

● Browser type and version

● Pages visited and time spent on pages

● Referring website

● Cookies and similar tracking technologies (see Cookie Policy)

4. HOW WE USE YOUR DATA

We use your personal data for the following purposes:

Service delivery: To provide mentoring, coaching, and educational services

Communication: To respond to inquiries, send service updates, and provide customer support

Marketing: To send newsletters, resources, and promotional materials (only with your consent)

Website improvement: To analyze website usage and improve user experience

Legal compliance: To comply with legal obligations and protect our legal rights

Legal basis for processing:

● Consent (for marketing communications)

● Contract performance (to deliver services you've purchased)

● Legitimate interests (to improve our services and website)

● Legal obligation (to comply with applicable laws)

5. DATA SHARING

We do not sell your personal data. We may share your data with:

Service providers: Email marketing platforms (to be determined), payment processors (e.g., Stripe, PayPal), scheduling tools (e.g., Calendly), website hosting providers

Legal requirements: When required by law, court order, or government request

Business transfers: In case of merger, acquisition, or sale of business assets

All third-party providers are GDPR-compliant and process data only as instructed by us.

6. DATA RETENTION

We retain your personal data only as long as necessary:

Active clients: Duration of service plus 7 years (for tax/legal requirements)

Marketing subscribers: Until you unsubscribe

Website visitors: Analytics data retained for 26 months

Inquiries/contacts: 3 years from last contact

7. YOUR RIGHTS UNDER GDPR

You have the right to:

Access: Request a copy of your personal data

Rectification: Correct inaccurate or incomplete data

Erasure: Request deletion of your data ("right to be forgotten")

Restriction: Limit how we use your data

Portability: Receive your data in a structured, machine-readable format

Object: Object to processing based on legitimate interests

Withdraw consent: Unsubscribe from marketing at any time

To exercise these rights, contact us at: eva@dlom.co

8. DATA SECURITY

We implement appropriate technical and organizational measures to protect your data, including:

● SSL encryption for data transmission

● Secure hosting providers

● Access controls and password protection

● Regular security assessments

However, no internet transmission is 100% secure. We cannot guarantee absolute security.

9. INTERNATIONAL DATA TRANSFERS

Some of our service providers may be located outside the EU/EEA. When we transfer data internationally, we ensure adequate protection through:

● EU Standard Contractual Clauses

● Privacy Shield (or equivalent mechanisms)

● Adequacy decisions by the European Commission

10. CHILDREN'S PRIVACY

Our services are not directed to individuals under 18. We do not knowingly collect data from children.

11. COOKIES

See our separate Cookie Policy for information about how we use cookies.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. The "Effective Date" at the top indicates the last revision. Continued use of our website after changes constitutes acceptance.

13. CONTACT & COMPLAINTS

For privacy questions or to exercise your rights:

Email: eva@dlom.co

You also have the right to lodge a complaint with the Spanish Data Protection

Authority (AEPD):

Website: www.aepd.es

Phone: +34 901 100 099