Elelyon Digital

Privacy policy

Last updated: 18 October 2026

Website: https://elelyondigital.com/

This is the English version of this document. A Spanish version is also published on this website. Where the two versions differ, the Spanish version prevails, because it is the version drafted under Spanish law.

1. Data controller

  • Controller: Betuel Paul Grozescu, self employed professional, trading under the brand Elelyon Digital.
  • NIE (Spanish tax identification number): X5646129C
  • Address: Calle Boqueras 75, Almazora, Castellon, Spain.
  • Contact email, also used to exercise your rights: info@elelyondigital.com

The full identification details of the controller and the general terms of use of the Website are set out in the legal notice.

This policy is drafted in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR), Spanish Organic Act 3/2018 on the protection of personal data and the guarantee of digital rights (LOPDGDD), and Spanish Act 34/2002 on information society services and electronic commerce (LSSI-CE).

2. What data we process and where it comes from

Contact form. This is the only form on the Website. It asks for:

  • Name: required.
  • Company: optional.
  • Email address: required.
  • Goal or message: required.
  • Acceptance of this privacy policy: a required checkbox before the form can be sent.

The form does not ask for a phone number.

Form security. The form uses Google reCAPTCHA v3 in invisible mode, with the action “Form”. The service analyses technical data about the interaction and the device in order to assess the risk of the submission. reCAPTCHA v3 sets no cookies on the Website: it stores the technical key _grecaptcha in the browser’s local storage. This processing involves a disclosure of data to Google, which acts as the provider of the security service.

Floating WhatsApp button. The Website shows a button that opens WhatsApp. The conversation then takes place entirely within WhatsApp, which is operated by WhatsApp Ireland Limited, part of the Meta group. When you write through that channel, the data processed are your phone number, your WhatsApp profile name, and the content of the messages and files you send. That conversation is governed by Meta’s terms of service and privacy policy. Elelyon Digital processes those data solely in order to deal with and reply to your enquiry.

Browsing data. Where you allow it in the cookie notice, we process technical and usage data about the Website: pages viewed, source of the visit, interaction with the page, browser and device. Each cookie is listed in detail in the Cookie policy.

Special categories of data. The Website does not ask for special category data. Please do not include in the message field, or in the WhatsApp conversation, information about health, political opinions, beliefs, trade union membership, sex life, biometric data or other special categories, because they are not needed in order to deal with your enquiry.

3. Purposes, legal bases and retention periods

Processing Purpose Legal basis Retention
Contact form Receive your enquiry, understand the goal you describe, reply, and where appropriate prepare and send a proposal for working together Consent of the data subject, Article 6(1)(a) GDPR, given through the required acceptance checkbox. Where the enquiry concerns possible collaboration, also steps taken at the request of the data subject prior to entering into a contract, Article 6(1)(b) 1 year from the last contact if no commercial relationship begins. If the contact becomes a client, for the applicable legal and tax retention periods, up to 6 years
Anti spam security for the form (Google reCAPTCHA v3) Prevent fraudulent and automated submissions and spam, and protect the operation of the form Legitimate interests of the controller, Article 6(1)(f) GDPR The time needed to verify each submission. The technical key _grecaptcha remains in the browser’s local storage until you clear the site data
Own consent cookie Remember your choice about cookie categories Legitimate interests of the controller in recording and honouring your choice, Article 6(1)(f) GDPR, together with the obligation under Article 22(2) LSSI-CE to be able to evidence consent 12 months from the choice
Website analytics (Google Analytics 4 and Microsoft Clarity) Measure how the Website is used and understand behaviour on the page in order to improve it Consent of the data subject, Article 6(1)(a) GDPR, given in the cookie notice Cookies: as set out in the Cookie policy. In Google Analytics 4: 2 months for event data and 14 months for user data, with user retention reset on new activity. In Microsoft Clarity: up to 1 year for project data
Advertising and conversion measurement (Meta pixel and attribution through the Google Analytics 4 to Google Ads link) Understand which ads generate visits and enquiries, measure campaign conversions and optimise them Consent of the data subject, Article 6(1)(a) GDPR, given in the cookie notice Cookies: as set out in the Cookie policy. Aggregated campaign data are retained on the Meta and Google platforms in accordance with each provider’s terms
Handling enquiries through WhatsApp Deal with and reply to the enquiry you start through the floating button Consent of the data subject, Article 6(1)(a) GDPR, when you start the conversation, and steps taken at your request prior to entering into a contract, Article 6(1)(b), where the enquiry concerns possible collaboration 1 year from the last contact if no commercial relationship begins. If the contact becomes a client, for the applicable legal and tax retention periods, up to 6 years

Once these periods have elapsed, the data are erased or blocked in accordance with Article 32 LOPDGDD, remaining available only to courts, tribunals, the Public Prosecutor’s Office or the competent authorities for as long as any liability may be claimed.

4. Measurement and security tools used by the Website

No analytics or advertising tool loads before you accept the relevant category in the cookie notice. If you reject the non essential categories, those tools never load.

  • Google Analytics 4, property G-1GT637BR6T, operated by Google Ireland Limited. Measures visits, pages viewed, sessions and technical browsing data. It loads once you accept either the “Analytics” or the “Advertising” category. Google Signals is switched off in the property.
  • Microsoft Clarity, project ytlxapcjwn, operated by Microsoft Ireland Operations Limited. This is a behavioural analytics tool: it records your interaction with the page on a pseudonymised basis, that is pointer movement, scrolling and clicks, and produces heatmaps and session recordings. It is not used to identify you personally and it is not used for advertising. It loads once you accept the “Analytics” category.
  • Meta pixel, identifier 1072871965292563, operated by Meta Platforms Ireland Limited. Measures the performance of Facebook and Instagram ads. It records the PageView event across the Website and the Lead event on the two thank you pages shown after the contact form is sent. It loads once you accept the “Advertising” category.
  • Google Ads conversion attribution. The Website contains no Google Ads tag of its own. Conversions are imported from Google Analytics 4 into Google Ads through the key event ads_conversion_Gracias_1, using the link between the two accounts. That link sets the attribution keys _gcl_au and _gcl_ls, described in the Cookie policy, and depends on the “Advertising” category.
  • Google reCAPTCHA v3, operated by Google Ireland Limited. Protects the contact form against automated submissions, fraud and spam. Unlike the tools above, it loads before the cookie choice is made, because it is a security measure the form needs in order to work. It sets no cookies and it is not used for audience or advertising purposes.

The Website serves the Manrope and Inter typefaces from its own domain. No connection is made to Google’s font servers. The Website contains no social plugins, iframes or tags from Facebook, Instagram, X, YouTube, Pinterest or LinkedIn, and it uses no TikTok Ads or LinkedIn Ads tags.

5. Consent and Google Consent Mode v2

The cookie notice offers three options, within the same notice and at the same level: “Accept all”, “Reject non-essential” and “Manage preferences”, so that rejecting is just as easy as accepting. The categories are essential, analytics and advertising, and the last two can be accepted or rejected independently.

Your choice is stored in the first party cookie elelyon_cookie_consent for 12 months, in the format analytics=0|1&ads=0|1, with the Secure and SameSite=Lax attributes. After choosing, you can change your decision at any time using the “Cookie settings” button on the Website.

The Website uses Google Consent Mode v2. Before you choose, the default states are: analytics_storage, ad_storage, ad_user_data and ad_personalization denied, and functionality_storage and security_storage granted. The implementation waits 500 milliseconds for your choice to be applied before continuing, and switches on advertising data redaction for as long as advertising consent is absent. With permissions denied, the Google tag is never downloaded, so no measurement at all is sent to Google, not even cookieless modelled measurement.

When you withdraw analytics or advertising permission, the implementation deletes any Google cookies present in the browser, that is those beginning with _ga and _gcl_, and the tools in the withdrawn category stop loading. Meta and Microsoft Clarity cookies already set stop receiving data and expire on their own within the periods given in the Cookie policy; they can also be deleted at any time from your browser settings.

6. How the contact form is handled

The form sends your enquiry by email to info@elelyondigital.com, a mailbox hosted on the Website’s own hosting account at Raiola Networks S.L. and created from the hosting cPanel. The configured technical sender is noreply@elelyondigital.com, and the reply goes to the address you entered in the “Email” field.

The form is processed through an email action, and enquiries are not stored in the WordPress database: they remain only in the mailbox that receives them.

7. Recipients and processors

Data are not disclosed to third parties except where required by law. The recipients and providers involved are:

  • Raiola Networks S.L. (Spain). Provides hosting for the Website and the email service for the elelyondigital.com domain, including the info@elelyondigital.com mailbox. It acts as a processor on behalf of the controller under a contract compliant with Article 28 GDPR, and its servers are located in Spain.
  • Google Ireland Limited and Google LLC. Google Analytics 4 (property G-1GT637BR6T), Google reCAPTCHA v3, and the attribution link between Google Analytics 4 and Google Ads.
  • Meta Platforms Ireland Limited and Meta Platforms, Inc. The Meta pixel (identifier 1072871965292563).
  • WhatsApp Ireland Limited, part of the Meta group. Operator of the WhatsApp service in which conversations started from the floating button take place.
  • Microsoft Ireland Operations Limited and Microsoft Corporation. Microsoft Clarity (project ytlxapcjwn).

For the analytics and advertising services, Google, Meta and Microsoft act as processors for the part of the service they provide on behalf of the controller, and as independent controllers for the processing they carry out for their own purposes under their own terms. For WhatsApp, Meta acts as the controller of the messaging service.

8. International data transfers

The Website makes international transfers of personal data to the United States, arising from the use of the services described in this policy.

  • Google LLC (United States), for Google Analytics 4, Google reCAPTCHA v3 and conversion attribution.
  • Meta Platforms, Inc. (United States), for the Meta pixel and for the WhatsApp service.
  • Microsoft Corporation (United States), for Microsoft Clarity.

These transfers rely on the EU and US Data Privacy Framework, recognised by the European Commission’s adequacy decision of 10 July 2023, to which those entities are certified. In addition, the standard contractual clauses approved by the European Commission apply, as incorporated in each provider’s data processing terms, together with the supplementary technical and organisational measures each provider declares.

Hosting and email for the Website involve no international transfer: Raiola Networks S.L. provides the service from Spain.

9. Automated decisions and profiling

The controller does not take automated decisions with legal effects on users and does not build profiles for that purpose. The Meta and Google advertising tools may carry out their own advertising profiling under their own terms, and only where you have accepted the “Advertising” category in the cookie notice.

10. Security and confidentiality

The Website is always served over HTTPS with a TLS certificate, so traffic between your browser and the server is encrypted. The form is protected with Google reCAPTCHA v3. Access to the mailbox and to the content management system is restricted to authorised persons and protected with individual credentials.

Technical and organisational measures appropriate to the risk of the processing are in place, including hosting backups and regular updates of the Website software. If a personal data breach occurred that could pose a risk to the rights and freedoms of individuals, it would be notified to the Spanish Data Protection Agency and, where applicable, to the people affected, within the periods set out in Articles 33 and 34 GDPR.

11. Your rights

You may exercise the following rights over your personal data:

  • Access: find out what data are processed and obtain a copy.
  • Rectification: correct inaccurate or incomplete data.
  • Erasure: ask for your data to be deleted where they are no longer needed.
  • Objection: object to processing based on the controller’s legitimate interests.
  • Restriction of processing: ask that your data be kept but not used while a complaint or a verification is resolved.
  • Portability: receive the data you provided in a structured, commonly used format, or have it transmitted to another controller.
  • Withdrawal of consent: withdraw consent at any time, without this affecting the lawfulness of processing carried out beforehand. Cookie consent is withdrawn using the “Cookie settings” button on the Website.

To exercise them, simply send a request to info@elelyondigital.com with the subject “Exercise of rights”, or write to Betuel Paul Grozescu, Calle Boqueras 75, Almazora, Castellon, Spain. Your request should state which right you wish to exercise and give the information needed to locate your data. Additional identity documentation will only be requested where necessary and proportionate. We reply within one month of receipt, extendable by a further two months in complex cases, in accordance with Article 12 GDPR. Exercising these rights is free of charge.

12. Complaints to the supervisory authority

If you believe that your data are not being processed in accordance with the law, you may lodge a complaint with the Spanish Data Protection Agency (AEPD), the competent supervisory authority: www.aepd.es, C/ Jorge Juan 6, 28001 Madrid. You may also contact the controller first at info@elelyondigital.com.

13. Third party links

The Website links to external pages and services, including WhatsApp and Instagram. Those destinations have their own controllers and their own privacy policies. Before giving data to a third party through a link, it is advisable to read its privacy information.

14. Cookies

The Website’s Cookie policy lists every cookie and every browser storage item used, with its name, category, provider, purpose and duration, and explains how to accept, reject and delete them. This privacy policy and the Cookie policy are complementary documents.

15. Changes to this privacy policy

This policy is updated whenever the purposes, the data processed, the providers, the measurement technologies, the form or the applicable legal obligations change. The applicable version is the one published on this page, with the last updated date shown at the top.

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