PRIVACY POLICY

This policy explains how personal data is processed when you use omarigruzzman.com, in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD).

1. Data controller

Omari Mshvenieradze (trading as Omari Gruzzman)
Avenida Imperio Argentina 12, Bloque 6 - 3A, 29004 Málaga, Spain
NIF Z1889679G · mail@omarigruzzman.com

2. What data is processed, why, and on what legal basis

a) Commission enquiry form

Data: name, email address, and — where you provide it — company or studio name, phone number, project details, budget range, delivery date, links and any information in your message.
Purpose: to assess your enquiry and prepare an estimate for a custom composition, and to correspond with you about it.
Legal basis: steps taken at your request prior to entering into a contract (Art. 6(1)(b) GDPR).
Retention: 24 months from the last contact, unless a commission results, in which case the data is kept for the duration of the engagement and the statutory retention periods that follow (tax and accounting law, currently up to 6 years in Spain).

b) Checklist download and newsletter

Data: email address, date and time of sign-up and confirmation, and — where you provide it — your name.
Purpose: to send you the requested checklist and occasional emails about music licensing and the composer's work.
Legal basis: your consent (Art. 6(1)(a) GDPR), confirmed by double opt-in. You may withdraw consent at any time via the unsubscribe link in every email or by writing to the address above.
Retention: until you unsubscribe. A record of your consent and withdrawal is kept for as long as necessary to prove compliance.

c) Technical data when visiting the site

Data: IP address, browser type, date and time of access, pages requested, referring URL.
Purpose: delivering the website securely and keeping it operational; server logs are used only for security and error analysis.
Legal basis: legitimate interest in operating a secure website (Art. 6(1)(f) GDPR).
Retention: server logs are kept by the hosting provider for as long as is necessary for security and error analysis, and are deleted according to the provider's own retention schedule; they are not used for any other purpose and are not combined with other data.

d) Website statistics

This website uses Plausible Analytics, a privacy-focused statistics service operated by Plausible Insights OÜ (Estonia) with servers in the European Union. Plausible does not use cookies, does not store IP addresses, and does not create profiles of individual visitors; it records only aggregated data such as page views, referring websites, country, device type and browser. Because no personal data is stored, no consent is required.
Legal basis: legitimate interest in understanding how the website is used (Art. 6(1)(f) GDPR).

3. Recipients and processors

Your data is not sold or passed to third parties for their own purposes. The following service providers process data on the controller's behalf under data processing agreements:

  • Hosting: Hostinger International Ltd., servers located in the European Union (France); backups stored in Lithuania.
  • Email marketing (checklist and newsletter): MailerLite (UAB "MailerLite", Vilnius, Lithuania — EU).
  • Website statistics: Plausible Insights OÜ, Tallinn, Estonia (EU).
  • Email: enquiry form submissions are delivered to the controller's mailbox, hosted by Hostinger (EU).

No other transfers of personal data outside the European Economic Area take place.

4. Your rights

You have the right to access your data, to have it rectified or erased, to restrict or object to its processing, to data portability, and to withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal. To exercise these rights, write to mail@omarigruzzman.com; a copy of an identity document may be requested if your identity cannot otherwise be verified. You also have the right to lodge a complaint with the Spanish Data Protection Authority (Agencia Española de Protección de Datos, www.aepd.es).

5. Security

Appropriate technical and organisational measures are applied to protect your data, including TLS encryption of the website and access restrictions on the mailbox and mailing tools.

6. Cookies

See the Cookie Policy.

7. Changes

This policy may be updated to reflect legal or technical changes. The current version is always published on this page.

Last updated: 5 September 2026