Privacy policy
Last updated: 28 August 2026
This policy explains what personal data we process, why, how long we keep it and what rights you have. It is written to be understood: if anything is unclear, write to us and we'll explain it.
Two different things are worth separating, because different rules apply: the data we process through THIS WEBSITE (sections 2 to 7), and our clients' data, which we process as their supplier (section 8).
This English version is provided for convenience. These documents are governed by Spanish law and the Spanish version prevails in the event of any discrepancy.
1. Data controller
- Registered name
- Black Wings, S.L.
- Tax ID (CIF)
- B10991172
- Address
- Calle Mira-sol 8, 46015 Valencia (España)
- Data protection contact
- hola@blackwings.dev
We are not required to appoint a data protection officer and we have not appointed one. Data protection enquiries are handled at the address above.
2. What data we process through this site
This website has no user registration, no private area and no database. The only personal data that reaches us is:
- Contact form data
- Your name, email address, company (optional) and the content of the message you write.
- Technical server data
- IP address, browser type and access logs, generated automatically by our hosting provider when serving the pages.
- Language preference
- A technical cookie remembering whether you prefer to read the site in Spanish or English. It identifies nobody.
We process no bank or card details through this website, because nothing is sold on it.
3. What we use it for, and on what legal basis
| Purpose | Legal basis |
|---|---|
| Replying to the message you send via the form or by email | Consent and pre-contractual measures at the data subject's request (art. 6(1)(a) and 6(1)(b) GDPR) |
| Keeping the site available and protecting it from abuse | Legitimate interest in the security of the service (art. 6(1)(f) GDPR) |
| Remembering your language preference | Legitimate interest in providing the service requested by the user |
| Meeting tax and accounting obligations if you become a client | Legal obligation (art. 6(1)(c) GDPR) |
We send no marketing to people who write to us through the form. There is no mailing list, no newsletter, and no transfer to third parties for commercial purposes.
4. How long we keep it
The contact form message is not saved in any database: it is emailed to our inbox, and that email is the only record that exists.
- Contact emails: up to 2 years from the last interaction, unless the conversation leads to a contractual relationship.
- Technical server logs: as retained by our hosting provider under its own policy, typically around 30 days.
- Billing data, if you become a client: 6 years, under Spanish commercial and tax law.
- Language cookie: 1 year, or until you clear it from your browser.
5. Who else can see this data
For the site to work and for us to reply to you, two providers process data on our behalf as processors:
- Vercel Inc.
- Website hosting and content delivery network. Processes the technical data in section 2.
- Resend Inc.
- Delivery of the email generated by the contact form. Processes the name, email and message you write.
Where a provider processes data outside the European Economic Area, we ensure the safeguards in Chapter V of the GDPR are in place, usually the standard contractual clauses approved by the European Commission.
We do not sell or transfer personal data to third parties for commercial purposes. Ever.
6. Your rights
Under the GDPR and Spanish Organic Law 3/2018 (LOPDGDD), you have the right to:
- Access your personal data.
- Rectify inaccurate data.
- Erase data when it is no longer necessary.
- Restrict or object to processing.
- Port your data to another provider.
- Withdraw consent at any time, without affecting the lawfulness of processing carried out beforehand.
To exercise any of them, write to hola@blackwings.dev identifying yourself appropriately. We will respond within a maximum of one month.
If you believe we have not handled your request properly, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).
7. Security measures
This site's best security measure is that it stores almost nothing: no database, no user accounts, no passwords to protect. In addition:
- All traffic is encrypted in transit (HTTPS).
- The contact form does not persist your message in any store; it only carries it to email.
- Access to the inbox receiving the messages is protected with two-factor authentication.
No system can guarantee absolute security, but we undertake to notify any relevant breach within the legally established deadlines.
8. Our clients' data: we act as a processor
When we develop or maintain software for a company, that company is the controller of the data inside it, and Black Wings, S.L. acts as a processor within the meaning of article 28 GDPR.
- The client retains ownership of its data at all times.
- We process that data only on its documented instructions and to provide the contracted service.
- The relationship is formalised in a data processing agreement signed with each client.
- When the service ends, we return or delete the data as the client directs.
If you are a user or customer of a company that works with us and you want to exercise your rights over your data, your contact is that company, not us. We will assist them with whatever they need in order to help you.
9. Minors
Our services are aimed at companies, professionals and adults. We do not knowingly collect data from children under 14. If we find that a minor's data has been provided without appropriate consent, we will delete it immediately.
10. Changes to this policy
We may update this policy to reflect legal, technical or business changes. The version in force is always the one published on this page, bearing the last-updated date in the header.