Tsugiwa

Privacy policy

Controller

Controller
Gorka Linaza, trading as Nijūsan Studio
Tax ID (NIF)
78878417D
Address
Calle Butrón 4, 3.º B — 28022 Madrid, Spain
Contact
hola@tsugiwa.net, or by post to the address above

What is not collected

This site has no forms, no sign-up, no user accounts, no subscription and no waiting list. It uses no analytics, no cookies and no browser storage. There are no tracking pixels, and we load no resources from additional providers: typefaces, images and video all come from this same domain. Nobody asks you for a single detail and nothing identifies you from one visit to the next.

What isn't up to us: the host may add its own headers when serving the page —today that includes a network error reporting notice pointing at a domain of its own— and your browser may send those reports. That is part of the delivery service, not something we set up to measure anything.

The typefaces are served from this same domain, not from an external provider, precisely so that visiting this page doesn't send your IP address to anyone else.

The home page does run one small script of our own, hosted here, which handles the background video and makes the text appear as you scroll. It measures nothing, stores nothing in your browser and talks to no server. You can read it: it's at /js/portada.js.

What does happen when the page is served

For your browser to receive this site, the hosting provider — Cloudflare — processes technical data about the connection: IP address, user agent and the time of the request. This is unavoidable on any website and serves to deliver the content and protect it from attack.

Legal basis: legitimate interest in the operation and security of the site (art. 6(1)(f) GDPR). Cloudflare acts as a processor and may process that data on servers outside the European Economic Area, relying on the European Commission's standard contractual clauses. We do not use it for profiling or for any commercial purpose.

Retention: those technical logs are retained by the hosting provider for the period set out in its own policy, not by us. We keep no copy and no records of our own.

Your rights

You can exercise your rights of access, rectification, erasure, objection, restriction of processing and portability by writing to hola@tsugiwa.net, or by post to the address above. Note that this site creates no record of its own associated with you, so to act on a request we would need you to tell us which processing you mean.

If you believe your rights have not been respected, you can complain to the Spanish Data Protection Agency (www.aepd.es) or to the supervisory authority in your country.

When this policy will change

This policy covers an informational website about a product under construction. Before any account can be created, a full policy will be published setting out what data the service processes, on what basis, for how long and with which processors.

It will also include a Data Processing Agreement (art. 28 GDPR) for healthcare professionals, whose patients generate special category data (art. 9 GDPR).