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Privacy Policy

How we collect, use and protect your personal data.

This Privacy Policy explains how The Hold Circle collects, uses and protects your personal data when you visit theholdcircle.com or place an order. We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and Spanish data-protection law.

1. Who is responsible for your data

The data controller is Myrian Aeby, trading as The Hold Circle (sole trader, Spain).

  • Tax ID (NIF/DNI): Y3568114T
  • Address: Carrer Del Pintor Vila Prades 20, 1-3, 46008 València, Spain
  • Email: hello@theholdcircle.com

2. What data we collect

Information you give us: name, billing and shipping address, email, phone (optional), order details, and any message you send us. If you sign up to our newsletter, your email address.

Information collected automatically: IP address, device and browser data, and usage data via cookies and similar technologies (see section 4).

Payment details (card numbers, etc.) are entered with our payment providers and are not stored by us.

3. How and why we use your data

  • To process and deliver your orders — legal basis: performance of a contract.
  • To take payment via PayPal, Bizum or SEPA bank transfer — performance of a contract.
  • To manage your account and provide support — performance of a contract / our legitimate interests.
  • To send our newsletter, where you have subscribed — your consent (you can unsubscribe at any time).
  • To run analytics and marketing (Google Analytics 4, Meta Pixel) — your consent, given via our cookie banner.
  • To meet legal and tax obligations (e.g. keeping invoices) — compliance with a legal obligation.
  • To keep the Site secure and improve it — our legitimate interests.

4. Cookies & tracking

We use essential cookies needed to run the Site and your cart, plus analytics cookies (Google Analytics 4) and marketing cookies (Meta Pixel). Non-essential cookies are only set after you give consent through our cookie banner, and you can change or withdraw your choice at any time.

5. Who we share your data with

We share data only with service providers (processors) who help us run the shop, and only as needed:

  • Payment providers: PayPal, Bizum, and our bank for SEPA transfers
  • Shipping carrier: [CARRIER]
  • Email & newsletter: Mailchimp (Intuit)
  • Analytics & marketing: Google (Analytics) and Meta (Pixel)
  • Domain provider: Hostinger.com
  • Web hosting / web-space: All-Inkl (ALL-INKL.COM GmbH, Germany)

We do not sell your personal data.

6. International transfers

Some providers (e.g. Google, Meta, Mailchimp) may process data outside the EU, including in the United States. Where they do, the transfer is protected by appropriate safeguards such as the EU Standard Contractual Clauses and/or the EU–US Data Privacy Framework.

7. How long we keep it

We keep order and invoice data for as long as required by Spanish tax and commercial law (generally up to 6 years). Newsletter data is kept until you unsubscribe. Analytics data is retained according to each provider’s settings.

8. Your rights

You have the right to access, correct, delete or restrict your data, to object to processing, to data portability, and to withdraw consent at any time. To exercise any of these, email hello@theholdcircle.com. You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD, www.aepd.es).

9. Security

We use appropriate technical and organisational measures to protect your data, including encryption in transit (HTTPS). No method of transmission is completely secure, but we work to keep your data safe.

10. Children

The Site is not directed at children. We do not knowingly collect personal data from anyone under the age of 14.

11. Changes to this policy

We may update this policy from time to time. Last updated: 12 June 2026.

12. Contact

For any privacy question, email hello@theholdcircle.com.