Privacy Policy & Data Protection

1. Data Controller

FCH Cupolo · Av Suiza 5a, 29651 Málaga, Spain · E-mail: fw@fchcupolo.com · Phone: +34 633 180 914. A Data Protection Officer (DPO) has not been appointed, as FCH Cupolo does not meet the thresholds under GDPR Art. 37. All data-protection enquiries should be directed to the e-mail above.

2. Personal Data We Collect

We collect only the personal data you provide voluntarily via the contact form on this website: (a) first and last name; (b) business e-mail address; (c) company name (optional); (d) product interest category; (e) free-text message. No sensitive data ("special categories" under Art. 9 GDPR) is requested or collected. Server logs may temporarily record your IP address and browser user-agent for security purposes.

3. Legal Basis for Processing

We process your data on the following lawful bases under GDPR Art. 6: (a) Art. 6(1)(b) — processing is necessary to take pre-contractual steps at your request when you submit a business enquiry; (b) Art. 6(1)(f) — our legitimate interest in conducting B2B commodity trading activities, replying to trade-related correspondence and maintaining accurate business records. We do not rely on consent as a legal basis for the contact-form data.

4. Purposes of Processing & Retention

Your data is processed solely to: respond to your enquiry; maintain ongoing business correspondence; and keep records of pre-contractual negotiations as required by applicable commercial law. Data is retained for a maximum of three (3) years from the date of last contact, after which it is securely deleted, unless a longer period is required by applicable law (e.g. tax, accounting).

5. Third-Party Processors

Your form submission is transmitted to and temporarily processed by Formspree, Inc. (USA), which acts as our data processor under a Data Processing Agreement. Formspree processes data solely to deliver the message to our inbox and does not use it for any other purpose. No other third parties receive your personal data. We do not sell, rent or share your data with marketing companies, data brokers or advertising networks.

6. International Data Transfers

Formspree, Inc. is based in the United States. Transfers to Formspree are safeguarded by Standard Contractual Clauses (SCCs) approved by the European Commission under Art. 46(2)(c) GDPR. A copy of the applicable safeguard may be requested at fw@fchcupolo.com.

7. Your Rights Under GDPR (Arts. 15–22)

You have the right to: (Art. 15) request a copy of the personal data we hold about you; (Art. 16) ask us to correct inaccurate or incomplete data; (Art. 17) request erasure of your data where there is no overriding legal basis to retain it; (Art. 18) request restriction of processing while a dispute is resolved; (Art. 20) receive your data in a machine-readable format (portability); (Art. 21) object to processing based on our legitimate interests. To exercise any of these rights, write to fw@fchcupolo.com. We will respond within one calendar month as required by GDPR Art. 12.

8. Right to Lodge a Complaint

If you believe your data has been processed unlawfully, you have the right to lodge a complaint with the Spanish supervisory authority: Agencia Española de Protección de Datos (AEPD) — www.aepd.es — C/ Jorge Juan, 6, 28001 Madrid, Spain. You may also contact the supervisory authority in your country of habitual residence.

9. Automated Decision-Making

We do not use your personal data for automated decision-making or profiling as described in GDPR Art. 22.

10. Cookies & Local Storage

This website uses only functional browser storage (localStorage) to remember your preferences — no analytics or advertising cookies are deployed. For full details, please read our Cookie Policy.

11. Changes to This Policy

We may update this policy from time to time. The date of the last revision is shown at the bottom of this page. Continued use of the website after a change constitutes acceptance of the updated policy.

Last updated: June 2025