Draft — 15 September 2026

Who is responsible for your information?

BrandCoherence is operated personally by Luis Ocleiry, who is responsible for the personal information described in this policy.

Website: https://brandcoherence.eu
Email: luis@brandcoherence.eu
Address: Martín Machío, 30-2ºD, 28002 Madrid, Spain

This policy covers website visitors, people who contact me or book meetings, and professional contacts whose information I hold.

Information I collect

Depending on how we interact, I may process:

• Your name, company, job title, work email address and LinkedIn profile.
• Your telephone number when you book a meeting.
• Messages, optional booking comments and relevant notes about our conversations.
• Meeting details, including dates and calendar invitations.
• A recording of a call, only where you have agreed beforehand.
• Technical information associated with website access, such as IP address, browser information and server logs.

Please avoid providing sensitive personal information that is unnecessary for our professional discussions.

Where information comes from

You may provide information directly through email, Calendly bookings or our conversations.

For professional prospecting, I may obtain business contact information from LinkedIn, company websites, articles, public posts and referrals. I keep relevant contact details and conversation notes in Google Sheets.

Where information comes from another source, I will provide the required privacy information within the applicable period—normally no later than one month, or at the first communication if earlier.

Why I use information

Enquiries and meetings

I use information to respond to enquiries, arrange meetings and discuss potential work. Where you are considering a contract with me personally, this processing may be necessary to take steps at your request before entering a contract. Where you represent a company, I rely on my legitimate interest in managing professional enquiries and relationships.

Professional contacts and prospecting

I use relevant professional information to identify potential business relationships and maintain appropriate contact records. Any reliance on legitimate interests requires consideration of your interests, reasonable expectations and privacy rights.

This does not replace any permission required for commercial electronic communications. Publicly available contact information is not, by itself, permission to send promotional emails.

You may object to the use of your information for direct marketing at any time.

Website operation and security

Technical information may be used to deliver the website, diagnose problems and protect it against misuse, based on my legitimate interest in maintaining a secure, functioning website.

Legal obligations

Information may also be retained or disclosed where necessary to comply with applicable legal obligations or establish, exercise or defend legal claims.

Booking meetings through Calendly

The website’s booking button takes you to a separate Calendly page; the booking calendar is not embedded in this website.

Bookings request your name, email address, telephone number and company. You may also leave an optional comment. Required fields must be completed to book through Calendly; you can alternatively contact me by email.

Calendly connects to my Google Calendar to manage appointments. Calls are held through Google Meet.

Calendly and Google also process information under their applicable terms and privacy notices:

• Calendly Privacy Notice
• Google Privacy Policy

Optional call recordings

With your prior permission, I may record a call to keep an accurate record of negotiation discussions and understandings.

Before recording begins, I will explain the purpose and ask for your agreement. You may decline and continue the call without recording.

Recordings are stored in my Google Drive, with access restricted to me, and deleted within three months. You may withdraw your consent by contacting me. Withdrawal does not affect processing that was lawful before withdrawal; I will stop consent-based use and delete the recording unless a separate legal requirement justifies retaining it.

Cookies, Analytics and downloads

The Founder Transfer Problem document can currently be downloaded without completing a form or supplying contact details. Accessing a download may still generate technical server information.

The website currently has no embedded videos, maps or social-media feeds.

Google Analytics 4 is configured to measure website visits and interactions only after you give consent for Statistics cookies.

Google Tag Manager manages the relevant tag. No Google Ads or remarketing setup is included at this stage.

The Cookie Policy and consent controls explain the cookies in use and how to change your choices.

Services that handle information

I use the following services for the activities described above:

• Hostinger: website hosting and business email hosting.
• Microsoft Outlook: accessing and sending business email.
• Google Drive and Google Sheets: storing professional contact records and relevant notes, and any agreed call recordings.
• Google Calendar and Google Meet: scheduling and holding meetings.
• Calendly: appointment booking.
• LinkedIn: professional research and communication.
• Complianz: managing website cookie preferences once configuration is complete.

I am the only person within BrandCoherence with access to these business accounts and records. Service providers may process information as necessary to provide their services. Some may also process information independently for purposes explained in their own privacy notices.

Information may be disclosed to authorities where legally required.

International processing

Some service providers may process information outside the European Economic Area.

The applicable transfer arrangements depend on the provider, service and account agreement. These may include an applicable adequacy decision or European Commission Standard Contractual Clauses.

You may contact me for information about the safeguards applicable to your information and how to obtain a copy.

How long I keep information

• Unanswered prospect records: up to 12 months from collection.
• Enquiries and related conversation notes: up to 12 months after the last meaningful interaction, unless an ongoing relationship requires continued retention.
• Call recordings: no longer than three months.
• Contractual or legally required records: for the period needed for the relevant relationship, applicable obligations or legal claims.
• Do-not-contact records: a minimal email-address record is kept separately for as long as needed to respect your objection and prevent accidental renewed outreach. Its necessity will be reviewed periodically.

Technical logs, cookie records and future Analytics data have separate retention settings, which will be checked and reflected in the final policy and Cookie Policy.

Your rights

Depending on the circumstances, you can ask to:

• Access your personal information.
• Correct inaccurate or incomplete information.
• Delete information.
• Restrict how information is used.
• Object to processing based on legitimate interests.
• Object to direct marketing, which will stop.
• Receive eligible information in a portable format.
• Withdraw consent where processing relies on it.

Contact luis@brandcoherence.eu to exercise these rights. I may need proportionate information to verify your identity. Requests will normally receive a response within one month; where a permitted extension is necessary, I will explain why.

You may complain to the Spanish Data Protection Agency, AEPD, or another competent supervisory authority.

I do not use your information for solely automated decisions that produce legal or similarly significant effects.

Changes to this policy

I will update this policy when relevant practices change, including before introducing embedded videos, advertising tools or materially different uses of personal information.