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Privacy policy

Last updated: 9 October 2026

This is a translation provided for convenience. In the event of any discrepancy, the Spanish version prevails.

This policy describes how IMPARAGON SL processes the personal data of people who use the website imparagon.com, the platform mi.imparagon.com, and the contact and diagnostic forms, in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on the Protection of Personal Data and the guarantee of digital rights (LOPDGDD).

1. Data controller

  • Identity: IMPARAGON SL
  • Tax ID (NIF): B-75664524
  • Registered address: Carrer de Felip II, 210, 2-2, 08027 Barcelona, Spain
  • Email: hello@imparagon.com

2. What data we process

We process only the data the user provides through the website’s forms, and the data generated by their use of it:

  • Identification and contact data: first name, surname, email address, telephone, company and job title.
  • Professional data provided in the diagnostic request: industry, approximate advertising spend, platforms used, CRM system, and any other information the user chooses to share about their company.
  • Browsing data: pages visited, source of the visit and technical connection data, processed anonymously as described in the Cookie policy.
  • Professional contact details of companies we present our services to: name, role, company, public professional profile and corporate phone or email, taken from the company’s own website and publicly accessible professional sources. When we contact someone this way, our first message says who we are and how to ask us not to contact them again.
  • Referral programme data: for the person who refers, their name, email, telephone, language and personal link, and proof that they accepted the terms (date and time, version, accepted text, IP address and browser); for the referred company, the details of its contact person provided by the person who refers (name, email or telephone, company and website), with their knowledge.
  • Platform access data (clients only): credentials and activity logs on mi.imparagon.com.

We do not process special categories of data. The user is responsible for the accuracy of the data they provide and for not including third-party data without authorisation.

Purpose Description Legal basis
Responding to diagnostic and contact requests Handling the enquiry, preparing the requested diagnostic and maintaining the communication needed to do so Pre-contractual measures at the data subject’s request (Art. 6.1.b GDPR)
B2B prospecting Presenting IMPARAGON SL’s services to people in charge at companies that may need them, via LinkedIn or by phone, and emailing information only to those who asked for it Legitimate interest in presenting our services to other businesses (Art. 6.1.f GDPR), limited to professional data and with the right to object at any time
Commercial management Following up with companies interested in IMPARAGON SL’s services, preparing and sending proposals Legitimate interest in conducting business (Art. 6.1.f GDPR), balanced against the rights of the data subject
Providing the service to clients Managing the contractual relationship and access to the mi.imparagon.com platform Performance of a contract (Art. 6.1.b GDPR)
Referral programme Registering referrals, informing the person who refers of their status, sending them the reward and evidencing their acceptance of the terms Performance of the programme terms (Art. 6.1.b GDPR) for the person who refers; legitimate interest in contacting the referred company, which knows it is being referred (Art. 6.1.f GDPR); tax obligations (Art. 6.1.c GDPR)
Sending communications Sending content, articles and news from IMPARAGON SL by email Consent of the data subject (Art. 6.1.a GDPR), which may be withdrawn at any time
Website analytics Anonymous measurement of website use in order to improve it Legitimate interest (Art. 6.1.f GDPR); the data does not identify the user
Advertising measurement Loading advertising platform tags to measure campaign effectiveness Consent of the data subject (Art. 6.1.a GDPR), via the cookie banner
Compliance with legal obligations Responding to requests from authorities and meeting tax and commercial obligations Legal obligation (Art. 6.1.c GDPR)

4. How long we keep the data

  • Diagnostic and contact requests: for as long as needed to handle the request and, if it does not lead to a contractual relationship, for a maximum of two years from the last contact.
  • Client data: for the duration of the contractual relationship and, afterwards, for the limitation periods of the applicable legal obligations (generally six years for commercial purposes and four for tax purposes).
  • B2B prospecting: at most twelve months from the last contact if there is no interest; if the person asks not to be contacted, we keep only what is needed to respect that request.
  • Referral programme: while you take part in the programme and, afterwards, for the periods during which liability may be claimed (generally five years), including the proof of acceptance of the terms. If the referred company does not become a client, its contact details are kept as a contact request.
  • Communications sent with consent: until the data subject withdraws consent or unsubscribes.
  • Analytics data: being anonymous, it is not subject to personal data retention periods.

Once those periods have elapsed, the data is deleted or anonymised so that the person can no longer be identified.

5. Who receives the data

IMPARAGON SL does not sell or transfer personal data to third parties. To deliver its services it uses suppliers who act as processors under contract and follow its instructions:

  • Hosting and database providers with servers located in the European Union.
  • Meeting scheduling tools, used to arrange diagnostic and follow-up sessions.
  • Email providers for sending communications.
  • Referral programme rewards provider (Tremendous Inc., United States): receives the name and email of the person who refers and the amount, only to send them the reward. The transfer relies on the European Commission’s standard contractual clauses.
  • Advertising platforms (Google, Meta and others), only where the user has given consent through the cookie banner and solely for campaign measurement.

Some of these suppliers may be established outside the European Economic Area. Where that is the case, IMPARAGON SL ensures the transfer is made with the safeguards required by the GDPR (a European Commission adequacy decision or standard contractual clauses).

Data may also be disclosed to public administrations and competent authorities where there is a legal obligation to do so.

6. Your rights

Any person has the right to:

  • Access: find out what data we process about them.
  • Rectification: correct inaccurate or incomplete data.
  • Erasure: ask for their data to be deleted when it is no longer needed.
  • Objection: object to processing based on legitimate interest, including processing for commercial purposes.
  • Restriction: ask for processing to be restricted in the cases set out in the legislation.
  • Portability: receive their data in a structured, commonly used format, or have it transmitted to another controller.
  • Withdraw consent at any time, without affecting the lawfulness of processing carried out beforehand.
  • Not be subject to automated decisions producing legal effects or significantly affecting them.

To exercise these rights, write to hello@imparagon.com stating which right you wish to exercise and attaching a document that allows us to verify your identity. We will reply within one month of receiving the request, extendable in the cases provided for by law.

7. Complaints to the supervisory authority

If you believe the processing of your data does not comply with the legislation, you may lodge a complaint with the Spanish Data Protection Agency (AEPD), at www.aepd.es or at its offices at C/ Jorge Juan, 6, 28001 Madrid. We would be grateful if you contacted us first at hello@imparagon.com so we can try to resolve it.

8. Security

IMPARAGON SL applies appropriate technical and organisational measures to protect personal data against unauthorised access, loss or alteration, taking into account the state of the art and the nature of the data processed. Access to the mi.imparagon.com platform is protected by individual credentials and authenticated sessions.

9. Client data processed on behalf of third parties

In delivering its services, IMPARAGON SL may process data belonging to the contacts and customers of its client companies (for example, leads recorded in a CRM). In those cases IMPARAGON SL acts as a processor on behalf of the client company, which is the controller, and the processing is governed by the data processing agreement signed between both parties under Article 28 GDPR.

10. Changes to this policy

IMPARAGON SL may update this policy to reflect changes in legislation or in its processing activities. The version in force will always be available on this page, showing the date it was last updated.