Privacy Policy

1. Introduction:

Fragua LLC ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your personal data when you visit our website maurosgv.com (and/or fraguadesign.com) or engage our services.

For the purposes of the General Data Protection Regulation (GDPR), the Data Controller is Fragua LLC, a company registered in Wyoming, USA.

2. Contact Information:

If you have questions about this policy or your data rights, please contact us:

Email: admin@fraguadesign.com

Mailing Address: 30 North Gould Street, Ste N, Sheridan, WY 82801, USA.

3. Data We Collect:

We collect and process the following types of personal data:

Inquiry Data: Name and email address provided when you schedule a meeting via Calendly or contact us via email.

Client Data: Billing address, company details, and signatories' information required for contracts (OpenSign) and invoicing (Stripe/Mercury).

Workspace Data: Access credentials or user invites you voluntarily provide to grant us access to your website platform (such as Webflow, GitHub or Cloudflare), Slack, or other platforms.

Technical Data: We use PostHog to understand how our website is used: pages visited, the referring website, browser and device type, approximate location (country or city, derived from your IP address, which is not stored) and interactions such as clicks. PostHog runs in cookieless mode: nothing is stored on your device, and visitors are counted with a privacy-preserving hash calculated on PostHog's servers, not with a persistent identifier.

Tool Data: On our PostHog Objection Handler page (maurosgv.com/posthog), the text you type into the tool is sent to our server to generate an answer and is recorded as an analytics event. That page also records a session replay of your visit, with form inputs masked. As stated on the page, the replay lasts only for that page view and nothing is stored on your device.

4. How and Why We Use Your Data:

We process your data under the following legal bases (GDPR Art. 6):

Purpose: Scheduling Meetings | Legal Basis: Consent (implied when you book a slot).

Purpose: Providing Services (website design and development) | Legal Basis: Performance of a Contract or steps prior to entering one.

Purpose: Billing & Payments | Legal Basis: Legal Obligation (tax/accounting) and Performance of a Contract.

Purpose: Communication (Slack/Email) | Legal Basis: Legitimate Interest to maintain the business relationship.

Purpose: Site Security | Legal Basis: Legitimate Interest to protect our website and services.

Purpose: Website Analytics, including the session replay on the Objection Handler page | Legal Basis: Legitimate Interest to understand how the website is used and improve it. You can object at any time by emailing us.

5. Sharing Your Data (Processors):

We do not sell your data. We share data only with trusted third-party service providers ("Processors") essential to our operations:

Hosting & Security: Cloudflare (USA)

Analytics: PostHog (data stored in the EU, Frankfurt)

Scheduling: Calendly (USA)

Communication: Google Workspace, Slack (USA)

Contracts: OpenSign (USA)

Payments & Banking: Stripe, Mercury (USA)

6. International Data Transfers:

Fragua LLC is a US-based entity. Therefore, personal data you submit to us is transferred to and processed in the United States. We ensure your data is protected by prioritizing providers that adhere to the EU-US Data Privacy Framework (DPF) or by utilizing Standard Contractual Clauses (SCCs) where necessary. Website analytics data is stored in the EU by PostHog.

7. Data Retention:

Inquiries: Deleted after 12 months if no business relationship is established.

Client Contracts & Billing: Retained for 5 years after the contract ends to comply with tax and legal obligations.

Workspace Access: We request that you revoke our access immediately upon project completion.

8. Your Rights:

Under the GDPR, you have the right to:

Access the personal data we hold about you.

Rectify incorrect or incomplete data.

Delete your data ("Right to be forgotten"), subject to legal retention obligations.

Restrict or Object to processing.

Portability: Receive your data in a structured, standard format.

Withdraw Consent at any time.

To exercise these rights, email admin@fraguadesign.com. You also have the right to lodge a complaint with a supervisory authority (e.g., the AEPD in Spain).

9. Cookies Policy:

We do not use marketing, tracking, or advertising cookies.

Analytics: We use PostHog in cookieless mode. It does not set cookies or store anything on your device.

Essential Cookies: Our website host and security provider (Cloudflare) may set strictly necessary cookies, for example to filter malicious bot traffic. These are essential for the site to function securely and cannot be disabled.