Privacy Policy

01. Preliminary Considerations and Regulatory Framework

The present Privacy Policy establishes the general principles, operational parameters and applicable conditions governing the collection, processing, conservation and protection of personal information within the digital environment associated with SAXTRONICS, an independent initiative dedicated to the conceptualisation, engineering, development and presentation of electronic musical instruments and associated technological applications.

The processing activities described herein shall be interpreted in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, hereinafter referred to as the General Data Protection Regulation (GDPR), together with Organic Law 3/2018 of 5 December on Personal Data Protection and the Guarantee of Digital Rights, and such other provisions of Spanish or European Union law as may be applicable.

Within the meaning attributed to the concept of data controller under Article 4(7) of the GDPR, responsibility for determining the purposes and essential means of processing personal information voluntarily communicated through saxtronics.com corresponds to Roberto Hinojosa, acting in connection with the independent SAXTRONICS project. Communications concerning the processing of personal information, including requests relating to the exercise of legally recognised rights, may be addressed electronically to contacto@saxtronics.com.

The interpretation and practical implementation of this policy shall remain subject to the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality and accountability, as established under Article 5 of the GDPR.

02. Nature, Scope and Purpose of Processing

The processing of personal information within the SAXTRONICS digital environment is primarily associated with the voluntary establishment of communications between visitors and the individual responsible for the project. Such communications may concern technical enquiries, product characteristics, development-related information or other matters directly connected with the activities presented through the website.

The categories of personal information potentially processed may include identifying information supplied by the interested party, electronic contact details and the substantive content of communications voluntarily submitted through the corresponding contact mechanisms.

The purposes for which such information may be processed are confined to the examination, management and resolution of enquiries, the provision of information expressly requested by the interested party and the maintenance of correspondence reasonably connected with the original communication.

The submission of information through the website shall not, by itself, constitute the formalisation of a contractual relationship, the execution of a commercial transaction or the establishment of any obligation to acquire or supply a particular product.

SAXTRONICS does not currently operate an automated electronic commerce platform, online checkout procedure or integrated payment-processing infrastructure.

03. Legal Grounds and Conditions of Lawful Processing

The legitimacy of the processing operations described in this policy shall be assessed in accordance with Article 6 of the GDPR, taking into consideration the nature of the communication initiated by the interested party and the specific circumstances surrounding the corresponding processing activity.

Where an enquiry concerns information requested by a visitor prior to the possible establishment of a contractual relationship, processing may be necessary for the implementation of pre-contractual measures undertaken at the request of the interested party, within the meaning of Article 6(1)(b) of the GDPR.

Where appropriate, the management of ordinary correspondence and the preservation of communications reasonably necessary for the protection of legitimate interests may be based upon Article 6(1)(f) of the GDPR, subject to the applicable assessment of necessity, proportionality and the rights and freedoms of the individual concerned.

Processing activities requiring consent shall not be undertaken on that basis unless the corresponding consent has been obtained under the conditions established by applicable legislation.

04. Principles Governing Data Retention

Personal information shall not be retained for periods exceeding those reasonably necessary for the purposes for which the information was originally collected, without prejudice to retention requirements arising from applicable legal obligations or the establishment, exercise or defence of legal claims.

The determination of the appropriate retention period shall take into account the nature of the communication, the continuity or termination of the corresponding enquiry, the existence of subsequent communications and any legal obligations requiring preservation of particular information.

Once the circumstances justifying continued processing have ceased, personal information shall be deleted or otherwise handled in accordance with applicable requirements concerning retention, restriction and secure disposal.

05. Confidentiality, Recipients and Technical Intermediation

Personal information collected through the website shall not be sold or commercially transferred to third parties for independent advertising purposes.

Notwithstanding the foregoing, the operation of a contemporary digital communications infrastructure may necessarily involve the participation of external technical service providers, including hosting operators, electronic communications providers and entities responsible for the maintenance or security of the technological environment.

Where such providers process personal information on behalf of the controller, the corresponding relationships shall be subject to the applicable requirements of Article 28 of the GDPR, including the establishment of appropriate contractual safeguards where required.

Any international transfer of personal information, where applicable, shall be assessed in accordance with Chapter V of the GDPR and the corresponding requirements governing transfers to third countries or international organisations.

The website may incorporate external technological services, including embedded audiovisual or audio playback functionalities. Such services may operate under the independent privacy frameworks of their respective providers. Additional information concerning storage technologies and third-party services may be provided through the corresponding Cookie Policy.

06. Rights of Interested Parties

Individuals whose personal information is processed within the scope of this policy may exercise the rights recognised under Articles 15 to 22 of the GDPR, insofar as the conditions established for their respective exercise are satisfied.

Such rights include access to personal information, rectification of inaccurate data, erasure where legally appropriate, restriction of processing, objection to processing and data portability where the corresponding statutory requirements are met.

Where processing is founded upon consent, the interested party may withdraw such consent at any time, without affecting the lawfulness of processing undertaken prior to its withdrawal.

Requests relating to these rights may be submitted through the electronic contact channel identified in this policy. The controller shall examine and respond to such requests in accordance with the procedural conditions and time limits established by Article 12 of the GDPR.

Where an individual considers that the processing of personal information infringes applicable data protection legislation, the individual may lodge a complaint with the competent supervisory authority, including the Spanish Data Protection Agency (Agencia Española de Protección de Datos), accessible through www.aepd.es.

07. Voluntary Communication and Accuracy of Information

The provision of personal information through the contact mechanisms available on the website is undertaken voluntarily by the interested party for the purpose of initiating a communication.

Information designated as mandatory within the corresponding interface shall be limited to that reasonably necessary for the examination and management of the enquiry concerned. The omission of information necessary to establish an effective communication channel may prevent the corresponding request from being processed.

Visitors are requested to ensure that information voluntarily supplied is accurate, relevant and appropriately updated, and to refrain from communicating personal information concerning third parties unless a legitimate basis exists for such communication.

08. Technical and Organisational Safeguards

The protection of personal information shall be approached through the implementation of technical and organisational safeguards proportionate to the nature, scope, context and purposes of processing, taking into consideration the risks presented to the rights and freedoms of natural persons.

In accordance with Article 32 of the GDPR, appropriate security measures may include access controls, confidentiality safeguards, secure communications infrastructure and other mechanisms reasonably necessary to preserve the integrity and availability of information.

Communications transmitted through the website are protected by HTTPS, providing transport-layer encryption between the visitor’s browser and the website infrastructure.

The adoption of technical safeguards does not constitute a representation that electronic systems are entirely immune to operational failures, unauthorised interference or other technological contingencies.

Security measures shall be maintained and reviewed as appropriate in light of the technological environment, the nature of the information processed and the risks reasonably associated with the corresponding activities.

09. Interpretation, Revision and Continuing Applicability

The provisions contained in this Privacy Policy shall be interpreted in a manner consistent with the applicable regulatory framework and the fundamental principles governing the protection of personal information.

Any modification to the technological functionality of the website, the purposes of processing or the applicable regulatory environment may give rise to the revision of the present document.

Such revisions shall be incorporated where necessary to ensure that the information provided to visitors continues to correspond with the processing activities actually undertaken within the SAXTRONICS digital environment.

Last updated: October 2026.