This policy explains how Desti Ads handles personal data when you visit www.desti-ads.com, submit an enquiry or communicate with us about our services. Our email communications are limited to responding to enquiries and managing the resulting business conversations. We do not subscribe enquirers to newsletters or promotional email campaigns.
Who is responsible for your data
The data controller is WILLIAM ANDRES VILLACRES ZAMORA, trading as Desti Ads. The controller decides why and how personal data covered by this policy is processed. CRO business-name registration number: 796540 (Ireland).
Business correspondence address: Apartment 2, Block B, Smithfield Market, Dublin, Ireland.
Privacy enquiries: will@desti-ads.com.
Website: https://www.desti-ads.com.
This policy concerns Desti Ads' own website and enquiries. If Desti Ads processes leads on behalf of a client, the client's privacy information and our separate contractual data-processing arrangements govern that work.
Information we collect and where it comes from
You provide information when you complete an enquiry form, email us or discuss a potential engagement. Depending on what you supply, this can include your name, email address, telephone number, business name, website, role, business needs, correspondence and any information included in a requested proposal. Please do not send identity documents, payment-card details, passwords or sensitive personal information through the enquiry form.
When you use the website, our hosting, form and security services process technical information needed to deliver and protect the service. This can include an IP address, browser and device information, request times, requested pages, security events and the source of a visit. Our consent service records your cookie choices and related consent records.
If you accept analytics cookies, Google Analytics 4 collects website activity such as page visits, referral or campaign information, engagement and a successful enquiry event. This involves browser identifiers, device information and approximate location information. We do not send your name, email address, phone number or the contents of your enquiry to GA4.
If a colleague contacts us on your behalf, we may receive your business contact details from them. We use those details only as relevant to that enquiry and provide the applicable privacy information when contacting you.
Why we use your information
We use enquiry information to understand your request, answer questions, arrange a conversation, prepare a requested proposal and follow up on that request. Where you are personally considering a contract with us, the lawful basis is taking steps at your request before entering a contract, under Article 6(1)(b) GDPR. Where you represent a business, or where that contract basis does not apply, we rely on our legitimate interest in responding to business enquiries and maintaining relevant correspondence, under Article 6(1)(f), after considering your interests and rights.
Other purposes and lawful bases
We process technical and security information to operate the website, deliver forms and email, prevent abuse and investigate problems. The basis is our legitimate interest in maintaining secure, reliable services. Where storage on or access to your device requires consent, we obtain that consent separately through the cookie controls. A legitimate-interest basis does not replace consent for optional cookies.
Optional website analytics and related identifiers are used with your consent, under Article 6(1)(a). Consent records are used to apply your preferences and demonstrate compliance with our legal obligations. We also process information where necessary to comply with a legal obligation or to establish, exercise or defend legal claims, using the basis appropriate to that purpose.
Enquiries and email communications
When you submit an enquiry, we use your information to deal with that request. You are not subscribed to marketing. Relevant replies may include a requested proposal, appointment arrangements and reasonable follow-up on the same enquiry. We do not use the enquiry list for newsletters, general promotions or automated marketing nurture campaigns. If we introduce email subscriptions later, we will provide the relevant information and establish an appropriate marketing permission before using your details for that purpose.
You can ask us to stop following up an enquiry by emailing will@desti-ads.com. Accepting advertising or analytics cookies is a separate choice from subscribing to email marketing.
Who receives information
We use service providers where needed to operate the website and manage enquiries. HubSpot provides the enquiry form and CRM. Microsoft 365, supplied through GoDaddy, provides our business mailbox and related communications. CookieYes manages cookie preferences and consent records. Google provides Google Tag Manager and consent-based GA4 analytics. Our planned website hosting provider is Hostinger; the hosting details will be confirmed when the site is deployed.
Relevant providers may use approved subprocessors for infrastructure, security and support. We restrict access to people who need the information for their work and use data-processing terms where providers act on our instructions. Providers can also act as independent controllers for their own legally defined purposes; their own privacy notices explain those activities. We may disclose necessary information to professional advisers, insurers, courts, regulators or public authorities where appropriate and legally permitted or required. We do not sell your enquiry information.
International processing
Some providers and their subprocessors operate internationally. Personal data may therefore be processed or accessed outside the European Economic Area, even where a service offers European hosting. Where a transfer is subject to GDPR transfer rules, we use an applicable adequacy decision or appropriate safeguards such as the European Commission's Standard Contractual Clauses, together with additional measures where needed. An adequacy framework is relied on only where the recipient and transfer are covered by it. Contact us for information about the safeguards relevant to your data.
Whether you must provide information
You can browse without accepting optional cookies. Information marked as required on an enquiry form is needed to receive and respond to that request. If you do not provide a usable contact method or sufficient enquiry information, we may be unable to respond. Other requested information is optional unless clearly indicated otherwise. Cookie choices do not enrol you in email marketing.
How long we keep information
For an enquiry that does not become a client relationship, we retain the enquiry record and relevant correspondence for up to 12 months after the last meaningful contact about that enquiry. Passive website visits or analytics events do not restart this period. We then delete or irreversibly anonymise the information unless a specific legal obligation or documented legal claim requires the relevant records to be retained longer.
Where an enquiry becomes an engagement, relevant information becomes part of the client record and is retained according to the contract, applicable legal duties and any justified need to deal with claims. Irish tax and accounting records are generally retained for six years, or longer where a particular legal requirement applies. This does not mean every unsuccessful enquiry is retained for six years.
We use a 14-month GA4 user-level and event-level retention setting. Deletion follows Google's scheduled processing. Standard aggregated reports can remain available for longer and are not governed by that setting. Browser-cookie expiry is separate and is explained in the Cookie Policy and cookie controls. Cookie preference records in your browser are stored for up to 180 days before a renewed choice is requested, unless you change them sooner.
Security logs are kept only for the operational period needed to identify faults, detect abuse and investigate incidents, according to the relevant service settings. Material relating to a specific incident may be retained until it is resolved and any associated legal obligation or claim is addressed. We keep the minimum records needed to handle privacy requests and demonstrate compliance. Deleted information may remain temporarily in protected backups until overwritten under the provider's backup cycle; those copies are not used for routine business activity.
Your rights and choices
Depending on the circumstances, you can request access to your personal data, correction of inaccurate information, erasure, restriction of processing and portability of data covered by that right. You can object to processing based on legitimate interests. We must then stop that processing unless there are overriding legitimate grounds or it is needed for legal claims. You can withdraw consent at any time without affecting processing that was lawful before withdrawal. These rights have conditions and exceptions under data-protection law.
Use Cookie settings on the website to change or withdraw optional-cookie consent. For other requests, email will@desti-ads.com or write to the correspondence address above. We may ask for proportionate information to verify your identity. We normally respond without undue delay and within one month. If the law permits an extension for complexity or the number of requests, we explain the reason within the initial month. Requests are normally free of charge.
You may complain directly to the Irish Data Protection Commission at www.dataprotection.ie, including through its online contact service. Its postal address is Data Protection Commission, 6 Pembroke Row, Dublin 2, D02 X963, Ireland. You may also complain to the competent supervisory authority where you live or work. You do not need to contact us first.
Security and automated decisions
We use appropriate technical and organisational measures to protect personal data, with access limited according to business need. No internet service can guarantee absolute security. Desti Ads does not make decisions about you based solely on automated processing that produce legal or similarly significant effects. Automated security and spam checks may help protect forms and services.
Changes to this policy
We update this policy when relevant services or processing change. The version date identifies the latest revision. Where a new use requires further notice or consent, we provide that information and obtain the required permission before starting that use. A policy update alone does not subscribe existing enquirers to marketing.