Lufran Solutions
Privacy policy
You can visit this website without leaving a trace: it has no forms, cookies, analytics or third-party content. Here we explain which data is processed anyway and what rights you have under Andorran Law 29/2021 of 28 October on the protection of personal data (Llei 29/2021).
Controller
Lucas Ezequiel Palma (Lufran Solutions), Andorra. Contact: info@lufransolutions.com.
What data we process and why
When you visit. Cloudflare, our hosting provider, receives the technical data every browser sends (IP address, date and time, requested page and browser type) to serve the website and protect it from attacks. We don’t use this data to identify you or to count visits, and we keep no visit logs.
If you write to us. If you email info@lufransolutions.com, we process your email address, your name if you give it and the content of your message, only to reply to you.
Receipt confirmation. When you write to info@lufransolutions.com you receive an automatic reply confirming that your message arrived. To decide whether to send it, a Cloudflare service (Email Routing and a Worker) reads a copy of the message at that moment, without storing it. So that no one can use this address to send emails to third parties, at most one confirmation is sent per message and one a day to the same person, with an overall hourly limit. For this, three counters with pseudonymous references (HMAC), never email addresses, are kept in a Cloudflare database in the European Union and deleted after 8 days.
Legal basis
Serving and protecting the website: our legitimate interest in keeping it available and secure.
Replying to your messages: our legitimate interest in answering your questions or, if you ask about our apps, steps taken at your request before any possible agreement.
Sending the receipt confirmation: our legitimate interest in confirming to whoever writes that their message arrived.
Retention
Emails and their data are kept for up to 12 months after your last message, unless a legal obligation requires keeping them longer or you ask us to delete them sooner.
Cloudflare processes technical visit data under its data processing agreement, only for the purposes above.
The receipt-confirmation counters (pseudonymous references, no addresses) are deleted after 8 days.
Recipients
Cloudflare, Inc., which hosts and protects the website and, through Email Routing and a Worker, decides whether to send the receipt confirmation, as a processor.
Google (Google Workspace), which hosts the info@lufransolutions.com mailbox and sends the receipt confirmation, as a processor.
We never sell or share your data. We would only disclose it to an authority if the law required us to.
International transfers
Cloudflare and Google may process this data outside Andorra, including in the United States, with the safeguards set out in their data processing agreements, such as standard contractual clauses.
Your rights
You can ask for access to, rectification or erasure of your data, restrict or object to its processing, or request its portability by writing to info@lufransolutions.com. We’ll reply without delay.
If you believe we have mishandled your data, you can lodge a complaint with the Andorran Data Protection Agency (Agència Andorrana de Protecció de Dades, APDA) at apda.ad and, where applicable, with the data protection authority in your country.
Cookies and storage
This website uses no cookies and stores nothing on your device. It also uses no analytics, advertising, external fonts or third-party videos or maps.
Automated decisions
We make no automated decisions and build no profiles with your data.
Changes
If we change anything important, we’ll publish it here with a new update date.