Privacy policy

1. Data controller

Name

Marco Lohmann

NIF

Y8537566A

Address

newways.consulting
Monsenyor Palmer 1
07014 Palma
Illes Balears · España

Email

mlo@newways.consulting

2. Purposes of processing

We process the data you submit for the following purposes:

• Handling enquiries sent through the contact forms
• Providing the professional services commissioned
• Sending commercial communications (only with prior consent)
• Statistics (Google Analytics) and ad measurement (Google Ads), only with your consent (section 7)
• Attributing an enquiry to the campaign through which you arrived (section 7)
• Protecting the forms against abuse (time and IP address of an enquiry)

Your enquiry also includes your voluntary answer on how you found us.

3. Legal basis

The legal basis for processing is:

• the consent of the data subject for enquiries, subscriptions, statistics and ad measurement
• the performance of a contract for the provision of professional services
• the legitimate interest of the controller in the technical security of the website and in evaluating its advertising (section 7)

4. Retention periods

Data is retained for as long as necessary to fulfil the purpose for which it was collected and to determine any liability arising from that purpose and from the processing.

5. Recipients

Data is not passed to third parties, except where required by law, where necessary for the provision of the service (for example hosting providers or tax advisors), or where you have consented: to Anthropic for the consulting assistant (section 6), to Google for statistics and ad measurement (section 7) and to Google/YouTube when you start a film (section 8).

6. The consulting assistant on this site

This website offers an AI-supported consulting assistant. To generate a response, your input is transmitted to and processed by Anthropic PBC (Anthropic, San Francisco, USA); this constitutes a transfer to a third country. Anthropic processes the input on our behalf; the transfer is based on the European Commission’s standard contractual clauses (Implementing Decision (EU) 2021/914), which form part of Anthropic’s contractual terms. You can obtain a copy on request from mlo@newways.consulting. The legal basis is your consent through active use of the assistant (Art. 6(1)(a) GDPR).

We do not store the conversations permanently; the conversation exists only in your browser and in the individual request to the service. Please do not enter personal or confidential data into the assistant. The assistant does not replace advice and makes no decisions about you.

7. Reach measurement and advertising (Google Analytics 4, Google Ads)

With your consent, we use two Google services on all pages of this website, which you can also choose individually under “Settings” in the notice: Google Analytics 4 for statistics (which pages are used and how) and Google Ads conversion measurement for ad measurement (through which advertisement visitors arrive and whether this leads to an enquiry). The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Both services are only loaded after you have consented; until then no script is loaded from Google and no cookie is set. The legal basis is your consent (Art. 6 (1) (a) GDPR, Art. 22 (2) LSSI; for access to your device from Germany, § 25 (1) TDDDG). We store your choice in your browser (localStorage, without any identifier); after twelve months we ask again.

After your consent, Google sets cookies and storage entries (see Cookies) and receives usage data: pages viewed, device and browser, approximate location, common usage events such as scrolling or clicks on links to other websites and, for ad measurement, the click identifier of an advertisement. We also explicitly measure the successful submission of an enquiry form and clicks on the phone number, WhatsApp, the e-mail address and the booking link of newways.suite. For qualified contact enquiries, enquiry type and business location are recorded as predefined categories. Your name, e-mail address and message are not sent to Google. Google keeps the event data of the statistics for no longer than 14 months.

Data may be transferred to Google LLC in the USA. Google LLC is certified under the EU-US Data Privacy Framework, for which an adequacy decision of the European Commission of 10 July 2023 exists. Google Signals, ad personalisation and remarketing are switched off.

You can withdraw or change your consent at any time with effect for the future: via “Cookie settings” in the footer of every page. If you withdraw something there, we delete Google’s cookies and storage entries for this website in your browser and reload the page without that service. Cookies that Google sets on its own domains can be removed in your browser settings.

Campaign details and click identifier in enquiries. If you reach us through an advertisement or a campaign link, the address you open contains campaign details (utm_…, von) and usually a click identifier (for example gclid). If you submit an enquiry form, the campaign details become part of your enquiry to us; that tells us through which campaign an enquiry came. They are not sent to Google this way. The legal basis is our legitimate interest in evaluating our advertising (Art. 6 (1) (f) GDPR). You may object to this processing at any time (Art. 21 GDPR), for example by e-mail to mlo@newways.consulting. We only include the click identifier itself in the enquiry with your consent to ad measurement; the site then also keeps the details until you close the tab (sessionStorage nw-klick), so that an enquiry from a later page can be attributed. If you only consent to statistics, Google Analytics receives the address you opened without the click identifier.

8. Films

The short, silent film loops and the films that open in this site’s own player window (for example the company film “The Dot.”), as well as the 52-second SENYA product film, are served from our own server. Playing them transmits no data to third parties.

Some of our brand, product and client films on the classic website and in the 3D Quartier are embedded from YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). They are only loaded when you explicitly start them; until then no connection to YouTube is made. After the click, data is transmitted to Google; the embed uses youtube-nocookie.com. The legal basis is your consent given by clicking (Art. 6 (1) (a) GDPR).

9. Your rights

You have the right to obtain confirmation as to whether we process your personal data, together with the rights to:

• access, rectification and erasure
• restriction of processing and objection
• data portability

To exercise these rights, an email to mlo@newways.consulting is sufficient. If there are reasonable doubts about your identity, we may request additional information (Art. 12(6) GDPR). You also have the right to lodge a complaint with the Spanish data protection authority (AEPD).