Privacy Policy

Last updated: October 2026

1. Introduction

Paulo Airaudo Group ("we", "us", "our") respects your privacy and is committed to protecting your personal data in accordance with Regulation (EU) 2016/679 (GDPR) and Spain's Organic Law 3/2018 (LOPDGDD). This policy explains how we collect, use, and protect personal data when you visit pauloairaudo.com ("the Site").

2. Data Controller

The data controller responsible for the processing of personal data through this Site is:

Legal name: Made In Mordor, S.L.
Tax ID (CIF): B-10592632 (VAT ESB10592632)
Registered address: Prim Kalea, 1, 20005 Donostia – San Sebastián, Gipuzkoa, Spain
Email: info@pauloairaudo.com

Company registered in the Registro Mercantil de Gipuzkoa.

For full company identification details, see our Legal Notice.

3. Information We Collect

We may collect the following categories of data:

  • Contact information — name, email address, and phone number submitted through our contact form or reservation inquiries.
  • Job applications — CV, cover letter, and professional details you send us when applying for a position.
  • Technical data — IP address, browser type, device information, and browsing patterns collected automatically through cookies, server logs, and error-reporting (used to keep the Site secure and functioning).
  • Newsletter — email address provided when subscribing to our newsletter.

4. How We Use Your Data

  • To respond to contact inquiries and reservation requests
  • To process job applications
  • To send newsletters (only with your explicit consent)
  • To measure and improve the Site (analytics — only with your consent)
  • To keep the Site secure and prevent abuse
  • To comply with legal obligations

5. Legal Basis (GDPR Art. 6)

We process your data on the following legal bases:

  • Consent — for the newsletter and for analytics and other non-essential cookies. You may withdraw consent at any time.
  • Performance of a contract / pre-contractual steps — for handling reservation requests and processing job applications you submit.
  • Legitimate interest — for the security of the Site, prevention of abuse, and error logging. Strictly-necessary cookies rely on this basis and on Art. 22.2 LSSI.
  • Legal obligation — where processing is required by applicable law.

6. Data Sharing

We do not sell your personal data. We may share data with trusted service providers acting as data processors on our behalf — including website hosting, email delivery, reservation platforms (e.g. SevenRooms), analytics (Google Analytics) and the AI assistant our team uses to manage this website (Claude, by Anthropic) — under data-processing agreements that meet GDPR Art. 28. We may also disclose data when required by law.

7. Data Retention

We retain personal data only as long as necessary for the purposes described above, or as required by law. Contact form inquiries are retained for up to 12 months. Job applications are retained for the duration of the recruitment process plus 12 months. Newsletter data is kept until you unsubscribe.

8. Your Rights

Under the GDPR and Spanish data protection law (LOPDGDD), you have the right to:

  • Access the personal data we hold about you
  • Request rectification of inaccurate data
  • Request erasure of your data ("right to be forgotten")
  • Restrict or object to processing
  • Data portability
  • Withdraw consent at any time

To exercise these rights, email us at info@pauloairaudo.com. You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.

9. International Transfers

As an international group with operations in Spain, Italy, Thailand, Hong Kong and other countries — and because some of our processors (e.g. Google Analytics and Anthropic) are based outside the European Economic Area (EEA) — your data may be transferred outside the EEA. Where this occurs, we ensure appropriate safeguards are in place as required by the GDPR, such as the European Commission's Standard Contractual Clauses (SCCs) or an adequacy decision.

10. Cookies

We use cookies and similar technologies as described in our Cookie Policy. Non-essential cookies are only set with your prior consent, which you can change or withdraw at any time via the "Cookie settings" link in the footer.

11. Changes to This Policy

We may update this policy from time to time. Changes will be posted on this page with an updated revision date. We encourage you to review this page periodically.

Privacy Policy · Paulo Airaudo