newways

newways · nwcustomers.com

Privacy policy

Overview and scope

Please note: This is a courtesy translation for your convenience. The binding version is the German/Spanish original. In case of any discrepancy, the original prevails: Datenschutz / política de privacidad.

newways.consulting attaches great importance to the protection of your data. This statement explains which data we collect on nwcustomers.com, the client area of newways.consulting, how we use it and with whom we share it. You retain control over your data and may inspect, update and have your personal information amended at any time.

For the previews on subdomains of nwcustomers.com (*.nwcustomers.com, except the status page status.nwcustomers.com), this statement applies only insofar as hosting and the server log files are concerned (section 11). The previews are drafts of client websites whose content and functions are the responsibility of the respective clients. What section 7 says about cookies, browser storage, statistics and third-party content applies only to the nwcustomers.com client area itself. Section 10 applies to the status page status.nwcustomers.com, which a service provider operates on our behalf.

The key points in brief: The client area uses neither cookies nor any other browser storage, does without statistics and advertising and loads nothing from third-party servers. When you merely visit the client area, only our web server at mittwald in Germany stores server log files (section 6).

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 transmit for the following purposes:

3. Legal basis

The legal basis for processing is:

You are under no legal obligation to provide us with personal data. However, without the data transmitted when you open a page (section 6), we cannot deliver the pages to you; without your contact details, we cannot answer your enquiry; and without the information required for a commission, we cannot conclude or perform a contract.

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. Section 6 applies to the server log files.

5. Recipients

Data is passed to third parties only where required by law or in the following cases. The recipients are mittwald as the hosting provider of the client area and the previews (section 6), the providers of our email mailboxes and of our telephone line, and our tax advisors. When you use the status page status.nwcustomers.com, the recipients are Hyperping and its sub-processors, in particular Vercel Inc. and Cloudflare, Inc., as well as Google, from which the page requests a font (section 10). If you write to us via WhatsApp, WhatsApp also receives your data (section 10).

For operating the client area and hosting the previews, we do not transfer any data to countries outside the European Economic Area (third countries); according to mittwald, the servers are located in Germany (section 6). If you open the status page or use WhatsApp, data may be transferred to the USA (section 10).

6. Hosting and server log files

The client area and the previews on subdomains of nwcustomers.com are hosted on a virtual server (vServer) provided by Mittwald CM Service GmbH & Co. KG, Königsberger Straße 4-6, 32339 Espelkamp, Germany (“mittwald”). According to mittwald, the servers are located in data centres in Germany. As a processor, mittwald processes the data on our behalf under a data processing agreement concluded with us (Art. 28 GDPR).

Each time a page or file is requested, the web server writes an entry to its access logs (server log files). According to mittwald, these contain:

If an error occurs, an error log records the error message, the requesting IP address and, depending on the error, the page requested.

We need this data to deliver the pages and to operate the server securely, for example to detect and address attacks and errors. The legal basis is our legitimate interest in a secure and functioning website (Art. 6(1)(f) GDPR). We do not analyse the logs for statistics or advertising. They are stored only for as long as is necessary for these purposes and are then deleted or anonymised. Your right to object is described in section 12.

7. No cookies, no statistics, no third-party content

The client area does not set any cookies and does not use any other storage in your browser, such as localStorage or sessionStorage. In the client area, we do not use any statistics or analytics services and do not show any advertising.

Fonts, images and the short, silent film loops are stored on our server at mittwald. The client area does not load any content, fonts or scripts from third-party servers; playing the film loops transmits no data to third parties. The client area uses JavaScript only for animations.

These statements apply only to the nwcustomers.com client area itself, not to the previews on its subdomains (section 11) or to the status page (section 10).

8. Language selection

When you open the home page, the server evaluates the language setting that your browser sends with every request (Accept-Language) and, where applicable, redirects you to the English (/en/) or Spanish (/es/) version. The purpose is to show you the client area in a suitable language. For this, the language setting is only read, not stored; we do not store your choice of language either. You can change the language at any time using the language switcher in the header of every page. The legal basis is our legitimate interest in displaying the client area in a suitable language (Art. 6(1)(f) GDPR).

9. Contact by email, phone or WhatsApp

There are no forms in the client area. If you send us an email, for example to hello@newways.consulting, or call us (+34 871 242 440), we process the details you provide – usually your name, email address or phone number and the content of your enquiry – in order to handle your enquiry. The same applies to messages via WhatsApp (section 10). The email and phone links only open your email program or your phone app; the client area itself does not transmit any data in the process.

The legal basis is your consent (Art. 6(1)(a) GDPR). Where your enquiry concerns an existing or planned commission, we process it to perform the contract or to take steps prior to entering into a contract (Art. 6(1)(b) GDPR). Section 4 applies to retention.

10. Links to other services

The client area links to other services. As long as you do not click on a link, no connection to these services is established and no data flows to them. Only when you click do you leave nwcustomers.com; your browser then opens the linked page and, in doing so, transmits technically necessary data such as your IP address to it.

11. Previews of client websites

On subdomains of nwcustomers.com (*.nwcustomers.com, except the status page status.nwcustomers.com), we show our clients drafts of their websites while these are in progress. The previews are blocked from search engines; we do not link to them publicly but send the links personally. They are hosted on the same server at mittwald. Each request generates the same server log entries as described in section 6; the purpose, legal basis and retention period are the same.

For the previews, this statement applies only insofar as hosting and the server log files are concerned; section 7 does not apply to them. The respective clients are responsible for the content and functions of the drafts.

12. Your rights

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

Right to object: Where we process data on the basis of our legitimate interest (Art. 6(1)(f) GDPR; sections 6, 8, 10 and 11), you may object to this processing at any time on grounds relating to your particular situation (Art. 21(1) GDPR).

You can withdraw any consent you have given at any time with effect for the future; this does not affect the lawfulness of the processing carried out before the withdrawal.

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, www.aepd.es/en).

No automated decision-making, including profiling (Art. 22 GDPR), takes place.

Last updated: November 2026

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