PRIVACY POLICY
Last updated: May 2026
1. WHO IS RESPONSIBLE FOR YOUR DATA
Sara Llopis Noble, trading as The Subtle Garden Travessera de Gràcia 347, Barcelona, Spain hello@thesubtlegarden.com
As a business based in Spain, we process personal data in full compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on Personal Data Protection and Digital Rights (LOPDGDD).
2. WHAT DATA WE COLLECT AND WHY
When you book a consultation or accompaniment We collect your name, email address, and any information you share during the booking process or session. Legal basis: performance of a contract.
When you complete our formula questionnaire We collect your name, email address, and your responses in order to recommend the most suitable formula for your needs. Legal basis: your consent. You may withdraw this consent at any time by contacting us.
When you subscribe to our newsletter (Letters from the Garden) We collect your name and email address to send you our Substack publication. Legal basis: your consent. You may unsubscribe at any time via the link in any newsletter email.
When you contact us We collect your name, email address, and the contents of your message in order to respond to your enquiry. Legal basis: our legitimate interest in responding to communications received.
When you visit our website We collect standard technical data including your IP address, browser type, and pages visited, through cookies and analytics tools provided by Squarespace. Legal basis: our legitimate interest in understanding how our website is used, and where required, your consent via cookie settings.
3. HOW LONG WE KEEP YOUR DATA
We retain your personal data only for as long as necessary for the purpose for which it was collected, or as required by law. Specifically:
Consultation and booking data is retained for 4 years in accordance with Spanish civil law limitation periods. Newsletter subscriber data is retained until you unsubscribe. Contact form enquiries are retained for 1 year unless an ongoing relationship develops. Questionnaire responses are retained for 6 months or until a consultation takes place, whichever comes first.
4. WHO WE SHARE YOUR DATA WITH
We do not sell your personal data to any third party. We share data only where necessary with trusted service providers who help us operate our business:
Squarespace — website hosting and contact form Typeform — formula questionnaire Substack — newsletter Booking system provider — consultation scheduling
All providers are required to handle your data securely and in compliance with applicable law. Where providers are based outside the EU, appropriate safeguards are in place in accordance with GDPR Chapter V.
5. YOUR RIGHTS UNDER GDPR
As a resident of the European Economic Area you have the following rights:
Right of access — to request a copy of the personal data we hold about you. Right to rectification — to request correction of inaccurate or incomplete data. Right to erasure — to request deletion of your personal data, subject to legal obligations. Right to restriction of processing — to request that we limit how we use your data. Right to data portability — to receive your data in a portable, commonly used format. Right to object — to object to processing based on legitimate interest. Right to withdraw consent — where processing is based on consent, to withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at hello@thesubtlegarden.com. We will respond within one calendar month as required by GDPR Article 12.
You also have the right to lodge a complaint with the Spanish Data Protection Authority: Agencia Española de Protección de Datos (AEPD) www.aepd.es
6. COOKIES
Our website uses cookies to function correctly and to understand how visitors use it. These include essential cookies necessary for the website to operate, and analytics cookies that help us understand visitor behaviour. You may control and withdraw cookie consent at any time through your browser settings or our cookie banner. Disabling certain cookies may affect the functionality of the website.
7. SECURITY
We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. However no method of transmission over the internet is completely secure and we cannot guarantee absolute security.
8. THIRD PARTY WEBSITES
Our website may contain links to third party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies independently.
9. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. We encourage you to review this page periodically.
10. CONTACT
For any questions about this Privacy Policy or how we handle your personal data: hello@thesubtlegarden.com The Subtle Garden — Travessera de Gràcia 347, Barcelona, Spain