Privacy Policy

Last updated: 19 September 2026

1. Guiding principles

Your privacy is very important to us. This Privacy Policy explains the steps we take to protect your personal data, the information we collect, the purposes for which we use it, the legal bases on which we rely, how long we keep it, and the rights you have under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD).

The website https://www.stemeditor.com (the “Website”) is operated by Alexander Comely, self-employed professional (autónomo), NIF X4942814E, with registered address at Carrer Unic 3, Clua de Meià, Artesa de Segre 25737, Spain (hereinafter “we”, “us” or “STEM Editor”).

Our processing of personal data is governed by the laws of Spain and by the GDPR. This Privacy Policy forms part of our Terms and Conditions and should be read together with them. We never sell personal data about our clients to anyone.

2. Data controller

The data controller is:

Name: Alexander Comely

NIF: X4942814E

Address: Carrer Unic 3, Clua de Meià, Artesa de Segre 25737, Spain

Email: info@stemeditor.com

We have not appointed a Data Protection Officer (DPO) because we are not required to do so under Article 37 GDPR or Article 34 LOPDGDD.

3. What personal data we collect

Depending on how you interact with us, we may process the following categories of personal data:

3.1 Data you provide when you contact us or place an order

• Full name

• Email address

• Tax domicile / fiscal address (required for invoicing under Spanish tax rules)

• The document(s) you upload for proofreading/editing and any special instructions

• Any other information you voluntarily include in your enquiry or order

3.2 Data collected automatically when you visit the Website

• IP address

• Browser type and version, device information, and operating system

• Pages visited, date and time of access, and referring URL

• Cookie identifiers and similar technologies (see Section 8)

3.3 Payment-related data

When you pay via PayPal (including credit/debit card payments processed through PayPal), we do not receive or store full card numbers, CVV codes or bank-account details. PayPal processes those data as an independent controller under its own privacy policy. We only receive confirmation of payment, the amount, currency, transaction ID and the billing name/email associated with the payment.

4. Purposes and legal bases for processing

We process personal data only for the purposes set out below and on the legal bases indicated:

4.1 Providing the proofreading and editing service

Purpose: To receive, track and fulfil your order, to communicate with you about the order, to deliver the edited files, and to handle any follow-up queries.

Legal basis: Performance of a contract (Art. 6(1)(b) GDPR).

4.2 Invoicing and tax compliance

Purpose: To issue invoices and to comply with Spanish tax, accounting and anti-money-laundering obligations.

Legal basis: Compliance with a legal obligation (Art. 6(1)(c) GDPR).

4.3 Responding to enquiries

Purpose: To answer questions you send by email or through the Website.

Legal basis: Pre-contractual measures or legitimate interest in providing customer service (Art. 6(1)(b) or (f) GDPR).

4.4 Website security, diagnostics and aggregated statistics

Purpose: To keep the Website secure, to diagnose technical problems, and to produce aggregated (non-identifying) statistics that help us improve the site.

Legal basis: Legitimate interest in running a secure and functional website (Art. 6(1)(f) GDPR).

4.5 Analytics cookies (if you consent)

Purpose: To understand how visitors use the Website so we can improve layout and navigation.

Legal basis: Consent (Art. 6(1)(a) GDPR and Art. 22(2) LSSI-CE). You may withdraw consent at any time.

4.6 Legal claims and fraud prevention

Purpose: To establish, exercise or defend legal claims, and to prevent or investigate fraud or other illegal activity.

Legal basis: Legitimate interest or legal obligation (Art. 6(1)(f) or (c) GDPR).

5. Recipients and processors

We do not sell or rent personal data. We share data only with the following categories of recipients, and only to the extent necessary.

Jotform Inc.: the online form platform through which orders are submitted. Jotform acts as a data processor under a Data Processing Addendum that includes Standard Contractual Clauses. You may choose EU data residency within Jotform where available.

PayPal (Europe) S.à r.l. et Cie, S.C.A.: payment gateway. PayPal processes payment data as an independent controller under its own privacy policy (available at paypal.com). We never receive full card or bank details.

Contract editors: freelance editors who perform the proofreading/editing work. They receive only the documents necessary to complete the assignment and are bound by written non-disclosure and data-protection obligations. Identifying customer data (name, email, address) is not shared with editors unless strictly required.

Hosting and email providers: the companies that host the Website and provide email services. They act as processors under appropriate contractual safeguards.

Tax and accounting advisers (gestoría): only the data required for invoicing and tax compliance.

Competent authorities: when we are legally required to disclose information (e.g. tax authorities, courts, police).

We do not transfer personal data outside the European Economic Area except where the recipient is covered by an adequacy decision, Standard Contractual Clauses, or another valid transfer mechanism under Chapter V GDPR (for example, Jotform’s EU–US Data Privacy Framework participation or SCCs).

6. Retention periods

Client documents submitted for editing: securely deleted 15 days after the edited files are returned to you. If you prefer earlier deletion, email us at info@stemeditor.com.

Order, invoicing and tax records: retained for the periods required by Spanish tax and commercial law (generally 4–6 years after the end of the relevant financial year).

Enquiry correspondence: retained for as long as needed to handle the enquiry and for a reasonable period thereafter (normally up to 2 years) unless a longer period is required for legal claims.

Server logs and technical data: normally retained for a short period (typically 30–90 days) for security and diagnostic purposes.

Analytics data: retained according to the settings of the analytics tool and only while consent remains valid.

7. Your rights

Under the GDPR and LOPDGDD you have the following rights:

Access: to obtain confirmation of whether we process your data and a copy of it.

Rectification: to have inaccurate or incomplete data corrected.

Erasure (“right to be forgotten”): to request deletion of your data in the circumstances set out in Art. 17 GDPR.

Restriction: to request that processing be limited in certain cases.

Portability: to receive your data in a structured, commonly used and machine-readable format and to transmit it to another controller where technically feasible.

Objection: to object to processing based on legitimate interests.

Withdrawal of consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, please write to us at info@stemeditor.com or by post to the address given in Section 2. We may ask for additional information to verify your identity before responding. We will reply within one month (extendable by two further months in complex cases).

You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD) at www.aepd.es if you consider that our processing infringes data-protection law.

8. Cookies and similar technologies

A cookie is a small file of letters and numbers that we store on your browser or device. We use first-party and third-party cookies, pixels and similar technologies.

8.1 Strictly necessary cookies

These cookies are essential for the Website to function (for example, to maintain a session or to remember cookie-consent choices). They do not require consent under Art. 22(2) LSSI-CE.

8.2 Analytics and other non-essential cookies

We may use analytics tools (for example Google Analytics or equivalent) to understand how the Website is used. These cookies are set only if you give prior consent via the cookie banner. You may refuse or withdraw consent at any time without affecting the basic functionality of the Website.

You can also control cookies through your browser settings. Useful information is available at www.allaboutcookies.org. Disabling certain cookies may affect site performance.

9. Security measures

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction or alteration. Order forms and file uploads are transmitted using SSL/TLS encryption (normally 256-bit or higher). Documents are stored only for the time needed to perform the service and are then securely deleted. Contract editors are bound by confidentiality obligations. No method of transmission or storage is completely secure; you remain responsible for the security of your own devices and for any residual copies you keep.

10. Minors

Our services are directed at adults and businesses. We do not knowingly collect personal data from children under 14. If you believe a child has provided us with personal data, please contact us so that we can delete it.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be notified on the Website or by email where appropriate. The “Last updated” date at the top of this document indicates the latest revision.

12. Contact

If you have any questions about this Privacy Policy or about how we process your personal data, please contact us at:

Alexander Comely – STEM Editor

Carrer Unic 3, Clua de Meià, Artesa de Segre 25737, Spain

Email: info@stemeditor.com

Thank you for reading our Privacy Policy.