Privacy Policy

Last updated: July 24, 2026

1. Data Controller

In compliance with Regulation (EU) 2016/679, the General Data Protection Regulation —GDPR—, and Organic Law 3/2018, on Personal Data Protection and Guarantee of Digital Rights —LOPDGDD—, it is hereby informed that the data controller for personal data collected through these websites is:

Controller: Wajari Velásquez Fernández
Trade name: Wajari
NIF: 77548325F
Professional address: Rúa Alejandro Sesmeros 4, 1B, 36005 Pontevedra, Spain
Email: wajari@wajari.com
Phone: +34 661 815 431

This privacy policy applies to personal data processed through:

• https://wajari.com
• https://cursos.wajari.com
• Forms, services, private areas, and content associated with both websites.

2. Principles Applied to Data Processing

Personal data will be processed in accordance with the following principles:

• Lawfulness, fairness, and transparency: users will be informed of the purposes for which their data is used.
• Purpose limitation: data will be collected for specified, explicit, and legitimate purposes.
• Data minimization: only data necessary for each purpose will be requested.
• Accuracy: efforts will be made to keep data correct and up-to-date.
• Storage limitation: data will not be kept longer than necessary.
• Integrity and confidentiality: reasonable measures will be adopted to protect data against unauthorized access, loss, destruction, or alteration.

3. Personal Data That May Be Collected

Depending on the user’s relationship with Wajari, the following categories of data may be processed:

Identification and contact data

• Full name.
• Email address.
• Phone number.
• Postal or billing address.
• Company or entity you work for.
• NIF, CIF, or tax identification number.

Data related to inquiries and services

• Information included in messages and contact forms.
• Data related to the user’s company, project, or website.
• URL of the website to be analyzed.
• Information about competitors, objectives, needs, or requested services.
• Communications maintained via email, phone, or video call.

Data related to courses

• Courses purchased.
• Purchase date.
• Order status.
• Course progress.
• Exercises, assignments, evaluations, and submitted answers.
• Participation in live sessions or communities linked to training.
• Technical data related to platform access.

Financial and billing data

• Data necessary for issuing invoices.
• Purchase and payment history.
• Payment method used.
• Information regarding returns or refunds.

Wajari does not directly store full bank card details. This data is processed by the respective payment providers.

Subscription and commercial communications data

• Name.
• Email address.
• Subscription date and origin.
• Consent granted.
• Information on opening or interacting with messages, when the tool used provides this data.

Technical and browsing data

• IP address.
• Browser and device type.
• Operating system.
• Date and time of access.
• Pages visited.
• Identifiers provided by cookies or similar technologies.
• Technical information necessary to ensure the security and operation of the website.

The use of non-essential cookies will be governed by the cookie policy and the preferences selected by the user in the settings panel.

Blog comments

When a user leaves a comment, the following may be collected:

• Data entered in the form.
• IP address.
• Browser information.
• An anonymized string or hash generated from the email, which may be sent to Gravatar to check if the user uses this service.

Once the comment is approved, the name, comment content, and, where applicable, the profile picture may be publicly visible.

4. Purposes and Legal Bases of Processing

4.1. Address inquiries and information requests

Data sent via forms, email, phone, or any other contact channel will be used to:

• Respond to inquiries.
• Analyze user needs.
• Prepare quotes or proposals.
• Provide information about professional services.
• Arrange meetings.
• Maintain communications prior to a potential contract.

Legal basis: application of pre-contractual measures requested by the data subject and, where applicable, consent.

4.2. Provide professional services

When the user contracts SEO consulting, auditing, advisory, training, or other professional services, data will be processed to:

• Manage the contractual relationship.
• Provide the contracted services.
• Maintain communication with the client.
• Share reports, documents, videos, and work materials.
• Monitor the project.
• Manage incidents and support.
• Comply with administrative, accounting, and tax obligations.

Legal basis: performance of a contract and compliance with legal obligations.

4.3. Manage free SEO audits

Data sent via the free audit form may be used to:

• Verify the information provided.
• Analyze the indicated website.
• Perform technical crawls and content analysis.
• Prepare and send audit results.
• Contact the applicant regarding said audit.

The user declares that they are authorized to request the analysis of the indicated website.

Legal basis: user consent and application of pre-contractual measures requested by the user.

Data will not be used to send subsequent commercial communications unless the user has given specific consent for this.

4.4. Manage course purchases and access

Student and buyer data will be used to:

• Process orders.
• Process payments.
• Create and manage user accounts.
• Facilitate access to purchased content.
• Manage student progress.
• Correct exercises or evaluations.
• Organize live training sessions.
• Resolve course-related inquiries.
• Manage refund requests.
• Send essential communications related to the acquired training.

Legal basis: performance of the sales contract and provision of the training service.

Communications strictly necessary to access the course, receive operational notices, or learn about relevant service changes are not promotional.

4.5. Manage payments

When a purchase is made, certain data will be communicated to the selected payment provider:

• Stripe.
• PayPal.

These providers will process the necessary information to authorize, manage, and verify payment, prevent fraudulent operations, and comply with their own legal obligations.

Wajari does not have access to the full bank card details used by buyers.

Legal basis: performance of the contract, compliance with legal obligations, and fraud prevention.

4.6. Billing, accounting, and taxes

Tax and financial data will be used to:

• Issue and send invoices.
• Manage collections and refunds.
• Maintain accounting records.
• File taxes.
• Address administrative requirements.
• Comply with legal obligations applicable to professional activity.

For these tasks, the FacturaDirecta service, owned by Conductiva Online Services, S.L., may be used.

Legal basis: Compliance with legal obligations and performance of the contract.

4.7. Sending newsletters and commercial communications

When the user voluntarily subscribes, their data will be used to send them:

• Articles and content.
• Tips related to SEO, WordPress, digital marketing, and professional activity.
• Information about courses and services.
• Promotions and offers.
• Invitations to activities or events.
• Other communications related to Wajari.

The management of these communications may be carried out using SendFox.

Legal basis: consent of the data subject.

Contracting a service or course will not automatically imply subscription to commercial communications. When necessary, separate and optional consent will be requested.

The user may withdraw their consent at any time using the unsubscribe link included in each communication or by writing to wajari@wajari.com.

The withdrawal of consent will not affect the lawfulness of processing carried out previously.

4.8. Publication and moderation of comments

Data provided in blog comments will be processed to:

• Publish the comment.
• Identify its author.
• Moderate the content.
• Prevent automated, unlawful, or fraudulent messages.
• Reply to the comment.

Legal basis: user consent and legitimate interest in protecting and moderating the website.

4.9. Website security and operation

Technical data may be processed to:

• Ensure the operation of the web pages.
• Prevent unauthorized access.
• Detect spam, fraud, or malicious activities.
• Fix technical errors.
• Maintain backups.
• Protect systems, accounts, and content.

Legal basis: legitimate interest of the controller in ensuring the security and availability of its systems.

4.10. Analytics and measurement

When authorized by the user through the cookie panel, analytics services may be used to:

• Know the number of visitors.
• Analyze website usage.
• Determine which content is most consulted.
• Improve navigation, content, and services.

Legal basis: user consent.

The user may withdraw or modify their consent at any time from the cookie settings panel.

5. Mandatory Nature of Data

Fields marked as mandatory in forms are necessary to manage the request or provide the corresponding service.

If the user does not provide the necessary data, Wajari may not be able to:

• Respond to your inquiry.
• Prepare a quote.
• Process a purchase.
• Issue an invoice.
• Provide access to a course.
• Properly provide the requested service.

Data requested for receiving commercial communications will always be optional.

6. Origin of Data

Generally, data is provided directly by the data subject through:

• Contact forms.
• Subscription forms.
• Audit forms.
• Purchase processes.
• Course platform registrations.
• Emails.
• Phone calls.
• Meetings or video calls.
• Comments published on the blog.

In services provided to companies, the client may also provide professional data of employees, collaborators, or representatives. In these cases, the person communicating the data must guarantee that they are authorized to do so and that they have informed the affected parties when necessary.

7. Data Retention

Data will be retained for the following periods:

Inquiries and information requests

They will be retained for the time necessary to respond and follow up on the request. If the inquiry does not lead to a contractual relationship, they may be deleted when no longer necessary, unless there is a legitimate reason to retain them for an additional period.

Clients and professional services

They will be retained as long as a contractual relationship exists and, subsequently, for the periods necessary to address potential legal liabilities.

Purchases and students

Data related to orders, course access, payments, and provision of training will be retained as long as necessary to provide the service and address inquiries, incidents, guarantees, or liabilities.

The student account may be maintained as long as they have access rights to the purchased content, without prejudice to the possibility of deleting or anonymizing data that is no longer necessary.

Billing and tax obligations

Invoices and accounting documents will be retained for the periods required by commercial, tax, and accounting regulations.

Subscribers

Data will be retained until the user withdraws their consent or requests to unsubscribe.

Minimum evidence of unsubscription may be kept to prevent unwanted new mailings and demonstrate compliance with legal obligations.

Comments

Comments and their metadata may be retained as long as the content remains published or until the user requests their deletion, provided there is no legitimate reason to keep them.

Technical and security data

They will be retained for the period necessary to analyze incidents, ensure security, and address potential liabilities.

Once the applicable periods have expired, the data will be deleted, anonymized, or blocked as appropriate.

8. Recipients and Service Providers

Wajari does not sell or rent users’ personal data.

To manage the websites and provide its services, it may allow access to certain providers who act as data processors or independent controllers, depending on the nature of the service.

These may include:

LucusHost

Web hosting provider, servers, databases, and technical services related to website operation.

SendFox

Platform used to manage subscriptions, mailing lists, automations, and sending communications.

Stripe

Provider used to process electronic payments and prevent fraudulent operations.

PayPal

Provider used to process electronic payments and manage operations carried out via a PayPal account or other methods supported by the platform.

FacturaDirecta

Software used to manage quotes, invoices, accounting, and tax obligations.

Google

Google services such as the following may be used:

• Google Analytics.
• Google Drive.
• Google Workspace.
• Google Search Console.
• Looker Studio.
• Other services necessary to store documentation, analyze web pages, share reports, or maintain communications.

Data obtained through Google Analytics will only be processed when the user has authorized the corresponding cookies.

WordPress, WooCommerce, and training platform

The websites use WordPress and may employ WooCommerce, Academy LMS, or other extensions to manage content, users, orders, courses, evaluations, and private areas.

Video call and appointment booking services

Platforms such as Zoom or Calendly may be used to organize meetings, advisory sessions, or live classes.

Automattic and Gravatar

When the user publishes comments, Gravatar may be used to display a profile picture associated with the email.

Professional providers and public administrations

Data may also be communicated, when necessary, to:

• Tax, accounting, or legal advisors.
• Financial entities.
• Tax administrations.
• Courts and tribunals.
• Law enforcement agencies.
• Other public authorities when there is a legal obligation.

Providers will only have access to the data necessary to provide their services and will be subject to their corresponding contractual and legal obligations.

9. International Data Transfers

Some of the providers used, such as SendFox, Stripe, PayPal, Google, Zoom, Calendly, Automattic, or Gravatar, may belong to companies located outside the European Economic Area or process data from other countries.

When international data transfers occur, they will be carried out using one of the mechanisms recognized by applicable regulations, such as:

• An adequacy decision by the European Commission.
• The provider’s adherence to the EU-US Data Privacy Framework, where applicable.
• Standard contractual clauses approved by the European Commission.
• Other safeguards recognized by Articles 44 et seq. of the GDPR.

The user can request additional information about the applicable safeguards by writing to wajari@wajari.com.

10. User Rights

The user can exercise the following rights:

• Access: to know what personal data is being processed.
• Rectification: to request the correction of inaccurate or incomplete data.
• Erasure: to request the deletion of their data when it is no longer necessary.
• Objection: to object to certain processing.
• Restriction: to request that processing be temporarily restricted.
• Data portability: to receive their data in a structured format and transmit it to another controller when technically possible.
• Withdrawal of consent: to withdraw previously granted consent at any time.
• Not to be subject to exclusively automated decisions: to request human intervention when decisions with legal effects are based solely on automated processing.

To exercise these rights, the user can send a request to:

Email: wajari@wajari.com
Postal address: Rúa Alejandro Sesmeros 4, 1B, 36005 Pontevedra, Spain.

The request must indicate:

• Full name.
• Right you wish to exercise.
• Sufficient information to locate your data.
• Any other data necessary to reasonably verify your identity.

When there are reasonable doubts about the applicant’s identity, additional information may be requested to confirm that the request comes from the data owner.

The exercise of these rights is free of charge, except in cases of manifestly unfounded or excessive requests contemplated by the regulations.

11. Complaint to the Supervisory Authority

If the user considers that their personal data has not been processed correctly, they can file a complaint with the Spanish Data Protection Agency.

Before filing the complaint, you can contact Wajari via wajari@wajari.com to try to resolve the situation.

The competent supervisory authority in Spain is:

Spanish Data Protection Agency —AEPD—
https://www.aepd.es

12. Minors

The services and content of these websites are not specifically directed at children under 14 years of age.

Children under 14 must not provide personal data without the authorization of their parents, guardians, or legal representatives.

When a course or activity can be purchased or used by a minor, the contract must be made or authorized by their legal representative.

Wajari may delete an account or registration when it becomes aware that data has been provided by a minor without the necessary authorization.

13. Accuracy of Data

The user guarantees that the data provided is true, accurate, complete, and up-to-date.

The user will be responsible for communicating any modification and for any damages that may arise from providing false, inaccurate data, or data belonging to third parties without authorization.

14. Data Security

Wajari adopts reasonable technical and organizational measures to protect personal data against:

• Unauthorized access.
• Loss.
• Misuse.
• Alteration.
• Disclosure.
• Destruction.

However, no system connected to the Internet can guarantee absolute security. The user must protect their passwords, use secure devices, and report any suspicious access to their account.

15. Automated Decisions and Profiling

Generally, Wajari does not make decisions with legal or significant effects for the user based solely on automated processing.

Email marketing tools can segment subscribers or activate messages based on actions such as a subscription, a purchase, or interaction with a communication. These automations are used to manage content and communications but do not, by themselves, produce significant legal effects on the user.

16. Links to Third-Party Pages

The web pages may contain links to external services or sites.

Wajari does not control the privacy policies of such pages. The user must review the third party’s terms and policies before providing personal information.

17. Changes to the Privacy Policy

Wajari may update this policy to adapt it to:

• Regulatory changes.
• New criteria from data protection authorities.
• Service modifications.
• Incorporation or replacement of providers.
• Changes in forms or data processing.

The current version will be the one published on this page and will show its last update date.

When changes are significant, the user will be informed by reasonable means.