Regulatory Compliance

Data Controller Identification

The data controller responsible for the processing of personal data collected through this website is GlacierRelayForge, registered at 45001, Calle Comercio 3, Toledo, Spain. For any data-related inquiries, you may contact our designated Data Protection Officer at [email protected].

Categories of Personal Data Processed

We collect and process the following categories of personal data: (a) identification data including name and email address submitted through our contact forms; (b) technical data including IP address, browser type and version, operating system, referral source, and page interaction metrics collected automatically through standard server logging; (c) cookie-based data as described in our Cookies Policy below.

Legal Basis for Processing (Article 6, GDPR)

Personal data is processed on the following legal bases: (a) Consent (Article 6(1)(a)) — where you have explicitly provided data through contact forms or cookie acceptance; (b) Contractual Necessity (Article 6(1)(b)) — where data processing is necessary for the performance of a service agreement or pre-contractual measures at your request; (c) Legitimate Interest (Article 6(1)(f)) — for server security, fraud prevention, and website performance optimization, subject to a documented balancing test.

Purpose of Data Processing

Personal data is processed exclusively for the following purposes: responding to service inquiries and project scoping communications; delivering contracted digital services and managing ongoing client relationships; maintaining website security, integrity, and performance; complying with legal and regulatory obligations applicable to digital service providers operating within the European Union.

Data Retention Periods

Contact form submissions are retained for a maximum of 24 months from the date of submission unless an active service relationship exists. Service-related client data is retained for the duration of the contractual relationship plus 6 years in compliance with Spanish commercial record-keeping obligations (Código de Comercio, Art. 30). Server logs are automatically purged after 90 days. Cookie data retention is governed by the specific durations outlined in our Cookies Policy.

Data Recipients and International Transfers

Your personal data may be shared with the following categories of recipients: (a) technology infrastructure providers (hosting, CDN, email delivery) acting as data processors under written agreements compliant with Article 28 GDPR; (b) professional advisors including legal counsel and auditors bound by professional confidentiality obligations. All data processing occurs within the European Economic Area (EEA). In the event that any data transfer outside the EEA becomes necessary, we will ensure appropriate safeguards are in place pursuant to Chapter V of the GDPR, including Standard Contractual Clauses (SCCs) approved by the European Commission.

Data Subject Rights

Under the General Data Protection Regulation (EU 2016/679), you possess the following rights: Right of Access (Article 15) — to obtain confirmation of whether your personal data is being processed and to receive a copy of that data; Right to Rectification (Article 16) — to request correction of inaccurate personal data; Right to Erasure (Article 17) — to request deletion of your personal data where no overriding legal obligation requires its retention; Right to Restriction (Article 18) — to request limitation of processing in specific circumstances; Right to Data Portability (Article 20) — to receive your data in a structured, commonly used, machine-readable format; Right to Object (Article 21) — to object to processing based on legitimate interests. To exercise any of these rights, submit a request to [email protected]. We will respond within 30 days of receipt.

Right to Lodge a Complaint

If you believe your data protection rights have been infringed, you have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos — AEPD) at www.aepd.es.

Automated Decision-Making

GlacierRelayForge does not engage in automated decision-making, including profiling, that produces legal effects or similarly significantly affects data subjects.

What Are Cookies

Cookies are small text files placed on your device when you visit a website. They serve to store preferences, maintain session state, and collect analytical data to improve website performance and user experience.

Cookies We Deploy

Essential Cookies — These are strictly necessary for the website to function and cannot be disabled. They include session management cookies that maintain your browsing state and security tokens that protect against cross-site request forgery. These cookies do not collect personally identifiable information and are set only in response to actions you take, such as setting your privacy preferences or filling in forms.

Functional Cookies — These cookies enable enhanced functionality and personalization, such as remembering your cookie consent choices. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, some or all of these services may not function properly.

Analytics Cookies — These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us understand which pages are most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our site.

Managing Cookie Preferences

When you first visit our website, you are presented with a cookie consent banner allowing you to accept or decline non-essential cookies. You may change your preferences at any time by clearing your browser cookies and revisiting the site, which will re-trigger the consent banner. You can also configure your browser to block or alert you about cookies. Please note that blocking essential cookies may impair website functionality.

Cookie Duration

Session cookies are automatically deleted when you close your browser. Persistent cookies remain on your device for the period specified in the table below or until you delete them manually. Consent cookies are retained for 12 months to avoid repeated consent requests in compliance with Article 7 of the ePrivacy Directive.

Third-Party Cookies

We may utilize third-party services that set their own cookies, including analytics providers. These third parties act as independent data controllers for their own cookie processing activities. We encourage you to review their respective privacy policies for detailed information about their data practices.

Scope and Application

This Refund Policy governs all services provided by GlacierRelayForge, registered at 45001, Calle Comercio 3, Toledo, Spain. It applies to all service engagements, retainers, and project-based contracts entered into between GlacierRelayForge and its clients. This policy is designed to comply with EU consumer protection directives and Spanish commercial regulations.

Project Milestone-Based Refunds

All project engagements are structured around clearly defined milestones documented in the service agreement. Refund eligibility is assessed on a per-milestone basis. Upon completion and client sign-off of a milestone, the corresponding payment becomes non-refundable as the deliverable has been produced and delivered. For milestones in progress at the time of cancellation, a proportional refund is calculated based on the percentage of work completed relative to the milestone scope, minus any third-party costs already incurred.

Cancellation Before Work Commencement

If a client cancels a project before any work has commenced (defined as within 5 business days of contract signing and before any resources have been allocated), a full refund of all payments made will be issued within 14 business days. Cancellations received after resource allocation but before the first milestone delivery are subject to a deduction of 20% of the total project value to cover initialization costs, scoping labor, and reserved capacity.

Service Dissatisfaction

If a delivered milestone does not materially conform to the specifications documented in the service agreement, the client must submit a written dispute within 10 business days of delivery. GlacierRelayForge will review the dispute and, if the non-conformity is validated, will either (a) remediate the deliverable at no additional cost within 15 business days, or (b) issue a partial refund proportional to the scope of non-conformity. Disputes submitted after the 10-business-day window will be assessed on a case-by-case basis at the sole discretion of GlacierRelayForge.

Refund Processing

All approved refunds are processed within 14 business days of approval and are issued via the original payment method. Processing fees charged by payment providers are non-refundable and will be deducted from the refund amount. Clients will receive email confirmation when a refund has been initiated.

Exclusions

The following are excluded from refund eligibility: (a) third-party software licenses, API access fees, or infrastructure costs already procured on behalf of the client; (b) domain name registrations and SSL certificate purchases; (c) consulting hours and strategy sessions that have been delivered; (d) work completed under change orders approved and signed by the client.

Dispute Resolution

In the event of a refund dispute that cannot be resolved through direct negotiation, the parties agree to submit to mediation administered by the Spanish Mediation Center (Centro de Mediación de España) before initiating any formal legal proceedings. This Refund Policy is governed by the laws of the Kingdom of Spain.

Acceptance of Terms

By accessing or utilizing any services provided by GlacierRelayForge, registered at 45001, Calle Comercio 3, Toledo, Spain, you agree to be bound by these Terms of Service. If you do not agree to these terms, you must not use our services. These terms constitute a legally binding agreement between you (or the entity you represent) and GlacierRelayForge.

Service Scope and Engagement

All services are provided on the basis of the specific scope, timeline, and deliverables documented in the individual service agreement or statement of work (SOW) executed between the parties. GlacierRelayForge reserves the right to refuse service at its sole discretion. Any modifications to the agreed scope must be documented through a formal change order signed by both parties, which may affect pricing and timelines.

Intellectual Property and Ownership

Upon full payment of all applicable fees, the client receives full ownership of all custom deliverables produced specifically under the service agreement, including but not limited to custom code, design assets, content, and documentation. GlacierRelayForge retains ownership of all pre-existing tools, frameworks, methodologies, and reusable components utilized in the delivery of services. GlacierRelayForge grants the client a perpetual, non-exclusive license to use any such pre-existing components incorporated into the deliverables.

Confidentiality

Both parties agree to maintain the confidentiality of all proprietary information disclosed during the course of the engagement. This obligation survives the termination of the service agreement for a period of 3 years. Confidential information includes, but is not limited to, business strategies, technical architectures, source code, user data, and financial information.

Payment Terms

Unless otherwise specified in the service agreement, invoices are payable within 14 days of issuance. Late payments accrue interest at a rate of the European Central Bank base rate plus 8 percentage points per annum, in accordance with EU Directive 2011/7/EU on late payment in commercial transactions. GlacierRelayForge reserves the right to suspend work on any project where payment is overdue by more than 14 days.

Limitation of Liability

To the maximum extent permitted by applicable law, GlacierRelayForge's total aggregate liability arising out of or in connection with any service engagement shall not exceed the total fees paid by the client under the applicable service agreement during the 12-month period preceding the event giving rise to the liability. GlacierRelayForge shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of profits, data, or business opportunities.

Force Majeure

Neither party shall be liable for any failure or delay in performing its obligations under these terms where such failure or delay results from circumstances beyond the reasonable control of the affected party, including but not limited to acts of God, natural disasters, pandemics, government actions, internet infrastructure failures, or cyber attacks. The affected party must notify the other party within 48 hours of the force majeure event and use reasonable efforts to mitigate its impact.

Termination

Either party may terminate a service agreement with 30 days' written notice. GlacierRelayForge may terminate immediately if the client breaches a material term of the agreement and fails to cure such breach within 14 days of receiving written notice. Upon termination, the client is obligated to pay for all work completed up to the date of termination, including any non-cancellable third-party costs incurred by GlacierRelayForge on the client's behalf.

Governing Law and Jurisdiction

These Terms of Service are governed by and construed in accordance with the laws of the Kingdom of Spain. Any disputes arising out of or in connection with these terms shall be subject to the exclusive jurisdiction of the courts of Toledo, Spain, unless the parties agree to submit to arbitration under the rules of the Madrid Court of Arbitration (Tribunal Arbitral de Madrid).

Severability

If any provision of these terms is found to be invalid or unenforceable by a court of competent jurisdiction, the remaining provisions shall continue in full force and effect. The invalid provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving the original intent of the parties.

Entire Agreement

These Terms of Service, together with the applicable service agreement(s) and any executed change orders, constitute the entire agreement between the parties and supersede all prior and contemporaneous agreements, representations, and understandings, whether written or oral.