Privacy Policy

Last updated: April 5, 2026

Who we are

Jose Custom AI is operated by Jose Alberto Lugo Velazquez, trading as Jose Lugo GDPR AI Consulting, Lanzlbogen 1, 93155 Hemau, Germany. Contact: info@joselugo.de.

What data we collect

Website visits: This site is hosted on Cloudflare Pages. Cloudflare may collect basic connection data (IP address, browser type, referring page) for security and performance purposes. We do not run Google Analytics, Facebook Pixel, or any third-party tracking scripts.

Contact forms and emails: If you reach out via email or a contact form, we store your name, email address, and message content to respond to your inquiry.

Booking and scheduling: If you book a call through our scheduling tool (Cal.com), your name and email are processed by Cal.com under their privacy policy. We receive only the information needed to schedule the meeting.

Client engagements: For active clients, we process business contact data, project details, and system configuration information as needed to deliver our services. This is governed by a separate data processing agreement (DPA) signed before work begins.

What we do not do

We do not sell your data to anyone.
We do not serve ads or use ad-tracking pixels.
We do not use your data to train AI models.
We do not share your information with third parties for marketing purposes.

Legal basis (GDPR Art. 6)

We process personal data based on:

Legitimate interest (Art. 6(1)(f)): Website security, fraud prevention, and basic analytics.
Contract performance (Art. 6(1)(b)): Processing data necessary to deliver consulting services you have requested.
Consent (Art. 6(1)(a)): Where you voluntarily provide data via email or contact forms.

Data transfers

This site is served via Cloudflare, which operates a global CDN. Some data may be processed on servers outside the EU/EEA. Cloudflare participates in the EU-U.S. Data Privacy Framework and maintains Standard Contractual Clauses (SCCs) for international transfers.

Data retention

Contact inquiries are retained for up to 12 months after our last communication unless a business relationship is established. Client data is retained for the duration of the engagement plus any legally required retention period (typically 10 years for tax-relevant records under German law).

Your rights

Under the GDPR, you have the right to:

Access your personal data (Art. 15)
Rectify inaccurate data (Art. 16)
Request deletion of your data (Art. 17)
Restrict processing (Art. 18)
Data portability (Art. 20)
Object to processing (Art. 21)

To exercise any of these rights, email info@joselugo.de. We respond within 30 days.

Supervisory authority

You have the right to lodge a complaint with a data protection authority. The competent authority for our business is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach, Germany.

Cookies

This site does not set any first-party cookies. Cloudflare may set strictly necessary cookies for security purposes (e.g., bot protection). These do not require consent under ePrivacy rules.

Changes to this policy

We may update this policy from time to time. The date at the top of this page reflects the latest revision. Material changes will be noted here.