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Chronological Compliance Schedule

Legal & Governance

Last Revised: September 2026 — SmartDevelopmentWorks, Madrid, Spain

01

Data Collection & Retention Policy

Effective Date: September 2026

SmartDevelopmentWorks collects only the personal data strictly necessary to fulfill contractual obligations and deliver engineering services. Collected data categories include: full name, email address, phone number, company name, and project specifications submitted via our consultation forms.

Retention Period: Client contact data is retained for the duration of the active business relationship plus 24 months following the last completed engagement. Project deliverables and associated technical documentation are retained for 36 months post-delivery for warranty and support purposes. All data is permanently deleted within 30 days of a verified erasure request.

Legal Basis: Data processing is conducted under Article 6(1)(b) of the EU GDPR (performance of a contract) and Article 6(1)(f) (legitimate interest in service quality and security auditing).

02

Data Handling Lifecycle

Effective Date: September 2026

All personal data is processed within encrypted EU-hosted cloud infrastructure compliant with ISO/IEC 27001 standards. Data in transit is protected via TLS 1.3 encryption; data at rest is encrypted using AES-256.

Processing Activities: Client data is used exclusively for: (a) project communication and delivery coordination, (b) technical support and SLA fulfillment, (c) invoicing and statutory financial record-keeping, and (d) internal security auditing and quality assurance.

Third-Party Sharing: SmartDevelopmentWorks does not sell, rent, or distribute personal information to unauthorized third parties. Data may be shared only with essential service providers (cloud hosting, payment processing) under strict data processing agreements (DPAs) compliant with Article 28 of the GDPR.

Automated Processing: We do not engage in automated decision-making or profiling that produces legal effects concerning data subjects. All project assessments are conducted by qualified human engineers.

03

Client Rights Under GDPR

Effective Date: September 2026

In accordance with Regulation (EU) 2016/679, all data subjects whose personal data is processed by SmartDevelopmentWorks are entitled to exercise the following rights:

  • ✓ Right of Access (Art. 15): Request a complete copy of all personal data we hold.
  • ✓ Right to Rectification (Art. 16): Request correction of inaccurate or incomplete data.
  • ✓ Right to Erasure (Art. 17): Request permanent deletion of your personal data.
  • ✓ Right to Restriction (Art. 18): Request limitation of processing activities.
  • ✓ Right to Portability (Art. 20): Receive your data in a structured, machine-readable format.
  • ✓ Right to Object (Art. 21): Object to processing based on legitimate interests.

To exercise any of these rights, contact our Data Protection desk at [email protected]. All requests are processed within 30 calendar days in accordance with regulatory requirements.

04

Terms of Service

Effective Date: September 2026

All services provided by SmartDevelopmentWorks are governed by explicitly contracted Statements of Work (SOW) executed between the client and SmartDevelopmentWorks, registered at Gran Vía, 32, 28013 Madrid, Comunidad de Madrid, Spain.

Intellectual Property: Upon complete settlement of all agreed invoices, SmartDevelopmentWorks assigns 100% of worldwide intellectual property rights in client-specific software deliverables, source code, design assets, and documentation directly to the client. No recurring license fees or royalties apply.

Liability: SmartDevelopmentWorks' total aggregate liability under any engagement shall not exceed the total fees paid by the client for the specific service giving rise to the claim. We are not liable for indirect, incidental, or consequential damages.

Governing Law: These terms are governed by the laws of the Kingdom of Spain. Any disputes shall be submitted to the competent courts of Madrid, Spain.

05

Cookie Policy

Effective Date: September 2026

SmartDevelopmentWorks uses only strictly necessary functional cookies to ensure secure platform operation and to remember your cookie consent preference. These cookies do not track browsing behavior across third-party websites.

Cookies We Use: (a) cookie_accepted — localStorage flag to remember your consent and suppress the banner on return visits. (b) Session cookies essential for maintaining secure form states during your visit.

No Tracking: We do not use Google Analytics, Facebook Pixel, or any third-party advertising or behavioral tracking cookies. No cross-site tracking occurs.

Your Choice: You may clear cookies at any time through your browser settings. Declining functional cookies may impair certain form functionalities but will not affect your ability to browse the site.

06

Security Audit & Infrastructure

Effective Date: September 2026

SmartDevelopmentWorks maintains a rigorous security posture aligned with industry best practices. Our infrastructure undergoes quarterly vulnerability assessments and annual penetration testing conducted by independent security auditors.

Measures: (a) All production systems are deployed behind Web Application Firewalls (WAF) with DDoS mitigation. (b) Access to client data is restricted on a need-to-know basis with multi-factor authentication enforced. (c) Automated dependency scanning runs on every code deployment. (d) Incident response procedures are documented and tested bi-annually.

Breach Notification: In the unlikely event of a data breach affecting personal data, SmartDevelopmentWorks will notify the relevant supervisory authority within 72 hours and affected data subjects without undue delay, in compliance with Article 33 and 34 of the GDPR.

07

Refund & Reimbursement Policy

Effective Date: September 2026

SmartDevelopmentWorks operates on a milestone-based payment model. Each project SOW defines specific delivery milestones with corresponding payment installments.

Pre-Development Refund: If a client cancels before development work has commenced on a given milestone, 100% of the milestone payment is refunded within 14 business days.

Partial Refund: If cancellation occurs during active development, a prorated refund is calculated based on the percentage of completed deliverables relative to the milestone scope. Work already delivered and accepted by the client is non-refundable.

Post-Delivery: Once a milestone deliverable has been formally accepted by the client (via written confirmation or 14-day review period without rejection), the corresponding payment is non-refundable. Refund requests should be directed to [email protected].

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Company Registry

Entity: SmartDevelopmentWorks

Activity: Full-Stack Web Engineering, API Gateway Development & Platform Infrastructure

Address: Gran Vía, 32, 28013 Madrid, Comunidad de Madrid, Spain

Email: [email protected]

Phone: +34 650 94 18 67

Jurisdiction: Kingdom of Spain / European Union