NOT SURE KITTY

PRIVACY POLICY


Last updated: September 6, 2026


1. Who we are

This Privacy Policy explains how Pablo María Urcelay, operating under the trade name NOT SURE KITTY ("NOT SURE KITTY", "we", "us" or "our"), processes personal data in connection with https://www.notsurekitty.com/ (the "Site") and related communications, project enquiries and services.

Data Controller: Pablo María Urcelay, trading as NOT SURE KITTY 

NIF: 53732635N 

Email: info@notsurekitty.com 

Website: https://www.notsurekitty.com/


2. Scope

This Policy applies to personal data processed when you browse or interact with the Site, contact us, request information or a quotation, submit a project brief, subscribe to communications, create or use an account if that functionality is enabled, contribute material or collaborate with us, or otherwise interact with NOT SURE KITTY online.

Specific products, software, subscriptions, contests, campaigns, services or collaborations may be subject to additional privacy notices where necessary. If a specific notice conflicts with this Policy for a particular activity, the specific notice will prevail for that activity.


3. Personal data we may process

Depending on the features you use, we may process:

·  Identity and contact data, such as your name, email address, company, professional role, username, social-media handle, telephone number and other contact details you choose to provide.

·  Project and enquiry data, including briefs, requirements, budgets, schedules, references, files, links, messages, audiovisual materials, technical information and other content submitted in connection with a potential or active project.

·  Account data, where accounts are enabled, such as login identifiers, account settings, profile information and records related to account activity.

·  Newsletter and marketing data, such as subscription status, communication preferences and engagement with communications.

·  Contribution and collaboration data, including biography, credits, portfolio material, images, audiovisual works, social links and other material provided by collaborators, contributors or users where publication or participation features are enabled.

·  Technical and usage data, such as IP address, browser, operating system, device type, language, approximate location derived from IP, referring URLs, pages visited, timestamps, interaction data, logs and security events.

·  Cookie and similar technology data, as described in our Cookie Policy.

·  Transaction and billing data, if payment or paid-service functionality is introduced. Payment-card details may be processed directly by a payment provider rather than stored by us.

·  Communications, including emails, contact-form submissions, support requests and other correspondence.

We ask you not to provide special-category personal data or other highly sensitive information unless it is genuinely necessary for a specific project and we have agreed an appropriate method for handling it.


4. How we collect personal data

We may collect personal data:

·  directly from you;

·  automatically when you use the Site;

·  from service providers that support the Site and our operations;

·  from social platforms or third-party services when you interact with integrations or public NOT SURE KITTY accounts;

·  from collaborators, clients or project participants where this is necessary for a legitimate project or relationship and permitted by law; and

·  from publicly available professional sources where relevant to a genuine business or collaboration enquiry.


5. Purposes and legal bases

We process personal data only where a lawful basis applies. Depending on the context, we may process data to:

Operate, secure and improve the Site

To provide the Site, maintain functionality, diagnose errors, prevent abuse, secure infrastructure and understand performance. The legal basis is generally our legitimate interest in operating a secure and effective website, and where required, consent for non-essential cookies or similar technologies.

Respond to enquiries and develop project opportunities

To respond to messages, evaluate briefs, arrange calls, prepare quotations or proposals and take steps requested by you before entering into a contract. The legal basis is generally pre-contractual steps at your request, performance of a contract, or our legitimate interests in managing professional enquiries.

Provide professional services

To manage development, creative, technical, audiovisual production or related projects; communicate with clients and collaborators; exchange project materials; administer deliverables; and manage the professional relationship. The legal basis is generally performance of a contract, pre-contractual steps, legal obligations, and where appropriate our legitimate interests.

Manage accounts and community or collaboration features

Where enabled, to create and administer accounts, submissions, profiles, credits, collaborations, comments or other participation features. The legal basis may be performance of a contract, consent or legitimate interests, depending on the feature.

Send marketing or editorial communications

Where you subscribe or where otherwise legally permitted, to send news, product updates, magazine/editorial material, event information or promotional communications. The legal basis is consent or another lawful basis expressly permitted by applicable law. You can unsubscribe at any time.

Analytics, measurement and personalization

Where enabled, to understand use of the Site, measure content and campaigns, improve navigation and personalize non-essential experiences. Where consent is legally required, these activities will not take place until consent is obtained.

Legal, administrative and security purposes

To comply with tax, accounting, consumer, data-protection and other legal obligations; maintain records; handle claims; protect intellectual property; investigate misuse; and establish, exercise or defend legal rights. The legal basis is legal obligation and/or legitimate interests.


6. Cookies and similar technologies

We use cookies and similar technologies as described in our separate Cookie Policy. Non-essential cookies or similar technologies that require consent will be used only after valid consent has been obtained. You can change or withdraw your preferences through the cookie settings available on the Site.


7. Sharing personal data

We do not sell or rent personal data.

We may share personal data where necessary with categories of recipients such as:

·  website hosting, website-building, DNS, CDN, security and infrastructure providers;

·  cloud storage, file-transfer and collaboration providers;

·  email, communications, customer-support or newsletter providers;

·  analytics, measurement and performance providers, where enabled and lawfully configured;

·  payment, invoicing and accounting providers, if paid services are introduced;

·  professional advisers such as legal, tax or accounting advisers;

·  contractors, collaborators or production partners where required for a project and subject to appropriate obligations; and

·  public authorities, courts or regulators where disclosure is legally required.

Third-party platforms that you choose to interact with may process data under their own privacy policies.


8. International transfers

Some providers may process personal data outside the European Economic Area (EEA). Where a transfer requires safeguards under applicable law, we will use an appropriate mechanism, such as an adequacy decision, Standard Contractual Clauses approved by the European Commission, or another legally recognized safeguard, together with supplementary measures where required.


9. Retention

We keep personal data only for as long as reasonably necessary for the relevant purpose and applicable legal obligations. In particular:

·  general enquiries that do not lead to a project may normally be retained for up to 24 months after the last meaningful interaction, unless a longer period is justified;

·  project and contractual records may be retained for the duration of the relationship and thereafter for applicable legal, tax, accounting or limitation periods;

·  newsletter and marketing data is retained until you unsubscribe or the relevant purpose ends, while a minimal suppression record may be retained to respect your opt-out;

·  account data may be retained while the account remains active and for a reasonable period following closure where necessary;

·  published collaborator or contributor material may remain available for the agreed publication period or until removal is appropriate under the applicable agreement or legal basis; and

·  cookie and analytics data is retained according to the durations stated in the Cookie Policy or relevant consent-management interface.


10. Your rights

Subject to the conditions and limitations of applicable law, you may have the right to:

·  access your personal data;

·  correct inaccurate or incomplete data;

·  request erasure;

·  request restriction of processing;

·  object to processing based on legitimate interests;

·  receive certain data in a portable format;

·  withdraw consent at any time where processing relies on consent; and

·  lodge a complaint with a competent supervisory authority.

To exercise your rights, contact info@notsurekitty.com. We may request information reasonably necessary to verify your identity.

If you are in Spain, you may also lodge a complaint with the Spanish Data Protection Agency (AEPD).


11. Automated decision-making

We do not currently use solely automated decision-making that produces legal effects concerning you or similarly significantly affects you. If this changes, we will provide the information and safeguards required by law.


12. Security

We use reasonable technical and organizational measures intended to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. No internet or storage system can be guaranteed to be completely secure.


13. Minors

The Site is intended for a general audience and does not contain adult-only content, but it is not specifically directed at children. We do not knowingly seek to collect personal data from children who cannot lawfully provide their own consent. Where parental or guardian authorization is legally required, the relevant feature should not be used without that authorization.

If you believe that a child has provided personal data inappropriately, contact us at info@notsurekitty.com.


14. Third-party links and embedded content

The Site may contain links to or embeds from third-party websites, social networks, video platforms or other services. Those third parties may process information under their own policies. Where an embedded service requires non-essential cookies or tracking, it should be activated only in accordance with the consent choices available on the Site.


15. User and collaborator material

Where users, artists, collaborators, clients or other contributors provide material for publication, promotion, editorial use or project work, the associated personal data will be processed for the agreed purpose. Intellectual-property ownership and publication rights are governed by the relevant permission, licence, collaboration terms or project agreement.


16. Changes to this Policy

We may update this Privacy Policy to reflect changes to the Site, our services, technology, providers or applicable law. The current version will be published on this page with an updated date. Where required, we will provide additional notice or seek renewed consent.


17. Contact

For privacy questions or requests:

NOT SURE KITTY  

Controller: Pablo María Urcelay 

NIF: 53732635N 

Email: info@notsurekitty.com