Regulatory Alignment
& Protocol Compliance

Effective Date: 1 January 2026 — Last Updated: 1 January 2026

1. Data Controller Identification

The data controller responsible for the processing of personal data collected through this platform is IronAnchorWorks, registered at 07014, Passatge Particular de Joan XXIII 4, Palma, Spain. For all data protection inquiries, you may contact our designated data protection officer at [email protected].

2. Categories of Personal Data Collected

We collect and process the following categories of personal data through our platform operations:

• —Identity Data: Full name, professional designation, and organizational affiliation submitted through inquiry forms.
• —Contact Data: Email address, telephone number, and physical address provided during engagement initiation.
• —Technical Data: IP address, browser type and version, operating system, device identifiers, and access timestamps automatically collected during platform interaction.
• —Usage Data: Page navigation patterns, interaction timestamps, referral sources, and session duration metrics collected through analytics instrumentation.
• —Project Data: Technical specifications, business requirements, and strategic documentation submitted during active engagement periods.

3. Legal Basis for Processing

All personal data processing activities conducted by IronAnchorWorks are grounded in the following legal bases as defined under Article 6 of the EU General Data Protection Regulation (GDPR):

• —Consent (Art. 6(1)(a)): Where you have provided explicit, informed, and freely given consent for specific processing purposes, including marketing communications and analytics tracking.
• —Contractual Necessity (Art. 6(1)(b)): Where processing is necessary for the performance of a contract to which you are a party, or for taking pre-contractual steps at your request.
• —Legitimate Interest (Art. 6(1)(f)): Where processing is necessary for the purposes of our legitimate interests, including platform security, service improvement, and fraud prevention, provided such interests are not overridden by your fundamental rights.

4. Data Retention Periods

Personal data is retained only for the duration necessary to fulfill the purposes for which it was collected:

• —Inquiry Data: Retained for 24 months from the date of last communication, after which it is permanently deleted from all active and backup systems.
• —Contract Data: Retained for the duration of the contractual relationship plus 6 years in compliance with Spanish commercial record-keeping obligations.
• —Technical Data: Aggregated analytics data is retained for 38 months. Identifiable technical logs are purged after 90 days.
• —Consent Records: Proof of consent is retained for the duration of the consent plus 3 years for compliance verification purposes.

5. International Data Transfers

As a Spain-based entity operating within the European Economic Area, IronAnchorWorks primarily processes data within the EEU. Where data transfer to third countries is necessary for service delivery (e.g., cloud infrastructure providers), we ensure adequate protection through Standard Contractual Clauses (SCCs) approved by the European Commission, adequacy decisions, or other legally recognized transfer mechanisms under Chapter V of the GDPR.

6. Data Subject Rights

Under the GDPR, you maintain the following rights regarding your personal data:

• —Right of Access (Art. 15): Request a copy of all personal data we hold about you.
• —Right to Rectification (Art. 16): Request correction of inaccurate or incomplete personal data.
• —Right to Erasure (Art. 17): Request deletion of your personal data where there is no compelling reason for continued processing.
• —Right to Restrict Processing (Art. 18): Request limitation of processing activities under specific circumstances.
• —Right to Data Portability (Art. 20): Receive your personal data in a structured, commonly used, machine-readable format.
• —Right to Object (Art. 21): Object to processing based on legitimate interests, including direct marketing.

To exercise any of these rights, submit a written request to [email protected]. We will respond within 30 days in accordance with Article 12 of the GDPR.

7. Data Security Measures

IronAnchorWorks implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including encryption of data in transit (TLS 1.3) and at rest, access controls with multi-factor authentication, regular security audits, and incident response procedures aligned with ENISA guidelines. In the event of a personal data breach that poses a high risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and communicate the breach to affected data subjects without undue delay.

8. Supervisory Authority

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

Effective Date: 1 January 2026 — Last Updated: 1 January 2026

1. Cookie Technology Overview

Cookies are small text files placed on your device when you access our platform. They serve essential functions including session management, security authentication, preference storage, and analytical measurement. This directive explains how IronAnchorWorks deploys cookies and provides mechanisms for managing your cookie preferences.

2. Strictly Necessary Cookies

These cookies are essential for the operation of our platform and cannot be disabled. They enable core functionality including session persistence, security token management, and load balancing:

• —session_id: Maintains your authenticated session state across page navigations. Duration: Session. Provider: IronAnchorWorks.
• —csrf_token: Prevents cross-site request forgery attacks on form submissions. Duration: Session. Provider: IronAnchorWorks.
• —cookie_consent: Records your cookie preference selections to avoid repeated consent requests. Duration: 12 months. Provider: IronAnchorWorks.

3. Analytics & Performance Cookies

These cookies collect aggregated, anonymized data about how visitors interact with our platform. They enable us to measure and improve performance:

• —_analytics_session: Tracks anonymized page view sequences and interaction patterns. Duration: 30 minutes. Provider: IronAnchorWorks. Data is aggregated and cannot be used to identify individual users.
• —_performance_metric: Captures page load timing and rendering performance data. Duration: 24 hours. Provider: IronAnchorWorks.

4. Cookie Management

You may manage your cookie preferences at any time through the cookie consent banner displayed upon your initial visit. You may also modify your browser settings to block or delete cookies. Note that disabling strictly necessary cookies may impair platform functionality. Most browsers provide cookie management through their privacy or settings menus. For specific instructions, consult your browser's documentation.

5. Third-Party Cookies

IronAnchorWorks does not deploy third-party tracking cookies or advertising cookies. Embedded content from external services (e.g., Google Maps) may set their own cookies according to their respective privacy policies. We recommend reviewing Google's Privacy Policy for details on cookies set by the Maps embedding service.

6. Updates to This Directive

This Cookie Directive may be updated to reflect changes in our cookie practices or regulatory requirements. Material changes will be communicated through the cookie consent banner on your next platform visit.

Effective Date: 1 January 2026 — Last Updated: 1 January 2026

1. General Reimbursement Framework

IronAnchorWorks is committed to delivering services that meet or exceed the specifications defined in each engagement agreement. Reimbursement eligibility is evaluated against project milestone completion, deliverable quality standards, and the terms established in the individual service agreement between IronAnchorWorks and the client.

2. Pre-Engagement Reimbursement

If a project is cancelled before any engineering work has commenced, a full reimbursement of any advance payments will be issued within 14 business days. Cancellation requests must be submitted in writing to [email protected]. Once the discovery phase (Phase 1) has been initiated, reimbursement will be calculated proportionally based on the percentage of Phase 1 completion.

3. Milestone-Based Reimbursement

For engagements structured across multiple phases, reimbursement eligibility is assessed at each milestone boundary:

• —Phase 1 (Discovery & Mapping): If the client determines that the discovery deliverables do not meet the agreed scope, a reimbursement of 70% of Phase 1 fees will be issued within 21 business days.
• —Phase 2 (Engineering & Integration): Reimbursement for Phase 2 is evaluated against the technical specifications documented in the Phase 1 deliverable. If deliverables deviate materially from agreed specifications, a proportional reimbursement will be calculated based on non-conforming deliverable scope.
• —Phase 3 (Deployment & Delivery): Upon final delivery, a 14-day acceptance period is provided. If the client identifies material defects or non-conformities within this period, IronAnchorWorks will remediate at no additional cost. If remediation is not feasible, a proportional reimbursement will be issued.

4. Non-Reimbursable Items

• —Third-party service fees, licensing costs, and infrastructure expenses incurred on behalf of the client.
• —Engineering hours spent on client-requested scope changes outside the original engagement agreement.
• —Deliverables that have been accepted in writing by the client during the acceptance period.
• —Projects delayed or disrupted due to client non-responsiveness exceeding 30 consecutive calendar days.

5. Reimbursement Process

All reimbursement requests must be submitted in writing to [email protected] with the subject line "Reimbursement Request — [Project Identifier]." Requests will be acknowledged within 3 business days and evaluated within 14 business days. Approved reimbursements will be processed via the original payment method within 21 business days of approval.

6. Dispute Resolution

In the event of a reimbursement dispute, IronAnchorWorks proposes an initial mediation phase conducted by an independent mediator agreed upon by both parties. If mediation does not resolve the dispute within 30 days, either party may initiate formal proceedings in accordance with the jurisdiction defined in the Operating Agreement.

Effective Date: 1 January 2026 — Last Updated: 1 January 2026

1. Acceptance of Terms

By accessing, browsing, or using this platform and engaging the services of IronAnchorWorks, you acknowledge that you have read, understood, and agree to be bound by these Operating Agreement terms. If you do not agree to these terms, you must immediately cease all use of this platform and refrain from engaging our services. These terms constitute a legally binding agreement between you (or the entity you represent) and IronAnchorWorks, registered at 07014, Passatge Particular de Joan XXIII 4, Palma, Spain.

2. Service Description

IronAnchorWorks provides bespoke digital engineering services including but not limited to platform architecture, full-stack development, API integration, AI infrastructure deployment, systems auditing, and technical consulting. Each engagement is governed by an individual service agreement that defines the specific scope, deliverables, timelines, and compensation terms. These Operating Agreement terms supplement the individual service agreement and apply to all interactions with IronAnchorWorks.

3. Intellectual Property

Upon full payment of all applicable fees, the client receives ownership of all custom-developed deliverables specified in the individual service agreement, including source code, design assets, and documentation. IronAnchorWorks retains ownership of all pre-existing intellectual property, proprietary frameworks, development tools, methodologies, and know-how used in the delivery of services. IronAnchorWorks grants the client a perpetual, non-exclusive license to use any proprietary components integral to the delivered system. Neither party shall use the other party's confidential information or intellectual property for any purpose beyond the scope of the engagement without prior written consent.

4. Limitation of Liability

To the maximum extent permitted by applicable law, IronAnchorWorks shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising from or related to the use of our services, including but not limited to loss of profits, data, business opportunities, or goodwill. The total aggregate liability of IronAnchorWorks under any individual service agreement shall not exceed the total fees paid by the client under that agreement during the twelve (12) months preceding the claim. This limitation does not apply to liabilities that cannot be excluded or limited under Spanish law.

5. Confidentiality

Both parties agree to maintain the confidentiality of all proprietary information disclosed during the engagement period. Confidential information includes but is not limited to business strategies, technical specifications, source code, financial data, client lists, and trade secrets. This obligation survives the termination of the engagement for a period of three (3) years. Neither party shall disclose confidential information to third parties without prior written consent, except as required by law or to professional advisors bound by equivalent confidentiality obligations.

6. Force Majeure

IronAnchorWorks shall not be liable for delays or failures in performance resulting from causes beyond our reasonable control, including but not limited to natural disasters, pandemics, war, terrorism, government actions, power failures, internet disruptions, or third-party service failures. In such events, IronAnchorWorks will use commercially reasonable efforts to mitigate the impact and resume performance as promptly as practicable.

7. Termination

Either party may terminate an engagement with thirty (30) days written notice. IronAnchorWorks may terminate immediately if the client breaches material terms of the agreement and fails to cure such breach within fourteen (14) days of written notice. Upon termination, the client shall pay for all services rendered up to the termination date, and IronAnchorWorks shall deliver all completed work product in its possession.

8. Governing Law & Jurisdiction

These Operating Agreement terms and any individual service agreements shall be governed by and construed in accordance with the laws of the Kingdom of Spain and, where applicable, the regulations of the European Union. Any disputes arising from or related to these terms shall first be submitted to mediation. If mediation fails within thirty (30) days, disputes shall be submitted to the exclusive jurisdiction of the courts of Palma de Mallorca, Balearic Islands, Spain.

9. Amendments

IronAnchorWorks reserves the right to amend these Operating Agreement terms at any time. Material changes will be communicated via email to active clients at least thirty (30) days before taking effect. Continued use of the platform or services following the effective date of any amendments constitutes acceptance of the modified terms.

10. Contact

For all inquiries related to these Operating Agreement terms, please contact:

IronAnchorWorks
07014, Passatge Particular de Joan XXIII 4, Palma, Spain
[email protected]
+34 609 72 81 33