Data Controller
Full name: Daniel Ciommiento
NIF/NIE: Y3448899V
Address: Calle Fassina 14, Altafulla, Tarragona, Spain
Email: info@danielciommiento.com
Website: danielciommiento.com
Hosting & Domain: Raiola Network S.L. — raiolanetworks.es
Daniel Ciommiento is the Data Controller responsible for the personal data collected through this website, in accordance with Regulation (EU) 2016/679 (GDPR), the Spanish Organic Law 3/2018 (LOPDGDD), and all applicable international data protection legislation.
Privacy Policy
Updated March 2026What data we collect
When you interact with this website, we may collect the following personal data:
- Name and email address (when you submit a contact or booking form)
- IP address and approximate geolocation
- Browser type, device, and operating system
- Pages visited, time spent, and navigation behaviour
- Calendly booking data (name, email, responses to pre-call questions)
- Data provided voluntarily via email or social media direct messages
Legal basis for processing (GDPR Art. 6)
| Processing activity | Legal basis |
|---|---|
| Responding to enquiries | Legitimate interest / Pre-contractual measures (Art. 6.1.b) |
| Analytics & performance tracking | Consent (Art. 6.1.a) |
| Marketing & advertising pixels | Consent (Art. 6.1.a) |
| Booking via Calendly | Pre-contractual measures (Art. 6.1.b) |
| Legal compliance | Legal obligation (Art. 6.1.c) |
How we use your data
- To respond to consultation and booking requests
- To improve website performance and user experience
- To run targeted advertising campaigns via Meta and Google
- To comply with legal obligations
- To communicate service updates if you have given consent
Data retention
Personal data is retained only for as long as necessary for the purpose it was collected:
- Contact form data: up to 2 years from last interaction
- Booking data (Calendly): governed by Calendly's own retention policy
- Analytics data: up to 26 months (Google Analytics default)
- Advertising data: up to 180 days (Meta Pixel default)
International transfers
Some data processors (Google, Meta, Calendly, YouTube) are located outside the European Economic Area (EEA). All transfers are covered by Standard Contractual Clauses (SCCs) approved by the European Commission, or equivalent adequacy decisions, in accordance with GDPR Chapter V.
Data processors (third parties)
| Service | Purpose | Location |
|---|---|---|
| Google Analytics | Website analytics | USA (SCC) |
| Google Ads | Advertising | USA (SCC) |
| Meta (Facebook/Instagram) | Advertising pixel & remarketing | USA (SCC) |
| YouTube (Google LLC) | Embedded video content | USA (SCC) |
| Calendly | Appointment scheduling | USA (SCC) |
| Raiola Network S.L. | Hosting & domain | Spain (EU) |
| WordPress.org | CMS platform | USA (SCC) |
Cookie Policy
Updated March 2026This website uses cookies and similar tracking technologies. In accordance with EU Directive 2002/58/EC (ePrivacy) and GDPR, non-essential cookies are only activated after obtaining your explicit consent.
What are cookies?
Cookies are small text files stored on your device when you visit a website. They allow the site to remember your preferences and analyse how visitors interact with the content.
Types of cookies used
| Category | Cookie / Service | Purpose | Duration |
|---|---|---|---|
| Essential | WordPress session, security | Site functionality, login security | Session |
| Analytics | Google Analytics (_ga, _gid) | Traffic & behaviour analysis | Up to 2 years |
| Marketing | Meta Pixel (_fbp, _fbc) | Ad targeting & remarketing | Up to 90 days |
| Marketing | Google Ads (IDE, _gcl_au) | Conversion tracking | Up to 13 months |
| Functional | Calendly | Booking widget functionality | Session / persistent |
| Functional | YouTube (VISITOR_INFO1_LIVE) | Embedded video preferences | Up to 6 months |
Managing your cookie preferences
You can manage or withdraw your consent at any time by:
- Clicking the cookie settings banner when visiting the site
- Configuring your browser settings to block or delete cookies
- Using opt-out tools: Google Analytics Opt-out, Meta Ad Preferences
- Sending a request to info@danielciommiento.com
Please note that disabling certain cookies may affect the functionality of this website.
Tracking & Advertising Pixels
Meta Pixel (Facebook & Instagram)
This website uses the Meta Pixel provided by Meta Platforms Ireland Ltd. (4 Grand Canal Square, Dublin 2, Ireland). The pixel allows us to measure the effectiveness of advertising campaigns and show relevant ads to people who have visited this site. Meta may combine this data with information from your Meta account. For more information, see Meta's Privacy Policy.
Google Analytics & Google Ads
We use Google Analytics (provided by Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland) to understand how visitors interact with the site. IP anonymisation is enabled. We also use Google Ads conversion tracking. See Google's Privacy Policy.
YouTube Embedded Videos
This website embeds videos from YouTube (Google LLC). When you play a video, YouTube may set cookies on your device and collect data about your viewing behaviour. We use YouTube's privacy-enhanced mode where possible. See Google's Privacy Policy.
Calendly
The booking widget is provided by Calendly LLC (271 17th St NW, Atlanta, GA 30363, USA). When you schedule a call, your name, email, and responses are processed by Calendly. See Calendly's Privacy Policy.
Your Rights
Depending on your location, you have the following rights regarding your personal data:
| Right | What it means | Applicable law |
|---|---|---|
| Access | Request a copy of the data we hold about you | GDPR Art. 15 · CCPA · LGPD |
| Rectification | Correct inaccurate or incomplete data | GDPR Art. 16 · LGPD |
| Erasure | Request deletion of your personal data ("right to be forgotten") | GDPR Art. 17 · CCPA · LGPD |
| Restriction | Limit how we process your data | GDPR Art. 18 |
| Portability | Receive your data in a structured, machine-readable format | GDPR Art. 20 |
| Objection | Object to processing based on legitimate interest or direct marketing | GDPR Art. 21 |
| Withdraw consent | Withdraw consent at any time without affecting prior processing | GDPR Art. 7 |
| Do Not Sell | California residents may opt out of the sale of personal information | CCPA (California) |
To exercise any of these rights, contact us at info@danielciommiento.com. We will respond within 30 days (GDPR) or 45 days (CCPA). You also have the right to lodge a complaint with the Spanish supervisory authority:
Agencia Española de Protección de Datos (AEPD)
C/ Jorge Juan, 6, 28001 Madrid, Spain
www.aepd.es
Terms & Conditions
Updated March 20261. Acceptance of terms
By accessing and using danielciommiento.com, you accept and agree to be bound by these Terms and Conditions. If you do not agree, please do not use this website.
2. Services offered
Daniel Ciommiento offers consulting, positioning, and talent services for luxury hospitality lifestyle groups. All services are described on the website and agreed upon individually with each client prior to commencement.
3. Intellectual property
All content on this website — including but not limited to text, images, videos, logos, and methodology (including "The Iconic Method™") — is the exclusive intellectual property of Daniel Ciommiento. Reproduction, distribution, or use without written permission is strictly prohibited.
4. Limitation of liability
Daniel Ciommiento provides information and consulting in good faith. Results may vary depending on the client's specific circumstances, market conditions, and implementation. We cannot guarantee specific business outcomes. To the maximum extent permitted by applicable law, Daniel Ciommiento is not liable for indirect, incidental, or consequential damages.
5. Third-party links
This website may contain links to third-party websites. Daniel Ciommiento has no control over their content or privacy practices and accepts no responsibility for them.
6. Governing law
These Terms are governed by Spanish law. Any disputes shall be submitted to the courts of Tarragona, Spain, unless mandatory consumer protection laws in your jurisdiction apply.
7. Modifications
Daniel Ciommiento reserves the right to modify these Terms at any time. Continued use of the website after changes constitutes acceptance of the new terms. The date of the last update is shown at the top of this page.
Refund & Cancellation Policy
Consulting & advisory services
Given the bespoke and time-intensive nature of Daniel Ciommiento's services, all fees are agreed upon in a written proposal before work begins. Once a service agreement is signed and work has commenced, fees are non-refundable unless otherwise agreed in writing.
Right of withdrawal (EU consumers)
If you are a consumer located in the European Union and have purchased a service online or at a distance, you have the right to withdraw from the contract within 14 calendar days from the date of signing, without giving any reason, provided that the service has not yet commenced. To exercise this right, send a clear written statement to info@danielciommiento.com.
⚠️ Please note: If you have expressly requested the commencement of services within the 14-day withdrawal period and given prior informed consent, you acknowledge that the right of withdrawal is lost once the service is fully performed.
Cancellation of booked calls
Discovery calls booked via Calendly are free of charge. You may cancel or reschedule up to 24 hours before the appointment without any charge. Cancellations made less than 24 hours in advance may result in the forfeiture of your booking slot.
Disputes & chargebacks
We encourage clients to contact us directly at info@danielciommiento.com to resolve any billing concerns before initiating a chargeback or dispute with their payment provider.
Disclaimer
No guarantee of results
The case studies, testimonials, and examples shared on this website reflect past experiences and results. They are not guarantees that you or any other client will achieve the same outcomes. Individual results depend on many factors including effort, market conditions, and prior experience.
Professional advice
The content on this website is for informational purposes only. It does not constitute legal, financial, tax, or investment advice. Always seek qualified professional advice for your specific situation.
Accuracy of information
While we make every effort to ensure the information on this website is accurate and up to date, Daniel Ciommiento makes no warranties, express or implied, about the completeness, accuracy, or reliability of any information provided.
Availability
We do not guarantee uninterrupted access to this website. Maintenance, updates, or technical issues may cause temporary unavailability. Daniel Ciommiento accepts no liability for any loss or inconvenience caused by such unavailability.
Contact & Data Requests
For any questions, requests, or complaints relating to this Legal & Privacy page, please contact:
Daniel Ciommiento
Calle Fassina 14, Altafulla, Tarragona, Spain
NIF: Y3448899V
info@danielciommiento.com
danielciommiento.com
We will respond to all data protection requests within 30 days in accordance with GDPR Article 12. For urgent matters, please mark your email subject line: "Data Rights Request — Urgent".
