Privacy Policy.

• —Identity: Fëanor's Code S.L.
• —Address: Calle Roque Chabás 29, Puerta 266, CP 03011, Alicante, Spain
• —Tax ID (CIF): B22811475
• —Email: info@feanorscode.com

At Fëanor's Code S.L., we are committed to protecting the privacy of our clients and users. This Privacy Policy describes how we collect, use, store, and protect your personal data in compliance with:

• —Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation - GDPR)
• —Spanish Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights (LOPD-GDD)
• —Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE)

TENGWAR has been designed from its conception with privacy as a fundamental guiding principle:

100% Local Processing: All data processing, including artificial intelligence, document analysis, and queries, runs entirely on hardware installed at the client's premises. There is no transmission of data to external servers.

Zero Cloud Data: Unlike other enterprise AI solutions, TENGWAR does not send any data to cloud services. Your corporate documents, queries, and responses never leave your infrastructure.

Total Client Control: The client maintains absolute control over their data at all times. Fëanor's Code S.L. has no remote access to data processed by TENGWAR.

4.1. Data Processed Locally by TENGWAR (At Client Premises)

TENGWAR processes on your local infrastructure:

Important: This data is processed and stored exclusively on the client's hardware. Fëanor's Code S.L. has no access to this information.

4.2. Data Processed by Fëanor's Code S.L.

Fëanor's Code S.L. only processes the following data:

We process your personal data based on the following legal bases:

5.1. Contract Performance (Art. 6.1.b GDPR)

• —Provision of the TENGWAR product
• —Technical support and maintenance
• —Client account management
• —Service-related communications

5.2. Compliance with Legal Obligations (Art. 6.1.c GDPR)

• —Invoice issuance and tax compliance
• —Response to requests from competent authorities
• —Retention of commercial documentation

5.3. Legitimate Interest (Art. 6.1.f GDPR)

• —Fraud prevention and security
• —Improvement of our products and services (aggregated and anonymized data)
• —Sending information about critical security updates

5.4. Consent (Art. 6.1.a GDPR)

• —Sending commercial communications and newsletters
• —Use of non-essential cookies
• —Participation in satisfaction surveys

In accordance with the GDPR and LOPD-GDD, you have the right to:

How to Exercise Your Rights

You may exercise your rights through:

• —Email: info@feanorscode.com
• —Postal mail: Calle Roque Chabás 29, Puerta 266, CP 03011, Alicante, Spain, indicating "Data Protection"
• —Attaching a copy of identification document

We will respond to your request within a maximum period of one month, extendable by two additional months in cases of particular complexity.

Right to Lodge a Complaint

If you consider that the processing of your data violates regulations, you may file a complaint with the Spanish Data Protection Agency (AEPD): www.aepd.es

For users in other EU countries, you may contact your local Data Protection Authority.

7.1. No Transfer of TENGWAR Data

Data processed by TENGWAR at the client's premises is never transferred to Fëanor's Code S.L. or third parties. The system operates completely autonomously and isolated.

7.2. Recipients of Administrative Data

Administrative and commercial data may be communicated to:

7.3. International Transfers

We do not make international data transfers outside the European Economic Area. Should it become necessary, we will ensure compliance with appropriate safeguards in accordance with Chapter V of the GDPR.

We implement appropriate technical and organizational measures to ensure the security of personal data:

8.1. Technical Measures

• —Data encryption in transit (TLS 1.3)
• —Password hashing with BCrypt
• —Role-based access control (RBAC)
• —Authorization level system
• —Audit logs

8.2. Organizational Measures

• —Staff training in data protection
• —Information security policies
• —Incident management procedures
• —Impact assessments where applicable

8.3. Security in TENGWAR

TENGWAR incorporates enterprise-grade security measures:

• —JWT authentication with secure tokens
• —SSO support with Microsoft and Google
• —Four security classification levels
• —Department-based access control
• —Administrative approval for external users

9.1. Data in TENGWAR (Client Premises)

The client autonomously determines the retention periods for their data in TENGWAR. The system allows deletion of documents, conversations, and users according to each organization's internal policies.

9.2. Administrative Data (Fëanor's Code S.L.)

Our website uses only technical cookies by default and loads analytics only if you give explicit consent in the banner.

Cookie Summary

Google Processing

If analytics are accepted, Google Tag Manager may load Google Analytics 4. Consent Mode v2 is initialized as denied by default and updated only after your choice. Analytics data is used to understand aggregate site usage and improve the website, not to build advertising profiles.

Managing or Withdrawing Consent

You can accept all, reject all, or manage analytics preferences from the cookie banner. You can reopen the banner at any time from the footer link "Cookie preferences" and withdraw consent with the same ease as granting it. You can also delete cookies and localStorage from your browser settings.

TENGWAR is a product aimed exclusively at businesses. We do not knowingly collect data from minors under 14 years of age, in accordance with Article 7 of Spanish Organic Law 3/2018 (LOPD-GDD). If you become aware that a minor has provided us with personal data, please contact us so we can proceed with its deletion.

Our website may contain links to third-party sites. We are not responsible for the privacy practices of such sites. We recommend reading their privacy policies.

We may update this Privacy Policy periodically. Substantial changes will be notified through our website or by email. The date of last update is indicated at the beginning of the document.

For any questions related to this Privacy Policy or the processing of your personal data:

• —Email: info@feanorscode.com
• —Address: Calle Roque Chabás 29, Puerta 266, CP 03011, Alicante, Spain