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TENGWARTENGWAR

Privacy Policy

Last updated: January 2026

1. Data Controller

  • Identity: Fëanor's Code S.L.
  • Address: ST ROQUE CHABAS, N 29, DOOR 266, PC 03011, Alicante, Spain
  • Tax ID (CIF): B22811475
  • Email: info@feanorscode.com

    • 2. Introduction

    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)

    • 3. Fundamental Principle: Privacy by Design

    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. Data We Process

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

    TENGWAR processes on your local infrastructure:

    CategoryDataPurpose
    Corporate documentsPDFs, Word, Excel, PowerPoint, images, CSV, JSON, XML, HTML, Markdown and other formatsIndexing and semantic search for RAG-based responses
    User queriesQuestions and commands entered in chatGeneration of contextualized responses
    Session dataConversation history, user preferencesService continuity and experience improvement
    Access credentialsUsernames, hashed passwords (BCrypt)Authentication and access control
    Organizational metadataDepartments, roles, authorization levelsPermission management and security

    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:

    CategoryDataLegal BasisPurposeRetention
    Business contact dataName, email, phone, company, positionContract performance (Art. 6.1.b GDPR)Management of commercial and contractual relationshipContract duration + 5 years
    Billing dataTax data, payment informationLegal obligation (Art. 6.1.c GDPR)Compliance with tax obligations6 years (Commercial Code)
    Technical support dataReported incidents, communicationsContract performance (Art. 6.1.b GDPR)Provision of support serviceContract duration + 2 years
    Web browsing dataIP, cookies (see specific section)Consent (Art. 6.1.a GDPR)Website analysis and improvementSee cookie policy

    5. Legal Bases for Processing

    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

    • 6. Data Subject Rights

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

    RightDescription
    AccessObtain confirmation of whether we process your data and access to it
    RectificationRequest correction of inaccurate or incomplete data
    ErasureRequest deletion of your data when the prescribed circumstances apply
    RestrictionRequest restriction of processing in certain cases
    PortabilityReceive your data in a structured format and transmit it to another controller
    ObjectionObject to the processing of your data in certain circumstances
    Not be subject to automated decisionsNot be subject to decisions based solely on automated processing
    Withdraw consentWithdraw consent given at any time

    How to Exercise Your Rights

    You may exercise your rights through:

  • Email: info@feanorscode.com
  • Postal mail: ST ROQUE CHABAS, N 29, DOOR 266, PC 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. Data Recipients

    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:

    RecipientPurposeSafeguards
    Tax AdministrationCompliance with tax obligationsLegal obligation
    Financial institutionsPayment and collection managementContract performance
    Legal and accounting advisorsProfessional adviceConfidentiality agreement
    Technology providersWeb hosting, corporate emailData processing agreement (Art. 28 GDPR)

    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.

    8. Security Measures

    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. Data Retention

    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.)

    Data TypeRetention PeriodLegal Basis
    Contractual dataContract duration + 5 yearsStatute of limitations for civil actions
    Invoices and tax documentation6 yearsArt. 30 Commercial Code
    Support dataContract duration + 2 yearsLegitimate interest
    Commercial communicationsUntil withdrawal of consentConsent

    10. Cookie Policy

    Our website uses cookies. For detailed information about the types of cookies used, their purposes, and how to manage them, please see our Cookie Policy.

    Cookie Summary

    TypePurposeRequires Consent
    TechnicalWebsite operationNo
    AnalyticalUsage statisticsYes
    AdvertisingNot usedN/A

    11. Minors

    TENGWAR is a product aimed exclusively at businesses. We do not knowingly collect data from minors under 16 years of age. If you become aware that a minor has provided us with personal data, please contact us so we can proceed with its deletion.

    12. Third-Party Links

    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.

    13. Updates to This Policy

    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.

    14. Contact

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

  • Email: info@feanorscode.com
  • Address: ST ROQUE CHABAS, N 29, DOOR 266, PC 03011, Alicante, Spain

    • Executive Summary

    AspectDescription
    Who is the data controller?Fëanor's Code S.L.
    What data is processed in TENGWAR?Only on your infrastructure, without access by us
    Is data sent to the cloud?No, 100% local processing
    What are your rights?Access, rectification, erasure, restriction, portability, objection
    How to contact?info@feanorscode.com

    © 2026 Fëanor's Code S.L. All rights reserved.

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