If the two versions differ, the Spanish one prevails.
1. Data controller
- Controller: Miguel Ángel González Moríñigo, Tax ID (NIF) 07979570L
- Trade name: Momentum Logic AI (including the Atria service)
- Address: C. Los Mirlos, 4, 33186 El Berrón (Siero), Asturias, Spain
- Email: info@momentumlogicai.es
No data protection officer has been appointed, as the activity does not require one.
2. What data we process, why and on what legal basis
| Where | Data | Purpose | Legal basis |
|---|---|---|---|
| Nox chat and contact form | Name, email, phone, company, interest and the conversation text | Answer your enquiry, assess your request and book a free diagnostic call | Your consent when you write to us and pre-contractual steps you request (GDPR Art. 6(1)(a) and (b)) |
| Atria demo (Lucía) | Messages (max. 500 characters), a random session ID and date | Let you try the demo and improve the service | Your consent by using the demo (Art. 6(1)(a)) |
| Workshop demo | Workshop trade name, contact person, phone, email, city, fictitious data entered during the trial and technical activity logs (events, device and time of use) | Handle the registration, give you access to the demo, keep it running and follow up commercially only if you authorise it separately | Pre-contractual steps you request, to manage the access (GDPR Art. 6(1)(b)); your consent for optional follow-up emails (Art. 6(1)(a)); legitimate interest in the platform's technical security, where applicable (Art. 6(1)(f)) |
| Blog | Technical connection data (IP, browser) logged by the server | Show the site and keep it secure | Legitimate interest in site security (Art. 6(1)(f)) |
The demos are meant to be tried with fictitious information or data that does not identify people. Do not enter personal data of clients, employees, suppliers or other third parties, or confidential or specially protected information (health, children, patients).
The contact details of the person requesting access may be real personal data and are processed only to manage that access and any additional purposes you have accepted.
If you accidentally enter third-party personal data, tell us at info@momentumlogicai.es so we can assess the incident and delete the data where appropriate.
3. AI assistants
Nox (chat on momentumlogicai.es) and Lucía (Atria demo) are AI assistants, and the conversation tells you so. We take no solely automated decisions with legal effects on you: a person handles contact and booking requests.
To generate the answers of Nox and Lucía, the conversation text is sent to OpenAI through its API.
Under OpenAI's API terms, this data is not used by default to train its models unless the customer expressly authorises it. However, OpenAI may retain certain request and response data to detect misuse and for security; in general, these logs may be kept for up to 30 days, subject to the exceptions of each service and configuration. We limit what we send to what is needed to answer.
Nox also uses a knowledge base hosted by Pinecone that holds corporate information of Momentum Logic AI and no user data; your question is turned into a semantic search against it.
If you prefer not to send your query to these providers, write to info@momentumlogicai.es.
4. Recipients and processors
| Provider | Purpose | Processing and safeguards |
|---|---|---|
| IONOS Cloud S.L.U. (Tax ID B-85049435, Madre de Dios 21, 26004 Logroño, Spain) | Hosting of the VPS server, applications, databases and automation (n8n) | Hosting contracted in Spain. The provider's contractual terms and security measures apply |
| OpenAI | Processing conversations and generating the answers of the AI assistants | Processing under its API terms and the applicable data protection and international transfer safeguards |
| Pinecone | Nox knowledge base (no user data) | Processing under its terms and the applicable safeguards |
| Google Ireland Limited and the Google entities involved | Contact management (spreadsheets), calendar and email | Processing under the Google Workspace terms and the safeguards applicable to each service and transfer |
| Cloudflare | DNS management and, where enabled, security and connectivity services | Processing under the services actually contracted and the applicable safeguards |
Providers that access personal data on our behalf are bound by the confidentiality and data protection obligations that apply and, when acting as processors, by the terms required by Article 28 GDPR.
Where there are international transfers, the appropriate mechanism applies in each case: an adequacy decision, the EU-US Data Privacy Framework or standard contractual clauses with the necessary additional safeguards. You can ask for information about these safeguards at info@momentumlogicai.es.
We do not sell your data or share it with third parties except where required by law.
5. How long we keep your data
- Lucía demo conversations: at most 90 days from creation, unless they must be kept temporarily because of a security incident or a legal obligation.
- Nox and contact form leads: during the business relationship and for at most 24 months after the last meaningful contact, unless a contract is signed or a legal retention duty applies.
- Workshop demo logs and accounts: while the access stays active and for up to 12 months of inactivity.
- Billing data: the periods required by tax and commercial law.
After these periods data is deleted or anonymised, including the deletion cycles of backups. Data that must be kept blocked for legal reasons or for claims stays separate and limited to that purpose.
6. Your rights
You may exercise your rights of access, rectification, erasure, objection, restriction and portability, and withdraw any consent you have given, by writing to info@momentumlogicai.es.
Withdrawing consent does not affect the lawfulness of processing carried out before it. If we have reasonable doubts about your identity, we may ask for the information strictly necessary to verify it.
You can also complain to the Spanish Data Protection Agency (www.aepd.es).
7. Security
We apply reasonable technical and organisational measures: encrypted connections (HTTPS), restricted access to the server and databases, backups and usage limits on the assistants. No system is infallible; if a breach affects you, we will notify you as the law requires.
8. Children
The websites are not aimed at children under 14 and we do not knowingly collect their data.
9. Changes
If this policy changes, we will publish the new version with its date. Last updated: 31 October 2026.