Privacy Policy

Last updated: 21 October 2026

Market Circles SL (“Market Circles”, “we”, “us”) respects your privacy. This Policy explains what personal data we collect through marketcircles.es (the “Site”), our services and the brands we operate, why we collect it, and the rights you have under the EU General Data Protection Regulation (GDPR) and Spanish data protection law (LOPDGDD).

1. Data controller

The data controller is Market Circles, S.L. (NIF/CIF B02911683), registered address at Avda. Jerez, Torrenueva, Núm. 2, Pueblo Andaluz, 29649 Mijas (Málaga), Spain. See our Legal Notice for full Commercial Registry details. For any privacy query, contact mc@marketcircles.es.

Market Circles also operates introduction services under its own brand names, including North Wales Will Writers. Where you contact us through one of these brands, Market Circles SL is the data controller and this Policy applies.

2. What we collect

Contact form data: first name, last name, email address, subject and message content when you submit our contact form.
Enquiry and introduction data: when you message one of our brands (for example on Facebook Messenger or Instagram) or respond to our advertising, we collect your name, phone number, town or postcode, whether your enquiry is for you alone or for you and a partner, the content of your messages, and the date and time you gave your consent.
Client and prospect data: where we deliver campaign management, automation, dialler or data services on your behalf, we may process contact and business data you provide to us for that purpose, acting as your data processor.
Technical data: basic technical information (such as browser type and pages visited) collected via cookies, as described in our Cookie Policy.

3. Why we process it

To respond to enquiries submitted through the contact form (legitimate interest / pre-contractual steps).
To introduce you to a professional partner who can help with your enquiry, where you have asked us to and given your consent (consent).
To keep a record of your consent and our introduction, so we can show it was given and handle any query or complaint (legal obligation / legitimate interest).
To deliver services under a signed contract or proposal (performance of a contract).
To comply with legal and tax obligations.
To operate the Site securely and understand basic usage, where you have consented to non-essential cookies.

4. Contact form submissions

Our contact form is processed using a third-party form-delivery service that forwards submissions to our email inbox. We only use the data you submit to respond to your enquiry, and we do not use it for marketing unless you separately opt in.

5. Introduction services (including North Wales Will Writers)

North Wales Will Writers is an introduction service run by Market Circles SL. We do not write wills or give legal advice ourselves. When you send us your details and agree to be contacted, we pass them to our professional will-writing partner, a will-writing business based in North Wales, so they can contact you about your will. The partner then becomes a separate data controller for the information they hold about you, and their own privacy policy applies to the services they provide.

What we share: your name, phone number, town or postcode, whether the will is for you alone or for you and a partner, and any notes from your messages that help them prepare for the call.
Legal basis: your consent, given when you send us your details after reading our message explaining that we will pass them on.
Withdrawing consent: you can withdraw your consent at any time by replying STOP in the same chat or emailing mc@marketcircles.es. We will stop processing your details and tell our partner to do the same. Withdrawing consent does not affect anything done before you withdrew it.
No obligation: giving your details does not commit you to buying anything.

Messages sent through Facebook Messenger or Instagram are also processed by Meta Platforms Ireland Limited under its own privacy policy.

6. Sharing your data

We do not sell personal data. We share data with:

the professional partner you have asked to be introduced to, as described in section 5;
service providers who support our operations (for example email, hosting, CRM and record-keeping tools, and the form-delivery service referenced above) under appropriate data processing terms;
authorities, where required by law.

7. International transfers

Our will-writing partner is based in the United Kingdom. The European Commission has recognised the UK as providing an adequate level of data protection, so these transfers rely on that adequacy decision. Where any other service provider is located outside the European Economic Area, we take reasonable steps to ensure an adequate level of protection, such as reliance on the European Commission’s Standard Contractual Clauses.

8. Retention

We retain contact form enquiries only as long as needed to handle and follow up on the enquiry. We keep introduction data and the record of your consent for up to 24 months after the introduction, so we can deal with any query or complaint, and then delete it. If you withdraw consent, we delete your details except for a minimal record that you withdrew it. Data processed on behalf of clients is retained in line with the applicable service agreement and deleted or returned at its conclusion, unless a longer period is required by law.

9. Your rights

Under GDPR you have the right to access, rectify, erase or restrict the processing of your personal data, to object to processing, to data portability, and to withdraw consent at any time. You can exercise these rights by emailing mc@marketcircles.es. You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, aepd.es). If you are in the UK, you can also contact the Information Commissioner’s Office (ico.org.uk).

10. Changes to this Policy

We may update this Policy from time to time. The date at the top of this page reflects the most recent revision.