Privacy Policy
Last updated: November 1, 2026
1. Controller
Pablo Bellene
Stobbestraße 9
45147 Essen, Germany
Email: pablo@emigrarbook.com
Website: emigrarbook.com
Pablo Bellene is the owner of the site, the author of the book and the controller within the meaning of Art. 4(7) GDPR. There is no other company, publisher or entity behind this project. No data protection officer has been appointed because the conditions of Art. 37 GDPR and § 38 BDSG are not met.
2. What happens when you visit the site
Hosting. The site is hosted by Netlify (Netlify, Inc., USA). In order to deliver the pages to you, Netlify automatically processes technical connection data: IP address, date and time, requested page, amount of data transferred, response code, the browser and operating system reported, and, where applicable, the referring page. This processing is essential: without it there is no way to serve you the site. The legal basis is our legitimate interest in delivering and protecting the website (Art. 6(1)(f) GDPR). We do not use this data to profile anyone, nor do we combine it with other information. Netlify acts as our processor under a data processing agreement pursuant to Art. 28 GDPR.
And nothing else. The fonts, images, video and the text of the introduction are served from this same domain. On your first visit the site does not load optional providers: no analytics, no forms, no third-party scripts, and it does not set any cookie. The only exception is the hosting described above, which is technically unavoidable.
3. Storage in your browser
When you make a choice in the cookie panel, we store a single key in your browser's local storage (localStorage):
eb_consent— contains the version of the consent system, the version of this policy, whether you accepted analytics, amarketingfield that is always false since the advertising pixel was removed, and the date and time of your choice.
This key stays on your device and is not sent to any server. It serves only one purpose: to remember your choice in this browser so we don't ask you again. To be precise: since it is not transmitted, it does not constitute proof of consent that we could produce later; it is a local record of your preference, nothing more. We do not keep any consent record on a server, because doing so would require collecting and retaining data that we do not currently need.
It is kept until you delete it from your browser or until we change the version of the consent system, at which point you will be asked again. The legal basis for storing it is § 25(2) no. 2 TDDDG: it is strictly necessary to provide the service that you yourself requested by making a choice.
If you accept analytics, Google may also set its own cookies. These are described in section 5. You can change or withdraw your choice at any time using the “Cookie settings” link in the footer. When you withdraw it, we delete the analytics cookies accessible from this domain, disable measurement and reload the page to stop any tracking in progress. Please note that we can only delete what belongs to this domain: anything a third party has stored on its own domain cannot be reached from here, and anything already transmitted cannot be undone.
4. Consent: what it means and how to withdraw it
Analytics is activated only with your explicit consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG). Without consent, no script from that provider is loaded. No optional box is pre-ticked. On your first visit a notice appears at the bottom of the page that does not block reading, with “Reject” and “Accept” given equal weight. As long as you don't choose — or if you keep browsing without choosing — nothing is activated.
Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal (Art. 7(3) GDPR).
5. Google Analytics 4 (only with consent)
If you accept the “Analytics” category, Google Analytics 4 is loaded (measurement ID G-8SV371B09S), provided for European users by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland).
It helps us understand, in aggregate, which pages are read and how people arrive at the site.
Google Analytics may process, among other data, a truncated IP address, device identifiers
stored in cookies (_ga, _ga_*), page views, visit duration, device
type, browser and approximate location.
We also record a few clicks within the site: which edition, format and store you choose,
clicks on the buy buttons (we do not know whether you then buy), switching language, and
opening the introduction.
Legal basis: your consent. Analytics data is kept for the retention period set in the
property (at most 14 months); the _ga cookies last up to 2 years. Google acts
as our processor under a data processing agreement pursuant to Art. 28 GDPR.
We implement Google's Consent Mode: until you accept, the storage status is declared as denied; if you withdraw consent, it is updated to denied and the opt-out specific to this property is activated.
International transfer. Although the service in Europe is provided by Google Ireland Limited, Google may process data on servers of Google LLC in the USA. Google LLC is listed under the EU-US Data Privacy Framework, the adequacy decision adopted by the European Commission on July 10, 2023, and also applies standard contractual clauses. That framework is subject to challenges before the European courts and its future validity is not guaranteed. Google's privacy policy: policies.google.com/privacy.
6. Advertising: there is none
This site does not use advertising pixels. The Meta Pixel that was used previously was removed in August 2026 because there are no paid campaigns running and it made no sense to keep a data transfer that did not inform any decision. If it is ever reactivated, we will say so here, it will appear as a separate category in the cookie panel and you will be asked again before it is activated.
7. The introduction and the former subscriber list
Today. The book's introduction opens and is read directly on this website
(also via the shortcut emigrarbook.com/intro). There is no form, your email is
not requested and no third-party service is loaded to read it: the text is served from this
same domain. The site no longer loads MailerLite or Google reCAPTCHA and does
not accept new subscriptions.
Those who subscribed earlier. Until November 2026 the introduction was sent by email through a MailerLite form, protected by Google reCAPTCHA. People who were already subscribed receive the remaining emails in that sequence; when it ends, all records in the account are deleted, including unsubscribes; the provider's backups are erased according to its own schedule. The list is not used for any other mailing. Until then:
- Data: your email, your name (if you provided it) and the data MailerLite recorded at sign-up as proof of consent: IP address, approximate location, date, time, source and confirmation.
- Legal basis: the consent you gave in the form (Art. 6(1)(a) GDPR); the sign-up data serves as proof of consent (Art. 7(1) GDPR).
- Measurement: MailerLite may measure opens (invisible image) and always wraps links to count clicks; it does not allow this to be disabled for a specific address.
- Unsubscribing: every email includes an unsubscribe link; when you use it, we stop writing to you immediately. If you would rather we delete your record right away, write to us.
- Provider: MailerLite (Vercom S.A. group), with declared primary storage in the European Union and a data processing agreement pursuant to Art. 28 GDPR. Its contract allows sub-processors and processing outside the EU with the safeguards described in section 13. Policy: mailerlite.com/legal/privacy-policy.
Once the list is deleted, this section will be reduced to a note and the date at the top will be updated.
8. How to withdraw each thing
- Analytics. Via “Cookie settings” in the footer (section 3).
- Emails from the former list. Via the unsubscribe link in any email.
- Deletion of your data. Write to us and we will delete your subscriber record without waiting for the list to be deleted.
Anything already transmitted before the withdrawal cannot be undone retroactively, and the withdrawal does not affect the lawfulness of that earlier processing (Art. 7(3) GDPR).
9. If you email us
When you write to us at pablo@emigrarbook.com, we process your address and the content of your message in order to reply. The legal basis is our legitimate interest in responding to inquiries (Art. 6(1)(f) GDPR) or, if your inquiry relates to a contract, Art. 6(1)(b) GDPR. We keep the correspondence for as long as necessary for the matter and, where applicable, for the retention periods required under German commercial and tax law. Email to the domain is routed through an external forwarding service before reaching the mailbox; email is not an end-to-end encrypted channel, so please do not use it for particularly sensitive information.
10. Links to stores and external sites
The buy buttons, the link to Instagram and the articles published in the media take you off this site. They are not affiliate links and we do not receive any commission per click. Until you click them, those platforms receive nothing from here. Once you are there, each one is an independent controller and applies its own policy:
- Lemon Squeezy — EPUB digital edition. Acts as Merchant of Record (lemonsqueezy.com/privacy).
- Amazon — Kindle edition and print edition, depending on the country's store.
- Autores Editores — print edition distributed in Argentina.
- Instagram — the project's profile (Meta Platforms Ireland Limited).
- News media — Infobae, Los Andes and Diario UNO, when you open an article.
No payments are processed and no card data is stored on emigrarbook.com.
11. Summary: data, purpose and legal basis
- Connection data (IP, time, browser) — delivery and security of the site — legitimate interest, Art. 6(1)(f) GDPR. Unavoidable.
- Your cookie choice (
eb_consent) — remembering it in this browser — § 25(2) no. 2 TDDDG. - Site usage data (GA4) — aggregate analytics — consent.
- Former subscriber list (email, name, sign-up data) — completing the email sequence already requested, until the list is deleted — consent, Art. 6(1)(a) GDPR; the sign-up data serves as proof of consent (Art. 7(1) GDPR).
- Email correspondence — replying to you — legitimate interest or performance of a contract.
We do not process special categories of data under Art. 9 GDPR, we do not process payment data, and the site is not directed at children under 16.
12. Retention periods
- Server logs: kept by Netlify according to its own retention periods. We have no interface to change them and we do not download them.
- Former subscriber list: until the email sequence ends; after that, all records in the account are deleted, including unsubscribes, and the provider's backups are erased according to its own schedule. If you unsubscribe earlier, we stop writing to you immediately.
- Analytics: according to the retention period set in the Google Analytics property (at most 14 months).
- Correspondence: for as long as the matter requires and, where applicable, for the statutory retention periods applicable in Germany.
- Your cookie choice: in your browser, until you delete it or until we change the version of the consent system (currently version 4).
13. International transfers
Netlify (USA) and Google may process data outside the European Economic Area, mainly in the USA. In the case of MailerLite (for as long as the former list exists), the declared primary storage is in the European Union, but its contract allows the involvement of sub-processors and affiliates and does not make it possible to fully rule out access or processing outside the EU. All of these transfers rely on the adequacy decision for the EU-US Data Privacy Framework where the recipient is certified, and on standard contractual clauses approved by the European Commission. We cannot guarantee that a third country will at all times offer a level of protection equivalent to that in Europe, nor rule out access to the data by local authorities.
14. Your rights
With regard to your personal data, you have the right to:
- Access (Art. 15 GDPR): know what data about you we process and obtain a copy.
- Rectification (Art. 16 GDPR): have inaccurate or incomplete data corrected.
- Erasure (Art. 17 GDPR): ask us to delete it.
- Restriction (Art. 18 GDPR): ask us to stop using it without deleting it.
- Portability (Art. 20 GDPR): receive it in a structured, commonly used format.
- Objection (Art. 21 GDPR): object to processing based on legitimate interest, on grounds relating to your particular situation.
- Withdrawal of consent (Art. 7(3) GDPR): at any time, as described in section 8.
To exercise them, write to us at pablo@emigrarbook.com. We will respond without undue delay and in any event within one month of receiving the request. That period may be extended by two further months if the request is complex or if we receive several; in that case we will inform you of the extension and the reasons for it within the first month (Art. 12(3) GDPR). We may need to verify your identity before responding (Art. 12(6) GDPR).
15. Complaints to the supervisory authority
Without prejudice to any other remedy, you have the right to lodge a complaint with a data protection authority (Art. 77 GDPR). Since the controller is a private individual based in Essen (North Rhine-Westphalia), the competent authority is:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW)
Kavalleriestraße 2–4, 40213 Düsseldorf
Postal address: Postfach 20 04 44, 40102 Düsseldorf
Phone: 0211 38424-0 · Email: poststelle@ldi.nrw.de
www.ldi.nrw.de
You may also contact the authority in your country of residence or in the place of the alleged infringement.
16. Automated decision-making
We do not make automated decisions with legal effects or carry out profiling within the meaning of Art. 22 GDPR. Analytics produces aggregate statistics that are not used to make individual decisions about anyone.
17. If you do not provide your data
You are not required to give us anything. You can read the entire site and buy the book in the external stores without providing us with any data. The introduction can be read on the site without giving any data and, if you reject analytics, everything works exactly the same.
18. Security
We take reasonable technical and organizational measures proportionate to the size of the project: encrypted transport (HTTPS/TLS) with HSTS, security headers on the server, fonts, images, video and the introduction text served from the site's own domain, blocking of every optional third-party resource until consent is given, restricted access to provider accounts and two-step verification where the provider offers it. No measure completely eliminates the risk involved in transmission over the internet.
19. Changes to this policy
We may update this policy when the services we use or the legal framework change. The date of the last update is shown at the top. If the change affects processing that depends on your consent, we increment the version of the consent system and you will be asked again. Full contact details are provided in the Impressum.