PRIVACY POLICY

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Below, we inform you about the privacy policy that will apply in those cases in which the interested party, browsing through the website: [insert web page link] “Neelo” (hereinafter, the”Platform”), provide us with your personal data. We want to inform you of our updated Privacy Policy and the destination offered to the personal data you provide to us, including those we collect by browsing our Platform.

  1. IDENTIFICATION OF THOSE RESPONSIBLE

Responsible: TEPOZ INVESTMENT GROUP, S.L. (hereinafter, the”Responsible”)

Registered office: C/ Fernández De La Hoz, 58, Floor 2, Gate C, Madrid (Spain).

Registry Information: Madrid Commercial Registry, Volume 44519, Folio 100, Section 8, Sheet M-784345, I/A 1

C.I.F.: B-44565117

Email: [insert contact email for privacy purposes]

  1. INFORMATION AND CONSENT

In accordance with the provisions of the EU General Regulation 679/2016 on Data Protection (hereinafter,”RGPD”) and in Organic Law 3/2018, of December 5, on Data Protection and Guarantee of Digital Rights (hereinafter,”LOPDGDD”) by accepting this Privacy Policy, the interested party web (hereinafter, the”Interested”) GIVE YOUR CONSENT informed, express, free and unambiguous to process personal data collected through the Platform, through the forms enabled for this purpose or through the information collected by cookies.

In addition, the interested party consents that these data are processed by the Data Controller to provide their services by applying the organizational and security measures required by the RGPD.

All personal data requested from the Data Subject on the Platform are mandatory, and it is not possible to provide the service without the corresponding data processing by the Data Controller. However, browsing on the Platform is free of charge.

The Interested Party guarantees that the personal data provided to the Data Controller is certain and accurate, so that the Data Controller will not be responsible for any incident resulting from the inaccuracy or falsehood of the information provided by the Interested Parties, regardless of the possibility that the Interested Party has to exercise their right to rectification.

In the event that the interested party provides us with data from third parties, as responsible or in charge of the treatment, he will be responsible for complying with all applicable data protection regulations. In addition, the Interested Party guarantees that they have obtained all legally necessary consents, authorizations and/or approvals before including personal data of third parties on the Platform.

  1. ORIGIN, PURPOSE AND LEGAL BASIS

The personal data of the interested party, or of third parties, that are transferred by the interested party, will be treated confidentially and will be incorporated into the corresponding processing activity of the Data Controller.

The processing activities carried out by the Data Controller are as follows:

ACTIVITY: Execution of the contract

ORIGIN

From the interested party himself through the Platform.

LEGAL BASIS

General Data Protection Regulation, in particular:

  • Art. 6.1.a): the interested party gave their consent to the processing of their personal data;
  • Art. 6.1.b): processing is necessary for the execution of a contract to which the interested party is a party or for the application, at the request of the interested party, of pre-contractual measures;
  • Art.6.1.f): processing is necessary for the satisfaction of legitimate interests pursued by the data controller.

PURPOSES OF TREATMENT

  • Execution of the contract;
  • Respond to the requests and/or requests of the Interested Party;
  • Business and marketing purposes.

COLLECTIVE

Individuals, including representatives of legal entities, Stakeholders of the Platform.

DATA CATEGORY

Name, surname, email address, telephone number, transaction data based on transactions made through the Platform, billing information or other type of data provided by the Interested Party through the Platform.

INTERNATIONAL TRANSFER

International data transfer is not planned.

RECIPIENTS

The transfer of data to third parties is not envisaged, except for legal obligation or prior unequivocal and informed consent of the interested party.

STORAGE PERIODS

The data will be kept for the period strictly necessary to fulfill the purpose for which they were collected.

ACTIVITY: Contact via email or form

ORIGIN

From the interested party by sending emails to the indicated address, the form or using any telephone number provided through the Platform.

LEGAL BASIS

General Data Protection Regulation, in particular:

  • Art. 6.1.b): request for pre-contractual measures (management of requests or requests that the Interested Party makes to the Responsible's customer service).

PURPOSES OF TREATMENT

Respond to and respond to the inquiries requested by the Interested Party.

COLLECTIVE

Natural persons, including representatives of legal entities, users of the Platform.

DATA CATEGORY

Name and surname, email address, telephone number, as well as the rest of the data that the interested party indicates in the body of the message.

RECIPIENTS

The transfer of data to third parties is not envisaged, except for legal obligation or prior unequivocal and informed consent of the interested party.

INTERNATIONAL TRANSFER

International data transfer is not planned.

STORAGE PERIODS

The data will be kept for the period strictly necessary to fulfill the purpose for which they were collected.

In the same way, and with the prior consent of the Interested Party, in order to be able to offer users of the Platform those products according to their interests and improve their browsing experience on the Platform, the Responsible Party may draw up a “commercial profile” based on the information provided by the Interested Party. No automated decisions will be made based on that profile.

  1. DATA OF THE INTERESTED PARTY

The interested party guarantees that the data provided is true, accurate, complete and updated, and is responsible for any direct or indirect damage or loss that may arise as a result of the breach of such obligation, regardless of the possibility that the interested party has to exercise their right of rectification.

In addition, the interested party certifies that they are over eighteen (18) years of age and, therefore, has the necessary legal capacity to provide consent regarding the processing of personal data in accordance with this Privacy Policy. If the interested party is under eighteen (18) years of age, the interested party must have the prior and express authorization of their parents, guardians or legal representatives, who will be considered responsible for the acts carried out by the minors under their care, in accordance with current regulations.

In the event that the data provided belong to a third party, the interested party guarantees that they have informed that third party of the aspects contained in this document and obtained their authorization to provide their data to the person responsible for the purposes indicated above.

The Responsible Party cannot guarantee the absolute invulnerability of the systems, therefore, he does not assume any responsibility for damages resulting from alterations that third parties may cause to computer systems, electronic documents or files.

  1. COOKIE POLICY

In accordance with the provisions of the RGPD and Law 34/2002, on Information Society Services, all personal data obtained through cookies during the use of the Platform will be treated in accordance with the provisions of the Cookie Policy.

  1. EXERCISE OF RIGHTS

In accordance with the provisions of the RGPD, we inform you that you can exercise your rights to access, rectification, deletion, opposition, data portability and limitation of treatment directly to the Responsible.

To exercise these rights, the interested party may send a message for this purpose, indicating name, surname, email, ID number or passport, to the following email address: [insert contact email for privacy purposes].

The interested party may also exercise their rights by filing a complaint with the Spanish Data Protection Agency.

  1. ACCEPTANCE OF THE PRIVACY POLICY

The Interested Party ACKNOWLEDGE AND ACCEPT THAT YOU HAVE READ AND UNDERSTOOD this Privacy Policy whose content constitutes the entire agreement between the Interested Party and the Data Controller regarding the use and processing of their personal information. The interested party expressly agrees to be bound by the terms of this Privacy Policy, in all its extent and scope, without exception to any of its provisions.

The express acceptance of this Privacy Policy will be essential when the User registers through the Platform by filling out the corresponding registration/subscription form.

Last updated: July 8, 2024.