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tweem

Privacy Policy

1. Object

In compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 regarding the protection of natural persons with regard to the processing of personal data and the free circulation of this data (hereinafter GDPR) and other regulations in force on the matter, VBOTE INNOVATION SL (hereinafter VBOTE), wishes to inform users of the website www.tweem.com(hereinafter, the site or the website) the policy regarding the treatment and protection of personal data of those people who provide their personal data for the personalised use or under registration of the services of the site or any other act that involves a communication of your personal data to VBOTE (hereinafter also, Policy or Privacy Policy).

VBOTE informs the user of the site that this Privacy Policy contains a general description of the aspects related to the processing of personal data derived from the exploitation of the VBOTE website that this entity carries out as responsible for said treatment.

This policy is completed with those informative texts and texts requesting informed consent that are incorporated into any data request form on the website or are included in any particular conditions for the use of certain services.

It is the user's responsibility to read the aforementioned informative texts and consent request texts included in any data request form on the site as well as the content of this policy before communicating their personal data to VBOTE.

2. Obligation or voluntary nature of the communication of data by the user

The use of this site is voluntary for the user, but such use is regulated by the general contractual conditions published on this site, both for use of the site and for privacy.

Consequently, the use of the services of the website www.tweem.com, including those that require the communication of data to VBOTE, is always voluntary, but conditioned by the terms and conditions of use and privacy that, therefore, are understood to be expressly and fully accepted by the user of the site and the services published therein.

If the user voluntarily decides to use any service on this website that requires the communication of personal data, said communication constitutes a contractual requirement derived from the acceptance of the terms and conditions that regulate the site, leaving the user obliged to provide the data personal requests that this site requests, and being informed that, otherwise, the possible consequences of not providing such data are fundamentally the impossibility of using the requested web service.

In the event that the user does not agree with this policy or conditions of service, they should not access or use any service on the site that requires the communication of their personal data to VBOTE.

Likewise, the user is informed that this policy will be of subsidiary application of those others that, on the same matter, are established with a special and / or particular nature and are communicated to the user, without limitation, through the registration forms, contracting conditions or conditions of the particular services, this policy being complementary to the previous ones in that it is not contradicted.

When the user must communicate their personal data to VBOTE through the forms published on the site, if the user does not provide all the data requested in each form or, where appropriate, does not provide those marked with an asterisk for mandatory completion, VBOTE will not attend or will not be able to adequately attend the request made by the user and / or to guarantee the use and enjoyment of the requested service.

The user is informed that any processing of personal data will fall under the scope of the current legislation in Spain on data protection.

For this purpose, personal data shall be understood to be any information concerning identified or identifiable natural persons – including the data of the email and / or IP address- and by user, any identified or identifiable natural person who communicates their character personal data to VBOTE by email, customer service, sending curriculum vitae, filling in forms on this website and / or using services aimed at users of this website.

3. Identification and contact data of the person responsible for the treatment

The person responsible for the processing of personal data carried out through the website or as a result of the use of its services is VBOTE INNOVATION SL (hereinafter VBOTE).

Contact information: Address c/Reina, 10 pta 1. Contact email address info@vbote.com Telephone 963256879.

4. Data of minors or the disabled

Minors under 16 years of age and incapacitated persons may not use the services of the VBOTE website that require registration or identification without the representation of their father, mother, guardian or legal representative.

5. Accuracy and veracity of personal data

Users who access the VBOTE website are not obliged to provide personal information to use the site, therefore, any data communication for such purposes will be because the user has voluntarily decided to navigate or personalised use of the site and / or of the services made available through it.

In the event that the user provides VBOTE with their personal data, the user is obliged to provide true, current and exact data that correspond to their own identity, being responsible for any data and information of third parties that they provide for the use of the services made available to you through the site.

The user is solely responsible for the veracity, accuracy, updating and correction of the data provided, exonerating VBOTE of any responsibility in this regard and the user committing to keep the personal data duly updated.

The user agrees to provide truthful, updated, complete and correct information, always and only corresponding to their own identity, through any data collection channel published on the site, such as registration, registration or subscription forms, contact, of suggestions, hiring and / or any other request form for site data, including other means such as sending an email to VBOTE, through postal communication and / or by phone call.

The user is the only source of information for their personal data, so VBOTE asks that, in order to keep their data updated and updated at all times in accordance with the principles of data protection legislation, communicate to the postal and electronic addresses indicated below for the exercise of the rights indicated in this Policy, any variation thereof. In any case, when the data is collected or provided directly from the affected user, in accordance with the provisions of current regulations, those provided by the latter will be considered accurate, as long as the user does not update or rectify them.

6. Special categories of data

VBOTE does not request or require through the site information or data from special categories of users, understood by these, in accordance with current regulations, personal data that reveals race, ethnic or racial origin, political opinions, convictions or religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data relating to physical or mental health, data relating to the sexual life or sexual orientations of a natural person, data relating to convictions or criminal offenses.

In the event that VBOTE at any time requires this information from the user, the express consent of the user will be requested (either through a statement or a clear affirmative action), to collect and use that information, communicating to the user, previously and unequivocally, the purpose of the collection and treatment of said information.

Consequently, in the event that for any reason, and without having been requested by VBOTE, said information is voluntarily communicated by the user to the aforementioned entity, said communication will involve an explicit act of the user that implies the existence of a manifestation of express consent. by the user regarding the processing of their data by VBOTE.

7. Purposes and legal bases of the processing of personal data

Users who access the website and voluntarily provide personal information to navigate the site in a personalised way, contact, hire or use a service that requires the communication of data to VBOTE, are informed of the following purposes and legal bases of treatment of the Personal data of the users that VBOTE may carry out:

Based on the legal basis of the consent given by the user when supplying their data, VBOTE may carry out the processing of their data for the following purposes:

Contact with VBOTE: When the user uses the services enabled for this purpose to contact VBOTE (through forms, telephone, post or email), VBOTE will process their personal data to attend and manage the response to the communication made by the user and provide the requested information.

Sending commercial communications: When the user expressly authorises or consents, VBOTE will process their data to send them advertising information, bulletins, news and invitations to events and commercial communications. The legal basis for the processing of these user data by VBOTE is the consent granted by the user by accepting the corresponding boxes prior to sending the completed form to VBOTE.

Selection of candidates: If the user sends their curriculum vitae, the data provided through the site and / or those that are requested through the procedure established on the website, will be processed by VBOTE in order to assess and allow where appropriate their participation in selective processes developed by VBOTE.

Based on the contractual relationship established between VBOTE and the user who contracts with VBOTE the use of an online service, VBOTE may carry out the processing of user data for the following purposes:

Carry out the execution, maintenance, compliance and control of the contractual relationship, which may include authenticating the identity of the user and / or sending the keys to allow access and use of the service, as well as any purposes directly or indirectly related to the use of such services through this website, all without prejudice to the fact that this information will be specifically indicated in the particular contracting conditions and in the data request forms used for this purpose. Send the user by post, email and other equivalent electronic communication means bulletins, news, invitations to events, commercial and advertising communications regarding VBOTE products or services similar to those initially contracted,

With legal basis in the legitimate interest, VBOTE may carry out the processing of the user's data with the following purposes:

Exclusion of the sending of commercial and advertising communications: When the user requests the cancellation of the service of sending commercial and advertising communications , VBOTE will process your data to keep the minimum essential data of the interested party, in order to identify you and adopt the necessary measures that prevent the sending of commercial and advertising communications.

In any case, the user is informed that the purposes of processing the user's data collected through the forms published on the site will be explained through informative texts published on the forms themselves and when required, as set out above. VBOTE will request, through the boxes provided for this purpose, the consent of the user for the processing of their personal data when the legal basis for such treatment is based on obtaining the consent of the user.

8. Recipients of the data

With a legal basis in compliance with legal obligations, the user's personal data will be communicated to third parties when there is a legal obligation to communicate to the competent public authorities by reason of the matter and / or for the attention of the requirements made by them.

In such cases, they may be recipients of the data, without limitation, administrative bodies or Control Authorities in matters of data protection, telecommunications and the information society, Judges, Public Prosecutor's Office, Courts, Court of Accounts or Ombudsman.

Based on the legal basis in the execution of a contractual obligation, in the event that the user activates, registers or contracts a service offered through the website, VBOTE may transfer their data to third parties necessarily involved in the management of the service for the purpose to correctly manage the entire process of activation, subscription or contracting of the service, being the recipients of your data the banking and financial services entities involved in the collection of the services, and any other third parties that necessarily, directly or indirectly, must intervene in the management of the contracting of the service.

VBOTE informs the user that any other communication of data to third-party recipients that they must carry out will be made known to them, informing them in an expressly precise and unequivocal way of the legal basis of the treatment, of the recipients of the information, of the purpose to which they will be destined, the data, and the nature of the data transferred and, where appropriate, when the legislation establishes it, the explicit, unequivocal, specific and informed consent of the user will be previously requested. For these purposes, the user must pay special attention to the basic and detailed or additional information provided in each case in the personal data collection forms published on the site.

In the cases in which, in accordance with what is indicated in this section, VBOTE communicates data to a third party, VBOTE is not responsible for the data processing carried out by said third party, who, in any case, will become the new data controller. of the information, being obliged to comply with the obligations established by current regulations for this purpose.

In addition, third-party service providers with the category of data managers may be recipients of the data in order to provide services that support the data processing tasks, always commissioned by VBOTE and after signing a custom contract. treatment with sufficient guarantees of security, confidentiality, return or destruction of data and compliance with the instructions given by VBOTE to carry out the treatment. In these cases, there are the following categories of companies that provide web hosting services, providers of communication delivery services, providers of maintenance and computer support services and others.

9. International data transfers

Except for legal obligation, VBOTE will not carry out international transfers of the user's personal data to countries or international organisations.

10. Period of conservation of personal data

Regarding the conservation periods of the data provided by the interested party through the site, the following conservation criteria will be applied depending on the purposes for which they have been supplied:

The personal data that have been provided by the interested party to contact VBOTE and request information, will be kept by VBOTE as long as the treatment is maintained and as long as its deletion is not requested by the interested party and, where appropriate, until the legal deadlines for compliance with obligations and attention of possible responsibilities are completed.

When the interested party has expressly authorised the sending of advertising information, the data will be kept by VBOTE as long as the treatment is maintained and as long as its deletion is not requested by the interested party and, the deletion of the data by the interested party, and, in its case, until completing the legal deadlines for compliance with obligations and attention to possible responsibilities.

When the interested party sends their curriculum vitae to VBOTE, the data will be kept by this entity for a period of 24 months from receipt, unless the interested party requests its deletion before said period ends and, where appropriate, until the deadlines are completed. Legal requirements for compliance with obligations and attention to possible responsibilities.

The personal data that have been provided by the interested party for the activation, subscription or contracting of a service, will be kept by VBOTE as long as the contractual relationship is in force and, once this purpose has been completed or the deletion of the data is requested by the interested party and, in its case, until completing the legal deadlines for compliance with obligations and attention to possible responsibilities.

11. Exercise of rights

The user has the right to request VBOTE access to their personal data, its rectification, deletion, limitation of treatment, opposition and portability.

You also have the right to withdraw the consent granted for the treatment at any time, without affecting the legality of the treatment based on the consent prior to its withdrawal.

To exercise any of these rights, you must send a letter to VBOTE INNOVATION SL, at the following postal address c/ De la Barrac, 41 bajo. 46011 Valencia, or email info@tweem.com, indicating the right you exercise and providing a copy of your DNI / NIF or valid document in Law to prove your identity.

12. Protection of user rights

In any case, the user is informed of the right that assists them to file a claim with the Spanish Data Protection Agency (AEPD), in particular, when the user considers that they have not obtained satisfaction from VBOTE in the exercise of their Rights.

The user can contact the AEPD through www.agpd.es or at the following address C / Jorge Juan, 6. 28001 - Madrid, and / or contact telephone number 912 663 517.

13. Other user rights regarding electronic commerce and electronic commercial communications

VBOTE informs the user that they have expressly authorised the sending of commercial advertising communications, bulletins, news and invitations to events by electronic means that, under articles 21 and 22 of the Law of Services of the Information Society and Commerce Electronic (LSSICE), the user has the right to oppose the processing of their data for promotional purposes for the receipt of commercial advertising and advertising communications, as well as the right to revoke at any time the consent given for this purpose with the simple notification of their will to VBOTE and / or by sending an email with the subject BAJA.

For this, the user may direct their communication requesting the cessation of sending commercial advertising communications by revocation of consent and / or opposition to the email address: info@tweem.com requesting it and / or indicating in the subject BELOW.

VBOTE will attend to your request, preserving the minimum essential data to adopt the necessary measures that prevent the sending of said commercial communications.

14. Information society service providers and other third parties

VBOTE warns the user that this entity is only responsible and guarantees the confidentiality, security and treatment of the data in accordance with this policy, regarding the personal data that it collects from the user through this website, not having any type of responsibility regarding the processing and subsequent use of personal data that may be made by third party service providers of the information society who may access such data by reason of the provision of their services or exercise of their activity.

Third-party providers of information society services shall be understood – without limitation – those natural or legal persons that provide the following services: (i) Transmission through a communication network of data provided by the recipients of the service. (ii) Access services to the aforementioned network. (iii) Data storage or hosting services. (iv) Provision of content or information.

VBOTE is not responsible for the data processing carried out by third parties that establish hyperlinks with VBOTE or for those carried out by those responsible (private companies and / or public administrations) mentioned on the site www.tweem.com and whose websites are accessible through the corresponding links that, where appropriate, are published on the website www.tweem.com

15. Follow us on social networks

Social networks are services provided by third-party providers that allow the user to participate in a virtual community with other users through which they can generate their own public profile where they can create and share content, information and personal data with other users of the network. In a social network you can create and share pages, accounts or profiles for personal and / or commercial purposes. The operation of the social network is regulated firstly, by the conditions established by the owner and / or network provider and secondly, when it comes to pages, accounts or profiles for commercial purposes, by the established terms and conditions.,by the person in charge of the profile or commercial account who, if applicable, will also be responsible for the processing of their data.

VBOTE has TWEEM profiles on some social networks which are linked and accessible to the user, through the corresponding icons and links published on the site. The user can follow us and become a fan of the official pages of VBOTE and TWEEM in the mentioned social networks.

The user is informed that the treatment of the data that is carried out through the pages, profiles or accounts of VBOTE and TWEEM in social networks will be governed by the corresponding policies and conditions of both the official page and the provider and owner of each social network, where appropriate, and said owner and provider of the social network is also responsible for the personal data file of the user that is processed on the official page.

16. Personal data published on the website

In relation to the personal data that may be published on the website www.tweem.com , the user is informed that said data is part of one or more data processing owned and held by the aforementioned entity in which they have been incorporated with the prior informed consent of the interested parties and cannot be freely processed and reproduced by the user or other third-party users -not even when reference is made to their origin – unless the prior authorisation and informed consent of the interested party is obtained.

The personal data that VBOTE may publish on its website www.tweem.comcould consist without limitation of any numerical, alphabetical, graphic, photographic, acoustic or any other type of information concerning identified or identifiable natural persons, such as the name, surname, photos, images of events held by the entity, data published by users of web services and other information.

Therefore, all personal data – including images, videos, texts, data and any other information that is published on our website www.tweem.com sobre personas físicas identificadas y/o identificables- sólo podrán ser utilizados por el usuario con el fin de participar y disfrutar de nuestro sitio web en la forma establecida en la presente política, o en su caso condiciones particulares que regulen un determinado servicio, con fines privados y en el marco de la legalidad vigente y sin ánimo de lucro ni fines comerciales de cualquier naturaleza, quedando expresamente prohibido cualesquiera otros usos distintos a los señalados, incluida la incorporación de las imágenes o los datos a ficheros o tratamientos y/o creación de bases de datos de personas y/o envío de publicidad o cesión a terceros, sin el previo consentimiento informado del usuario titular de las informaciones y datos, no siendo responsable VBOTE de los usos que el usuario u otros terceros usuarios de nuestro sitio web efectúen contraviniendo lo establecido en estas condiciones y otras que los regulen.

At no time should the user consider that the VBOTE website www.tweem.com is a source accessible to the public from which personal data, information and content published through it can be freely made available.

17. Security measures

VBOTE informs the user that, in accordance with the provisions of the data protection legislation and taking into account the state of the art, the application costs, and the nature, scope, context and purposes of the treatment, as well as risks of variable probability and severity for the rights and freedoms of the natural persons who present the data processing, has adopted the necessary technical and organisational measures to guarantee a level of security appropriate to the risk and avoid accidental destruction, loss or alteration or illegal data as well as the treatment, conservation, communication or unauthorized access to said data.

VBOTE will regularly verify, evaluate and audit the effectiveness of said measures, updating them if necessary according to the results of said evaluations.

Likewise, VBOTE guarantees the user compliance with the duty of professional secrecy regarding the personal data of users and the duty to keep them.

18. Use of cookies and data storage and retrieval devices on the user's terminal equipment

VBOTE uses cookies and data storage and retrieval devices on the user's terminal equipment when the user browses the site www.tweem.com .

Such cookies and data storage and retrieval devices are used by VBOTE under the conditions described in its Cookies Policy .

19. Recommendations to users

VBOTE recommends that users use the latest versions of computer programs for browsing the Internet given the incorporation of greater security measures in these.

Likewise, VBOTE recommends that users use the security mechanisms available to them (secure web servers, cryptography, digital signature, firewall, etc.) to protect the confidentiality and integrity of their data to the extent necessary, given that there are risks of impersonation or violation of communication.

VBOTE reminds users that the Internet is not secure. However, there are and are developed different means that allow you to improve the protection of your data. So use whatever means you can to protect your data and communications, such as legally available encryption for confidential email and access codes to your own PC.

VBOTE warns users that whenever they provide personal information over the Internet through email, newsgroups, discussion forums, etc., keep in mind that such information may be collected and processed for purposes not desired by users, therefore that VBOTE recommends that users enquire about the confidentiality and privacy policies of the online sites they visit.

VBOTE advises users to keep in mind that, unless they use encryption mechanisms, email on the Internet is not secure. Email messages and discussion boards can be subject to spoofing and impersonation, which should be taken into account whenever they are used. If you do not want to publish your email address, configure your browser so that it does not leave your email address on the web servers that you access.

20. Policy update

Without prejudice to the preferential application of the specific legal texts for this purpose, such as informative texts that are contained in the data collection forms published by VBOTE on the site www.tweem.com, as well as, where appropriate, in the conditions of particular services, VBOTE will periodically update this privacy policy and the treatment of personal data of the users of the website. Any modification of this policy will be published on the website www.tweem.com, taking into account each user that the processing of personal data that may be communicated to VBOTE will be governed by the rules established and in force at the time of said communication.

In any case, it will be the responsibility of the user to periodically access the VBOTE privacy policies published in order to know the latest version at all times.

21. Contact information

Without prejudice to the preferential application of the specific legal texts for this purpose, such as informative texts that are contained in the data collection forms published by VBOTE on the site www.tweem.com, as well as, where appropriate, in the conditions of particular services, VBOTE will periodically update this privacy policy and the treatment of personal data of the users of the website. Any modification of this policy will be published on the website www.tweem.com, taking into account each user that the processing of personal data that may be communicated to VBOTE will be governed by the rules established and in force at the time of said communication.

In any case, it will be the responsibility of the user to periodically access the VBOTE privacy policies published in order to know the latest version at all times.