Spathios

June 2020 version

From Spathios we want to offer the User a safe and reliable browsing experience and service. For this reason, we have implemented this privacy policy that complies with the security measures required by Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, and by the European Data Protection Regulation 679/2016, of April 27, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data, all with the aim of guaranteeing their privacy and be transparent with the use of your data.

As already stated in the Legal Notice, who is behind this Platform is:

SPAIN
SPATHIOSLINK 14, SL
VAT/NIF: ESB67599241
Address: Carrer del Doctor Francesc Darder 8-10, Escalera A, 3º 2ª, 08034, Barcelona, Spain
Contact email: info@spathios.com
Telephone contact: +34 633 013 509

UNITED KINGDOM
SPATHIOSLINK 14 LTD
VAT: TBD
Address: 20-22 Wenlock Road, London, England, N1 7GU
Contact email: info@spathios.com
Telephone contact: +34 633 013 509

For anything you need as a User in relation to this privacy policy, you can contact us at the email indicated above or at our physical address.

1. IN WHICH SECTIONS OF OUR PLATFORM DO WE COLLECT YOUR PERSONAL DATA?

a). – Through our corporate email

Through our email address: info@spathios.com You may write to us and/or request the information you deem necessary to clarify any doubts related to our services or the operation of our website or data protection policy, as well as request assistance.

b). – Through the registration form

In the registration form you must fill in the fields that are requested, depending on whether you are going to operate on the Platform as a host User, for which you will provide your name, or that of your company, NIF, DNI of the person in charge, address, telephone number of contact, bank account number and Social Security number, email address and contact phone number; or as a guest User, providing your name, email address, contact telephone number and bank details.

c). - Throught social media

We may collect your data through your user profile on the social networks that we use from Spathios, which are detailed in section 10 of this policy.

2. WHAT IS THE OBJECTIVE AND/OR PURPOSE OF DATA COLLECTION?

The purpose of data collection in all the sections mentioned in the previous point is:

Maintain direct and personalized contact with our Users. In this way, we will use your data to answer questions or information that you have requested, manage your requests and guarantee an experience that respects the highest standards.
We may also use your data for advertising and commercial prospecting purposes, if you expressly consent at the indicated time and by virtue of what is reported in the previous paragraph.
The email from which you write to our corporate mail, we use it to send you information related to the doubts or concerns that you have raised, advice or sending purchase invoices, as appropriate.

In no case will you receive information from third parties without previously informing you and requesting your consent, thus ensuring that you comply with the parameters of Spanish law and European regulations.

We will send you information about our company, its actions, events, collaborations with third parties, commercial actions and/or any other initiative related to Spathios depending on the type of consent that, in any case, you grant us.

3. USE OF PERSONAL DATA AND COMMERCIAL PURPOSES

Spathios informs its Users that the personal data they provide us will be processed for the purposes set out in point 1 and that they will be, in detail, the following:

Address and resolve the requests or doubts required from the Users;
Report news that we may contain on the Web;
Provision and billing of services;
Send information that is considered to be of interest to the User;
Notification of the promotional agreements that Spathios has signed with companies, professionals or collaborators, to offer the Users of the platform certain functionalities that are different or additional to those that they have contracted or accepted;
Allow access to options that require registration;
Send commercial communications, carry out promotional actions or inform you regarding your data of the following: (i) your data will not be used for other purposes than to carry out the treatment for which you expressly consented at the time or for what is established in this policy by us; (ii) all this information is stored on a separate secure server.

Warn you that the information you provide through the Website may reveal or allow others to infer your nationality, ethnicity, gender, age or other aspects of your private life. In this way, by providing this information completely voluntarily through any means of our Platform, the User is expressly and voluntarily accepting this Privacy and Personal Data Protection Policy.

4. SHARING INFORMATION WITH THIRD PARTIES

As has already been established in the previous points, Spathios will not provide User data to third parties, understood as third parties that have no direct relationship with the User or that do not carry out a function on behalf of or commissioned by the service provider or responsible for the treatment, that is, of Spathios. For example, the company Stripe, for the processing and management of Platform payments.

If you would like to do so, you will be informed in advance and your consent will be requested.

5. LEGAL BASIS: EXPRESS CONSENT FOR THE PROCESSING OF YOUR DATA

5.1 Consent of natural persons

In compliance with the requirements of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, and the European Data Protection Regulation 679/2016 and in accordance with the provisions of our internal policies , each time you send us personal data you must give your express consent by doing click In the box that appears at the bottom of each form where your data is collected, or when you write to our contact email or any other enabled for specific features of the Platform, you will be expressly accepting that we can collect your data for the purpose or request that you have indicated to us. With said action(s), you are freely and unequivocally stating that you agree to Spathios treating your data for the purposes mentioned in the previous sections.

The User guarantees that the personal data provided to Spathios is true and is responsible for informing the User of any changes to them.

The User's acceptance that their data be processed for the purposes referred to in this established policy is always revocable, without retroactive effect, in accordance with the provisions of current legislation; therefore, you have the right to withdraw your consent at any time, without affecting the legality of the treatment based on your prior consent, through the means provided in section 6 of this legal text.

5.2 Consent of legal or professional persons

We inform you that, if you act on behalf of a legal entity or as an independent professional, you will authorize us to send you information associated with the contracted services, on the one hand, or commercial information, at the appropriate times through the acceptance of this privacy policy. Thus, when you request any information related to Spathios through the channels established through the Platform, your information may also be processed for commercial purposes and the sending of electronic communications when you have authorized us through the enabled options.

Likewise, the User's acceptance that their data be processed for the purposes referred to in this established policy is always revocable, without retroactive effect, in accordance with the provisions of current legislation; therefore, you have the right to withdraw your consent at any time, without affecting the legality of the treatment based on your prior consent, through the means provided in section 6 of this legal text.

6. ABOUT YOUR RIGHTS OF ACCESS, RECTIFICATION, DELETION, OPPOSITION, PORTABILITY, FORGETTING AND LIMITATION IN TREATMENT

Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights and the European Data Protection Regulation 679/2016 have implemented a series of legal guarantees that allow the user to exercise rights and actions related with the processing of your data.

Spathios offers you this legal guarantee, with which, at any time and/or when you deem it convenient, you can make use of your rights of Access, Rectification, Deletion, Opposition, Portability, Forgetting and Limitation in the treatment by writing to the email of contact that we have enabled for it: info@spathios.com, or by sending us a request by physical mail to Carrer del Doctor Francesc Darder 8-10, Escalera A, 3º 2ª, 08034, Barcelona, Spain.

, enclosing, in both cases, a copy of the passport or your DNI (data holder) and expressly indicating in the subject the request you wish to make: access, rectification, deletion, opposition, portability, forgetfulness or limitation in the treatment .

It is important that as a User you take into account that the information you have shared with Users by any means may continue to be visible and that Spathios is exempt from any responsibility in relation to the elimination of this information.

In the same way, Spathios does not control the renewal system of third-party search mechanisms, and said mechanisms may contain certain information from the public profile that has already been canceled but is still on the Internet due to its redistribution, in which case , we recommend that you contact those responsible for those platforms to request their cancellation or the exercise of a right to be forgotten.

We briefly explain what each of the rights that you can exercise consists of:

Access	Through the exercise of this right you can know what personal data of yours is being processed by us; its purpose, origin or possible transfer to third parties.
Rectification	It consists in that you can modify your personal data that is inaccurate or incomplete, specifying in the request what data you want to be modified.
Suppression	Allows the cancellation of your personal data for inadequate or excessive.
Opposition	With the right of opposition, you can oppose the processing of your data in cases such as: advertising and commercial prospecting activities or when said processing is intended to make a decision regarding you based solely on an automated processing of your data. personal information.
Portability	You will be able to receive your personal data provided in a structured format, of common use and mechanical reading, and be able to transmit them to another person in charge, whenever it is technically possible.
Forgot	You may request the deletion of personal data without due delay when any of the cases contemplated occurs. For example, illicit data processing, or when the purpose that motivated the processing or collection has disappeared.
Limitation in treatment	In general, in cases where it is not clear whether personal data should be erased, you can exercise your right to limit processing. This right exists in the following cases: (i) when the accuracy of the data in question is in doubt; (ii) when as a User you do not want the data to be deleted, (iii) when the data is no longer necessary for the original purpose, but cannot be deleted for legal reasons, (iv) when the decision of your objection to the treatment is slope. The limitation means that your personal data can only (except for conservation) be processed with your consent for the formulation, exercise or defense of claims, with a view to protecting the rights of another natural or legal person or for reasons of interest public of the EU or of a certain EU Member State. As a User you must be informed before the lifting of said limitation.

Likewise, as a User you have the right to file a claim with the competent Control Authority if you consider that the processing of personal data that concerns you violates the provisions of data protection legislation and regulations; all this without prejudice to any other administrative resource or judicial action.

Also, you are informed that the purpose of data processing will not be to make decisions about your information based solely on automated processing -automated decisions-, including profiling, that is, it does not include automated profiling - and without human intervention - of your personal data to evaluate personal aspects related to your person, such as analyzing or predicting aspects related to economic situations, health, personal preferences or interests, reliability or behavior, the situation of the interested party, all in to the extent that it has legal consequences for you or significantly affects you as a result. In any case, it would only apply when a law requires it and you would have said treatment will be subject to the appropriate guarantees, including specific information to your person, as an interested party and the right to obtain human intervention, in your case; also to express their point of view, to receive an explanation of the decision made after such evaluation and to challenge the decision, when appropriate.

7. AGE OF MAJORITY

To be a User of our Platform, you must be of legal age, so you must be over 18 years of age.

8. SECURITY MEASURES IN DATA COLLECTION

To guarantee security on our Website, we have integrated a security system that allows us to maintain the confidentiality and integrity of the data of our Users that have been sent or collected through the means mentioned in the first point.

In this way, Spathios maintains the data protection security levels required by Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights and the European Data Protection Regulation 679/ 2016, of April 27, and has arranged all the technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of the data that the User provides through the Web.

Also, as a User of our Website, you understand, accept and understand that security measures on the Internet are not impregnable and that, therefore, you are obliged to adopt the necessary security measures that allow you to trust the veracity of the page. website where you are entering your data. We will also do our best to guarantee the privacy and security of your personal data at all times, always using the utmost diligence and implementing the necessary measures.

Thus, we inform you that you will be solely responsible for the security measures that you implement in relation to the protection of your data, with which, Spathios is not responsible for situations where the User has not implemented the corresponding security measures; nor of its consequences, as well as for causes or damages caused by third parties unrelated to the business, including fortuitous events and/or force majeure.

In accordance with the foregoing, Spathios cannot guarantee that unauthorized third parties may have knowledge of the class, conditions, characteristics and circumstances of the use that Users make of the services offered on the Platform. However, as a measure, some conditions of use have been provided in our Legal Notice and Contract Conditions

9. PERIOD OF CONSERVATION OF YOUR PERSONAL DATA

The personal data provided will be kept for the time necessary to fulfill the purpose for which they are collected and to determine the possible responsibilities that may arise from the purpose, in addition to the periods derived from the applicable legislation.

10. SOCIAL MEDIA POLICY

Spathios has a corporate profile on Facebook, Instagram and Youtube. Thus, under the European Data Protection Regulation 679/2016 and the Organic Law 3/2018 on the Protection of Personal Data, Spathios is “Responsible for the treatment of your data” due to the existence of said profiles on Social Networks and the fact that you follow us and we can follow you.

The foregoing means that if you decide to join our corporate profile as a follower or by giving a "Like" or a "Like" to our content or profile, you accept this policy, where we explain your rights and how we use your data.

As the person responsible for the processing of your data, we guarantee confidentiality in the processing and compliance with your rights, always under the effects of the aforementioned legislation and regulations.

On the other hand, we inform you that we will use these social networks to announce news or relevant information related to our business and the services we offer, or on topics that we consider to be of interest to you. Using the functionalities of said platforms, it is possible that you receive news with this type of information on your wall or in your profile.

However, we also let you know that there is no link between Spathios and said platforms or social networks, so you will accept their use policy and conditions once you access them and/or validate their notices, terms and conditions in the procedure. of registration, Spathios not being responsible for the use or treatment of your data that is made outside the strict relationship and provision of services indicated in this policy.

11. COOKIES

Spathios uses third-party cookies to monitor and improve certain features and services. If you want to see what our policy is in this regard, click here.

12. MODIFICATION OF THIS PRIVACY POLICY

Spathios reserves the right to modify this policy to adapt it to future legislative or jurisprudential developments, as well as to future uses that it plans to make of the personal data of the Users of the Website. In the event that said modification affects you in relation to the processing of your data, for example, because some additional treatment is going to be carried out, not previously informed, we will proceed to notify you of it.

In any case, the User is recommended to proceed to read the Personal Data Protection Policy of the Website each time they access it.

13. INTEGRATION WITH THE REST OF THE LEGAL TEXTS

This privacy policy is supplemented by the Legal Notice, the Cookie Policy and the Contract Conditions associated with this Website.