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This Application collects some Personal Data of its Users.


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53, Portuetxe, 20218, San sebastian, Gipuzkoa, Spain

Contact email of the Holder:

Kinds of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: email address; business name; Usage data; Tracker.

Complete information regarding each category of Personal Data that is collected is provided in the sections of this privacy policy dedicated to that purpose or through specific explanatory texts that are displayed before the collection of said Data.
Personal Data may be freely provided by the User or, in the case of Usage Data, will be collected automatically when using this Application.
All the Data requested by this Application are mandatory and the refusal to provide them may make it impossible for this Application to proceed with the provision of the Service. In cases where this Application specifically indicates that certain Data is not mandatory, Users are free not to communicate such Data without this having any consequence on the availability or operation of the Service. Users who have doubts about what Data is mandatory can contact the Owner.
The use of Cookies - or other tracking tools - by this Application or by the owners of third-party services used by this Application is intended to provide the Service requested by the User, in addition to any other purposes described in this document and in the Cookies Policy, if available. 

The User assumes responsibility for the Personal Data of third parties that is obtained, published or shared through this Application and hereby declares that he has the consent of said third parties to provide said Data to the Owner.

Method and place of processing of the Data collected

Treatment Modalities

The Holder will treat the Data of the Users in an appropriate manner and will adopt the appropriate security measures to prevent unauthorized access, disclosure, alteration or destruction of the Data.
Data processing will be carried out using computers and/or IT tools, following organizational procedures and modalities strictly related to the stated purposes. In addition to the Owner, in some cases the Data may be accessed by certain categories of authorized persons, related to the operation of this Application (administration, sales, marketing, legal department and system administration) or external contractors who provide services to the Owner (such as such as external providers of technical services, courier companies, hosting companies, IT companies, communication agencies) that will be appointed by the Owner as Treatment Managers, if necessary. An updated list of said persons may be requested from the Holder at any time.

Legal basis of the Treatment

The Owner may process the User's Personal Data, if one of the following conditions is met:

  • When Users have given their consent for one or more specific purposes. Notice: Under several different laws, the Owner may be authorized to process Personal Data until the User objects to it ("opt-out"), without the need for consent or any other legal basis. However, this will not apply when the processing of Personal Data is subject to European regulations on the protection of Personal Data;

  • When obtaining Data is necessary for the fulfillment of a contract between the User and/or any other pre-contractual obligation thereof;

  • When the treatment is necessary for the fulfillment of a legal obligation that must be fulfilled by the User;

  • When the treatment is related to a task carried out in the public interest or in the exercise of official powers granted to the Holder;

  • When the treatment is necessary for the purpose of a legitimate interest pursued by the Owner or a third party.

In any case, the Holder is at your disposal to define the specific legal bases that apply to the treatment and in particular, if the collection of Personal Data is a contractual or statutory requirement or a necessary requirement to formalize a contract.


The Data is processed in the offices of the Holder, as well as in any other place where the parties involved in said treatment process are located.
Depending on Users' location, Data transfers may involve the transfer of Users' Data to a country other than your own. For more information on the place of processing of such transferred Data, Users may refer to the section containing the details on the processing of Personal Data.

Users will also have the right to know the legal bases of Data transfers to another country outside the European Union or to any international organization that is governed by International Public Law or that is made up of two or more countries, such as the UN, and also know the security measures taken by the Owner to safeguard their Data.

In the event that such transfer of Data takes place, Users may obtain more information by consulting the relevant sections of this document or requesting it from the Owner, through the contact information that appears in the contact section.

Storage period

Personal Data will be processed and kept for the time necessary and for the purpose for which they were collected.


  • The Personal Data collected for the formalization of a contract between the Holder and the User must be kept as such until said contract has been fully formalized.

  • The Personal Data collected in the legitimate interest of the Owner must be kept for the time necessary to fulfill said purpose. Users can find specific information related to the legitimate interest of the Owner by consulting the relevant sections of this document or by contacting the Owner. 

The Holder may keep the Personal Data for an additional period when the User gives his consent to such treatment, provided that said consent remains in force. In addition, the Holder will be obliged to keep Personal Data for an additional period whenever it is required to comply with a legal obligation or by order from the authority.

Once the retention period has ended, the Personal Data must be deleted. Therefore, the rights of access, modification, rectification and portability of data may not be exercised once said period has expired.

Purpose of the Treatment of the Data collected

The Data relating to the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as for the following purposes: Management of activity related to productivity, Platform and hosting services, Infrastructure monitoring and Advertising.

Users can find specific information on the Personal Data used for each purpose in the section “Detailed Information on the Processing of Personal Data”.

Detailed information on the Treatment of Personal Data

Personal Data is collected for the following purposes and using the following services:

Management of activity related to productivity 

This type of service helps the Holder to manage tasks, collaborations and, in general, activities related to productivity. When using this type of service, User Data will be processed and may be stored, depending on the purpose of the activity in question.
These services may be integrated with a wide range of third party services declared in this Privacy Policy in order to allow the Owner to import or export the Data necessary for the corresponding activity.

Google Workspace (Google Ireland Limited)

Google Workspace is an integrated set of cloud-based storage, collaboration and productivity services provided by Google Ireland Limited. Google does not scan Gmail or other G Suite services for advertising purposes. In addition, Google does not collect or use data within these services for advertising purposes in any other way.

Processed Personal Data: email address; business name.

Place of treatment: Ireland –  Privacy Policy .

Infrastructure monitoring 

This type of service allows this Application to monitor the use and behavior of its components, to allow the improvement of its performance and functionality, its maintenance or the resolution of problems.
The Personal Data processed will depend on the characteristics and methods of implementation of these services, which by their very nature filter the activity of this Application.

Sentry (Functional Software, Inc.)

Sentry is an application monitoring service provided by Functional Software, Inc. .

Processed Personal Data: different types of Data, as specified in the service's Privacy Policy.

Place of treatment: USA –  Privacy Policy .


This type of service allows the use of User Data for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on the interests of Users. 
This does not mean that all Personal Data is used for this purpose. The information and conditions of use are detailed later.
Some of the services indicated below may use Trackers to identify Users or may use the behavioral retargeting technique, that is, display personalized advertisements based on the interests and behavior of the User, including those that have been obtained outside of this Application. For more information, please check the privacy policies of the corresponding services.
In addition to the opt-out features provided by any of the services listed below, Users may opt out by visiting the  Network Advertising Initiative opt-out page .

Users may also opt out of certain advertising features through the corresponding device settings, such as mobile device advertising settings or general advertising settings.

Jetpack (Jetpack Digital LLC)

Jetpack is an advertising service provided by Jetpack Digital LLC.

Processed Personal Data: Usage data; Tracker.

Place of treatment: USA –  Privacy Policy  –  Opt out .

Reach (Reach International)

Reach is an advertising service provided by Reach International.

Processed Personal Data: Usage data; Tracker.

Place of treatment: United Arab Emirates –  Privacy Policy .

Platform and hosting services

These services are intended to host and run the key components of this Application, thereby enabling the delivery of this Application from a unified platform. These platforms provide the Owner with a wide range of tools (eg statistics, user registration, feedback, database management, e-commerce, payment processing) involving the collection and processing of Personal Data. 
Some of these services operate through geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.

Wix (, Ltd.)

Wix is a platform offered by, Ltd. that allows the Owner to design, run and host this Application.
Wix is highly customizable and can host various websites, from simple blogs to complex eCommerce platforms.

Processed Personal Data: Usage data; Email address.

Place of treatment: Israel –  Privacy Policy .

The rights of the Users

Users may exercise certain rights regarding the processing of Data by the Owner.

Especially, Users have the right to do the following:

  • Withdraw your consent at any time. Users have the right to withdraw their consent when they have previously granted it for the processing of their Personal Data.

  • Objection to the processing of your Data. Users have the right to object to the processing of their Data if such processing is carried out on a legal basis other than consent. For more information, you can refer to the corresponding section below.

  • Access to your Data. Users have the right to know if their Data will be processed by the Owner, to obtain information on certain aspects of the treatment, in addition to obtaining a copy of the Data subject to treatment.

  • Verify and request modification. Users have the right to verify the accuracy of their Data and request that they be updated or corrected.

  • Restrict the processing of your Data. Users have the right, in certain cases, to restrict the processing of their Data. In this case, the Owner will process your Data for the sole purpose of storing them.

  • Erase or remove Personal Data. Users have the right, in certain cases, to obtain the elimination of their Data by the Owner.

  • Receive your Data and transfer it to another person in charge. Users have the right to receive their Data in a standard, structured, mechanically readable format and, if technically possible, to have it transferred to another person in charge without any impediment. This provision will be applicable provided that the Data has been processed through automated means and that the processing is based on the User's consent, on a contract to which the User is a party or that appears in the pre-contractual obligations thereof.

  • Make a complaint. Users have the right to file a claim with the competent authority for the protection of personal data.

Details on the right to object to treatment

When the processing of Personal Data is of public interest, in the exercise of official powers granted to the Holder or due to a legitimate interest of the Holder, Users may oppose said treatment explaining a reason in relation to their particular situation to justify their objection.

Users should know that, however, if their Personal Data is processed for commercial purposes, they may object at any time to such processing without the need for justification. In order to know if the Personal Data of the Users is being processed by the Holder for commercial purposes, they should consult the relevant sections of this document.

How to exercise these rights

Any request to exercise the rights of the User can be addressed to the Owner through the contact information provided in this document. These requests will be processed by the Holder free of charge as soon as possible and always within a period of one month.

Cookies policy

This Application uses Trackers. For more information, the User can consult the  Cookie Policy .

Additional information on the collection of Data and its treatment

Legal defense

The User's Personal Data may be used for the legal defense of the Holder before a court or in the judicial phases prior to a possible lawsuit arising from the inappropriate use of this Application or the related Services.
The User declares to know that the Holder may be required by public authorities in order to reveal Personal Data.

Additional information about the User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services or the collection and processing of Personal Data.

System log and maintenance

For reasons related to operation and maintenance, this Application and any other service, provided by third parties, that is used, may collect a system log; that is, files that record the interaction with this Application and that may contain Personal Data, such as the User's IP address.

Information not contained in this privacy policy

Additional information on the collection and processing of Personal Data may be requested from the Owner at any time. Contact information is indicated at the beginning of this document.

How “Do Not Track” requests are processed

This Application does not allow “Do Not Track” requests.
To determine whether any of the third-party services you use accept "Do Not Track" requests, please review their privacy policies.

Modification of this privacy policy

The Owner reserves the right to modify this privacy policy at any time, notifying Users through this page and, if possible, through this Application and/or, if technically and legally possible, notifying Users directly. , in case the Holder has the necessary contact information for this purpose. It is strongly recommended that you check this page frequently, referring to the date of the last update indicated at the bottom of the page.

In the event that the changes affect the treatment activities carried out based on the User's consent, the Owner must obtain, if necessary, the User's new consent.

Definitions and legal references

Personal Data (or Data)

Personal data is any information that, directly, indirectly or in relation to other information – including a personal identification number – allows the identification of a natural person.

Usage Data

The information collected automatically by this Application (or by third-party services used by this Application), may include: the IP addresses or domain names of the computers used by the User who connects to this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method used to make the request to the server, the dimensions of the file obtained in response, the numerical code indicating the status of the response from the server (successful result, error, etc.), the country of origin, the characteristics of the browser and the operating system used by the visitor, the various time coordinates of the visit (for example, the time spent on each of the pages) and the details relating to the itinerary followed within the Application , with special reference to the sequence of pages consulted, to the parameters related to the operating system and the User's computer environment either.


The individual using this Application, who, unless otherwise stated, shall be the Data Subject.

Data Owner

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public administration, agency or any other institution, which processes Personal Data on behalf of the Data Controller, described in this privacy policy.

Responsible for the Treatment (or Holder)

The natural or legal person, public administration, agency or any other institution, acting alone or jointly with others, determines the purposes and measures of the processing of Personal Data, including the security measures related to the operation and use of this Application. Unless otherwise specified, the Data Controller is the Owner of this Application.

This Application

The means through which the User's Personal Data has been collected and processed.


The service provided by this Application, as described in the definitions and legal references (if available) and on this page or application.

European Union (or EU)

Unless otherwise stated, all references to the European Union in this document include all current Member States of the European Union and the European Economic Area.


Cookies are Trackers that consist of small amounts of data stored in the User's browser.


Tracker means any technology - eg Cookies, unique identifiers, web beacons, embedded scripts, entity tags and fingerprinting - that enables Users to be tracked, for example by accessing or storing information on the User's device.

Legal information

This privacy policy has been drafted based on the provisions of multiple legislations, including Arts. 13 and 14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy applies only to this Application, unless otherwise stated herein.

Last revision: March 12, 2021

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