Below we describe how your personal data is processed and your rights in this regard in accordance with the current data protection legislation – Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016, regarding the protection of natural persons with regard to the processing of personal data, and subsequent regulations, hereafter “data protection regulations” or “GDPR”.

DATA CONTROLLER AND CONTACT DATA

The data controller is SARUBU LABS, S.L. – with commercial name, Sarubu – with registered address at (28814) Daganzo de Arriba, Madrid, calle Gitanilla, 9. If required, you can contact us by email at the following address: [email protected]

For what purpose(s) will we process your data, and on what legal basis?

In accordance with GDPR provisions, your personal data will be processed on a legal basis and for the purposes described below:

1. Consent of the interested party

Your personal data will only be processed if you have granted us your consent, and for the following purposes:

To respond to and follow up queries/requests you submit via contact channels. We understand that, upon completing contact forms and providing the necessary data, the interested party provides their consent for their data to be processed for this purpose. To communicate free of charge for commercial and information purposes, both through electronic and non-electronic means. To evaluate your activity history, browsing pattern analysis and use of digital channels using information captured by cookies. You may withdraw this consent at any time. Please note that this will not affect the validity of any processing performed prior to withdrawal of consent.

2. Justified by legitimate interest

When necessary, SARUBU LABS, S.L. will process your personal data for its own legitimate interests, so long as your fundamental interests, rights and freedoms do not take precedence over the legitimate interests of SARUBU LABS, S.L. Your data will be processed in order to analyse your needs, including segmentation, in order to identify potential campaigns that could be of interest to you.

3. To comply with a legal obligation applicable to the data controller

SARUBU LABS, S.L. will process your data in order to obtain, store and manage the consent received with regard to protection of the data supplied, to demonstrate that consent is in accordance with the data protection regulations. If you do not grant permission for your personal data to be processed for this purpose and as the processing of this data is necessary to comply with the legal obligations to which SARUBU LABS, S.L. is subject, it will not be possible to provide the services you request.

AUTOMATED INDIVIDUAL DECISION-MAKING AND PROFILING

We do not use fully automated decision-making processes, in accordance with the provisions of article 22 of the GDPR. If we use this procedure on an occasional basis, you will be informed of this and will have the right to require human intervention in the decision-making process. Your data may also be processed to evaluate different aspects (profiling) in order to inform and advise you about your services based on your preferences.

WHO WILL THE DATA BE SENT TO?

For the purposes described above, SARUBU LABS, S.L. works with third-party service suppliers, who may have access to the personal data when undertaking the agreed services. SARUBU LABS, S.L. follows strict criteria when selecting third parties in order to ensure their compliance with data protection obligations, and signs the corresponding data protection agreement with them, in which these third parties undertake to comply with their data protection obligations and, in particular, to comply with legal, technical and organizational measures, when processing personal data for the agreed purposes, and prohibits the processing of this personal data for other purposes or its transfer to third parties.

HOW LONG DO WE HOLD YOUR DATA FOR?

SARUBU LABS, S.L. will comply with the provisions of the applicable legislation with respect to the duty to delete personal information once the purpose has been achieved or when the subject withdraws their consent for data processing, and the data will be available exclusively to the Courts and Judges, the Legal Ministry or the competent Public Administrations in order to attend to potential liabilities arising from processing, and only during the term for which such liabilities pertain. Upon expiry of such periods, this data will be irreversibly destroyed using secure methods.

HOW HAVE WE OBTAINED YOUR DATA?

The personal data that SARUBU LABS, S.L. processes consists of personal dated collected via the different contact channels available and directly supplied by the subjects.

WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE YOUR DATA?

In accordance with the provisions of the General Data Protection Regulation and domestic data protection legislation, you have the right to access, rectification and deletion of data, to request the restriction of processing of your personal data, to oppose such processing, to request data portability, and not to be subject to individual automated decision-making. In addition, where processing of the personal data is based on consent granted by you, you may revoke this consent at any time. Please note that this will not affect the validity of any processing performed prior to withdrawal of consent. You may exercise the rights described above through the following channels, supplying the necessary documentation so that we may verify your identity (copy of National Identity Document, passport, Foreign Citizen’s Identification Number, etc.) by email to the following address: [email protected].