WEBSITE PRIVACY POLICY

https://www.tribboo.co/

I. PRIVACY AND DATA PROTECTION POLICY

Respecting the provisions of current legislation, Tribboo Software SL (hereinafter also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

This privacy policy is adapted to the Spanish and European regulations in force regarding the protection of personal data on the Internet. Specifically, it respects the following rules:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
• Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, 2007, approving the Regulations for the development of Organic Law 15/1999, of December 13, 1999, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data

The person responsible for the processing of personal data collected in Tribboo Software SL is: TRIBBOO SOFTWARE SL, provided with NIF: B67844266 and registered in: Regsitro de valencia with the following registry data: ________, whose representative is: ________ (hereinafter, Data Controller). Its contact details are as follows:

Address:
Calle Ribera, 1 - BIS NO 1, Valencia, 46002, Valencia
Contact phone: 611319979
Contact email: info@tribboo.co

Data Protection Delegate (DPD)

The Data Protection Officer (DPD, or DPO) is responsible for ensuring compliance with the data protection regulations to which Tribboo Software SL is subject. The User can contact the DPD designated by the Data Controller using the following contact details: info@tribboo.co.

Personal Data Registry

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Tribboo Software SL through the forms provided on its pages will be incorporated and processed in our files in order to facilitate, expedite and fulfill the commitments established between Tribboo Software SL and the User or the maintenance of the relationship established in the forms that the User fills out, or to respond to a request or query from the User. Also, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided in Article 30.5 of the RGPD applies, a record of processing activities is maintained that specifies, according to their purposes, the processing activities carried out and other circumstances established in the RGPD.

Principles applicable to the processing of personal data

The processing of the User's personal data shall be subject to the following principles contained in Article 5 of the RGPD and in Article 4 and following of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Principle of lawfulness, fairness and transparency: the consent of the User will be required at all times after fully transparent information of the purposes for which personal data are collected.
• Purpose limitation principle: personal data will be collected for specified, explicit and legitimate purposes.
• Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and always up to date.
• Principle of limitation of the storage period: personal data will only be kept in such a way as to allow the identification of the User for the time necessary for the purposes of their processing.
• Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
• Principle of proactive responsibility: the Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by Tribboo Software SL are solely identification data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Tribboo Software SL undertakes to obtain the express and verifiable consent of the User for the processing of personal data for one or more specific purposes.

The User shall have the right to withdraw consent at any time. It shall be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent shall not condition the use of the Website.

In the occasions in which the User must or may provide his/her data through forms to make inquiries, request information or for reasons related to the content of the Website, he/she will be informed in case the completion of any of them is mandatory because they are essential for the proper development of the operation carried out.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 10 years, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed about the period for which the personal data will be kept or, when this is not possible, the criteria used to determine this period.

Recipients of personal data

The User's personal data will not be shared with third parties.

In any case, at the time the personal data is collected, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

Respecting the provisions of Articles 8 of the RGPD and 7 of the Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent to the processing of their personal data in a lawful manner by Tribboo Software SL. In the case of a minor under 14 years of age, the consent of parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

Tribboo Software SL undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

The Web Site has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted or encrypted.

However, because Tribboo Software SL cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to inform the User without undue delay when a breach of security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication of or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.

Rights deriving from the processing of personal data

The User has over Tribboo Software SL and may, therefore, exercise against the Data Controller the following rights recognized in the RGPD and in the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Right of access: This is the User's right to obtain confirmation of whether or not Tribboo Software SL is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Tribboo Software SL has carried out or will carry out, as well as, among others, the information available on the origin of such data and the recipients of the communications made or planned for them.
• Right of rectification: This is the User's right to have his or her personal data that proves to be inaccurate or, taking into account the purposes of the processing, incomplete, modified.
• Right of deletion ("the right to be forgotten"): This is the User's right, unless otherwise provided for by the legislation in force, to obtain the erasure of his or her personal data when such data are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his or her consent to the processing and the processing has no other lawful basis; the User objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Controller, taking into account the technology available and the cost of its implementation, shall take reasonable steps to inform controllers who are processing the personal data of the data subject's request for the deletion of any link to such personal data.
• Right to limitation of processing: This is the User's right to limit the processing of his/her personal data. The User has the right to obtain the limitation of processing when he/she contests the accuracy of his/her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.
• Right to data portability: In the event that the processing is carried out by automated means, the User shall have the right to receive from the Controller his or her personal data in a structured, commonly used and machine-readable format, and to transmit it to another controller. Whenever technically possible, the Controller shall transmit the data directly to such other controller.
• Right of opposition: This is the User's right not to have his or her personal data processed or to cease the processing of such data by Tribboo Software SL.
• Right not to be subject to a decision based solely on automated processing, including profiling: This is the User's right not to be subject to an individualized decision based solely on automated processing of his or her personal data, including profiling, unless otherwise provided for by applicable law.

Thus, the User may exercise his/her rights by means of a written communication addressed to the Data Controller with the reference "RGPD-https://www.tribboo.co/", specifying:

• Name, surname of the User and copy of the ID card. In cases where representation is admitted, it will also be necessary the identification by the same means of the person representing the User, as well as the document proving the representation. The photocopy of the DNI may be substituted by any other means valid in law that proves the identity.
• Request with the specific reasons for the request or information to be accessed.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that accredits the request you are making.

This application and any attachments may be sent to the following address and/or e-mail address:

Postal address:
Calle Ribera, 1 - BIS NO 1, Valencia, 46002, Valencia
E-mail: info@tribboo.co

Links to third party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Tribboo Software SL, and which are therefore not operated by Tribboo Software SL. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

In the event that the User considers that there is a problem or infringement of the regulations in force in the way in which his/her personal data is being processed, he/she shall have the right to effective judicial protection and to file a complaint before a supervisory authority, in particular, in the State in which he/she has his/her habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).

II. COOKIE POLICY

Access to this Web Site may involve the use of cookies. Cookies are small amounts of information that are stored in the browser used by each User -in the different devices that can be used to navigate- so that the server remembers certain information that later and only the server that implemented it will read. Cookies make browsing easier, more user-friendly, and do not damage the browsing device.

The information collected through cookies may include the date and time of visits to the Web Site, the pages visited, the time spent on the Web Site and the sites visited just before and just after the same. However, no cookie allows this cookie to contact the User's telephone number or any other means of personal contact. No cookie can extract information from the User's hard drive or steal personal information. The only way for the User's private information to be part of the Cookie file is for the User to personally give that information to the server.

Cookies that allow a person to be identified are considered personal data. Therefore, the Privacy Policy described above shall apply to them. In this sense, the use of cookies requires the consent of the User. This consent will be communicated, on the basis of a genuine choice, offered by means of an affirmative and positive decision, before the initial processing, removable and documented.

Own Cookies

Cookies are those that are sent to the User's computer or device and managed exclusively by Tribboo Software SL for the better functioning of the Website. The information collected is used to improve the quality of the Website and its Content and your experience as a User. These cookies allow us to recognize the User as a repeat visitor to the Website and adapt the content to offer content that suits your preferences.

Third party cookies

These cookies are used and managed by external entities that provide Tribboo Software SL with services requested by the latter to improve the Website and the user experience when browsing the Website. The main purposes for which third-party cookies are used are to obtain access statistics and analyze navigation information, i.e., how the User interacts with the Website.

The information obtained refers, for example, to the number of pages visited, the language, the place where the IP address from which the User accesses, the number of Users who access, the frequency and recurrence of visits, the time of visit, the browser used, the operator or type of device from which the visit is made. This information is used to improve the Web Site, and to detect new needs in order to offer the Users a Content and/or service of optimum quality. In any case, the information is collected anonymously and Web Site trend reports are prepared without identifying individual users.

You can obtain more information about cookies, privacy information, or consult the description of the type of cookies used, their main characteristics, expiration period, etc. at the following link(s):

________

The entity(ies) in charge of providing cookies may transfer this information to third parties, if required by law or if a third party processes this information for such entities.

Disabling, rejecting and deleting cookies

The User can disable, reject and delete cookies - in whole or in part - installed on their device by configuring their browser (among which are, for example, Chrome, Firefox, Safari, Explorer). In this regard, the procedures for rejecting and deleting cookies may differ from one Internet browser to another. Consequently, the User must follow the instructions provided by the Internet browser that he/she is using. In the event that you reject the use of cookies - in whole or in part - you may continue to use the Web Site, although you may be limited in the use of some of its features.

III. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy and Cookies Policy, as well as to accept the processing of personal data so that the Data Controller can proceed in the manner, during the periods and for the purposes indicated. The use of the Website implies acceptance of the Privacy and Cookies Policy of the same.

Tribboo Software SL reserves the right to modify its Privacy and Cookies Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy and Cookies Policy will be explicitly notified to the User.

This Privacy and Cookies Policy was updated on August 24, 2022 to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and to Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights.

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