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Privacy Policy

At TheWhiteBoxCompany S.R.L., we aim to provide Users with a safe and reliable browsing experience. Therefore, we have implemented this privacy policy, which 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, as well as the European General Data Protection Regulation 679/2016, of April 27, regarding the protection of individuals with regard to the processing of personal data and the free movement of such data. Our goal is to ensure your privacy and to be transparent about the use of your data.

As stated in the Legal Notice, the entity behind this Website is:

TheWhiteBoxCompany S.R.L.

Tax ID (CIF): B70713003

Address: Calle Azofra 2, 5º 3ª, 28050 Madrid

Contact Email: [email protected]

For any inquiries regarding this privacy policy, Users can contact TheWhiteBoxCompany S.R.L. at the email address provided above or at the physical address

1. IN WHICH SECTIONS OF THE WEBSITE ARE PERSONAL DATA COLLECTED

Through the contact form:

In the contact form, in the «Contact» section, the User must fill in the fields provided, which require the name and contact email address.

Through the registration form:

In this form, the User must provide the following data for their effective registration on the platform: name, last name, phone number, and email address.

Through social media:

TheWhiteBoxCompany S.R.L. may collect data through the User’s profile on social media platforms used by TheWhiteBoxCompany S.R.L., which are detailed in section 10 of this policy.

Through corporate email:

Through corporate email addresses: [email protected], Users can write and/or request information they consider necessary to clarify doubts related to the services offered or the operation of the Website or data protection policy.

2. PURPOSE AND/OR PURPOSE OF DATA COLLECTION

The purpose of data collection in all the sections mentioned in the previous point is to maintain direct and personalized contact with Users. Therefore, their data will be used to address any inquiries or information they have requested, manage their requests, and ensure an experience that respects the highest standards.

The email from which the User writes to the corporate email addresses of TheWhiteBoxCompany S.R.L. will be used to send information related to the questions or concerns raised.

Under no circumstances will the User receive information from third parties without having been informed and obtained their express consent beforehand, thus ensuring compliance with European regulations. Moreover, no international transfer will be made involving their personal data.

Their data may also be used for advertising and commercial prospecting purposes if the User expressly consents at the indicated time.

3. USE OF PERSONAL DATA AND COMMERCIAL PURPOSES

TheWhiteBoxCompany S.R.L. informs its Users that the personal data they provide will be processed for the purposes outlined in point 1, which are detailed as follows:

  1. Addressing and resolving Users’ requests or inquiries.
  2. Informing Users about updates contained in TheWhiteBoxCompany S.R.L. Website.
  3. Sending information considered to be of interest to the User.
  4. Notification of promotional agreements that TheWhiteBoxCompany S.R.L. has entered into with companies, professionals, and/or collaborating associations to offer Users certain functionalities in addition to those they have already acquired.
  5. Allowing access to options that require registration.
  6. Sending commercial communications, carrying out promotional actions or campaigns, identified as direct marketing actions.

Users are informed regarding their data of the following: (i) their data will not be used for purposes other than those for which they expressly consented at the time or as established in this policy; (ii) all this information is stored on an independent secure server.

Users are also warned that the information they provide through the platform may reveal or allow others to deduce their nationality, ethnicity, gender, age, or other aspects of their private life. By providing this information voluntarily through any means of the Platform, Users are expressly and voluntarily accepting this Privacy and Personal Data Protection Policy.

4. SHARING INFORMATION WITH THIRD PARTIES

As already established in the previous points, TheWhiteBoxCompany S.R.L. will not provide Users’ data to third parties. In the event that it wishes to do so, Users will be informed in advance, and their 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 General Data Protection Regulation 679/2016, and in accordance with the internal policies of the company, each time Users submit personal data, they must give their express consent by clicking on the checkbox at the bottom of each form where their data is collected, or when they write to contact emails or any other enabled for specific functionalities of the Platform, they are expressly accepting that their data may be collected for the purpose or request they have indicated. With such action(s), they are freely and unequivocally expressing their agreement that TheWhiteBoxCompany S.R.L. may process their data according to the purposes mentioned in the previous sections.

Users guarantee that the personal data provided to TheWhiteBoxCompany S.R.L. are truthful and are responsible for communicating any changes to them.

The Users’ acceptance that their data may be processed for the purposes referred to in this policy is always revocable, without retroactive effects, in accordance with current legislation; therefore, they have the right to withdraw their consent at any time, without affecting the lawfulness of the processing based on their prior consent, through the means provided in section 6 of this legal text.

5.2. Consent of legal entities or professionals for the processing of their data

It is informed that if Users act on behalf of a legal entity or as an independent professional, they authorize the receipt of information associated with the contracted services, on one hand, or commercial information, at the appropriate times through the acceptance of this privacy policy, on the other hand. Thus, when they request any information related to TheWhiteBoxCompany S.R.L. through the channels established via the Website, their information may also be processed for commercial purposes and the sending of electronic communications when authorized through the enabled options.

Likewise, the Users’ acceptance that their data may be processed for the purposes referred to in this policy is always revocable, without retroactive effects, in accordance with current legislation; therefore, they have the right to withdraw their consent at any time, without affecting the lawfulness of the processing based on their prior consent, through the means provided in section 6 of this legal text.

6. ABOUT THE RIGHTS OF ACCESS, RECTIFICATION, ERASURE, OBJECTION, PORTABILITY, FORGETTING, AND LIMITATION IN THE PROCESSING

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

TheWhiteBoxCompany S.R.L. provides this legal guarantee, so at any time and/or when the User considers it appropriate, they may exercise their rights of Access, Rectification, Erasure, Objection, Portability, Forgetting, and Limitation in processing by writing to the contact email enabled for this purpose: [email protected] or sending a request by physical mail to: Calle Azofra 2, 5th Floor 3rd, 28050 Madrid. In both cases, attaching a copy of the passport or ID card (data subject) and expressly indicating in the subject line the request to be made: access, rectification, erasure, objection, portability, forgetting, or limitation in processing.

However, it is important for the User to note that the information shared with other Users through any means may continue to be visible, and TheWhiteBoxCompany S.R.L. disclaims all responsibility regarding the deletion of this information.

Similarly, TheWhiteBoxCompany S.R.L. does not control the system for updating third-party search mechanisms, and certain information from the public profile that has been canceled may still be contained in these mechanisms due to their redistribution on the Internet. In this case, Users are advised to contact the responsible parties of these platforms to request their deletion or exercise the right to be forgotten.

Below is a brief explanation of each of the rights that can be exercised:

Access

Through the exercise of this right, you can know what personal data are being processed, their purpose, origin, or possible transfer to third parties.

Rectification

Consists of modifying inaccurate or incomplete personal data, specifying in the request which data is desired to be modified.

Erasure

Allows the cancellation of personal data that are inadequate or excessive.

Objection

With the right to object, you can oppose the processing of data in cases such as: advertising and commercial prospecting activities or when such processing aims to make a decision concerning you based solely on automated processing of your personal data.

Portability

You may receive your personal data provided in a structured, commonly used, and machine-readable format and transmit them to another controller, provided that this is technically feasible.

Forgetting

Allows you to request the deletion of personal data without undue delay when one of the conditions provided for occurs. For example, illegal data processing, or when the purpose that motivated the processing or collection has disappeared.

Limitation in processing

In general, in cases where it is not clear whether personal data should be deleted, you can exercise the right to limit processing. This right exists in the following cases: (i) when the accuracy of the data is in doubt; (ii) when you as a User 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 to object to the processing is pending. The limitation means that personal data may only (except for storage) 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 public interest of the EU or a particular EU Member State. You must be informed before this limitation is lifted.

Likewise, the User has the right to lodge a complaint with the competent Supervisory Authority if they consider that the processing of personal data concerning them infringes the legislation and regulations on data protection; all without prejudice to any other administrative recourse or legal action.

Also, it is informed that data processing will not aim to make decisions about the User’s information based solely on automated processing -automated decisions-, including profiling, i.e., it does not include the automated profiling (and without human intervention) of the User’s personal data to evaluate personal aspects regarding them, such as analyzing or predicting aspects related to economic situations, health, preferences, or personal interests, reliability, or behavior, the User’s situation, all insofar as it has legal consequences for the User or significantly affects them. In any case, it would only apply when required by law, and such processing would be subject to appropriate safeguards, including specific information about the person as a data subject and the right to obtain human intervention, where appropriate; also to express their point of view, receive an explanation of the decision made after such evaluation, and challenge the decision, where appropriate.

7. LEGAL AGE

To be a User of the Website, it is necessary to be of legal age, so the User must be over 18 years old.

8. SECURITY MEASURES IN DATA COLLECTION

To ensure security on the Platform, a security system has been integrated to maintain the confidentiality and integrity of the data of Users that have been submitted or collected through the means mentioned in the first point.

Thus, TheWhiteBoxCompany S.R.L. maintains the security protection levels of your data required by Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, and the European General Data Protection Regulation 679/2016, of April 27, and has implemented all technical means at its disposal to prevent loss, misuse, alteration, unauthorized access, and theft of data that the User provides through the Platform.

Also, the User understands, accepts, and comprehends that security measures on the Internet are not impregnable and, therefore, undertakes to adopt the necessary security measures to trust the veracity of the website where they are entering their data. TheWhiteBoxCompany S.R.L. will also make every effort to guarantee the privacy and security of your identification data at all times, always using the utmost diligence and implementing necessary measures.

Therefore, the User is informed that they will be solely responsible for the security measures they implement regarding the protection of their data, whereby TheWhiteBoxCompany S.R.L. is not responsible for situations where the User has not implemented the corresponding security measures, nor for their consequences, as well as for causes or damages caused by third parties unrelated to the project, including fortuitous events and/or force majeure.

In accordance with the above, TheWhiteBoxCompany S.R.L. cannot guarantee that unauthorized third parties may become aware of the type, conditions, characteristics, and circumstances of the use that Users make of the services offered on the Platform. However, as a measure, terms of use have been established in the Legal Notice.

9. PERSONAL DATA RETENTION PERIOD

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

10. SOCIAL MEDIA POLICY

TheWhiteBoxCompany S.R.L. has a corporate profile on the social media platforms Twitter, LinkedIn, and Instagram. Therefore, in accordance with the provisions of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, and the European General Data Protection Regulation 679/2016, TheWhiteBoxCompany S.R.L. is the ‘Data Controller’ for your data due to the existence of these profiles on social networks and the fact that the User follows the company, and vice versa.

This means that if the User decides to join TheWhiteBoxCompany S.R.L.’s corporate profile as a follower or by giving a ‘Like’ to the content or profile, they accept this policy, where their rights are explained and how their data is used.

As the data controller, confidentiality in processing and compliance with your rights are guaranteed, always under the effects of the legislation and regulations mentioned.

Furthermore, Users are informed that these social networks are used to announce news or relevant information related to the services offered or on topics that are considered to be of interest to Users. By using the functionalities of these platforms, they may receive news with this type of information on their wall or profile.

However, it is also noted that there is no connection between TheWhiteBoxCompany S.R.L. and these platforms or social networks, so Users will accept their terms of use and conditions once they access them and/or validate their notices, terms, and conditions during the registration process, with TheWhiteBoxCompany S.R.L. not being responsible for the use or processing of their data that is done outside of the strict relationship and provision of services indicated in this policy.

11. MODIFICATION OF THIS PRIVACY POLICY

TheWhiteBoxCompany S.R.L. reserves the right to modify this policy to adapt it to future legislative or jurisprudential developments, as well as to future uses that it may project to make of the personal data of the Website Users. In the event that such modification affects Users regarding the processing of their data, for example, because some additional processing is going to be carried out, not previously informed, notification of this would be provided.

It is recommended that the User, in any case, proceed to read the Personal Data Protection Policy of the website each time they access it.

12. INTEGRATION WITH OTHER LEGAL TEXTS

This privacy policy complements the Legal Notice and Cookie Policy associated with this website.

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